Non-Burning Management

Alternatives on Agricultural

Lands in the Western United

States

Volume II:

Non-Burning Management

Alternatives and

Implementation Plan Strategies

FINAL

Prepared for:

The Fire Emissions Joint Forum of the

Western Regional Air Partnership

May 15, 2002

Eastern Research Group, Inc.
ERG No.: 3261.00.005.001

NON-BURNING MANAGEMENT ALTERNATIVES ON AGRICULTURAL

LANDS IN THE WESTERN UNITED STATES

VOLUME II:

NON-BURNING MANAGEMENT ALTERNATIVES AND

IMPLEMENTATION PLAN STRATEGIES

FINAL

Prepared for:

The Fire Emissions Joint Forum of the

Western Regional Air Partnership

Prepared by:

Eastern Research Group, Inc. (ERG)

8950 Cal Center Drive, Suite 260

Sacramento, California 95826

and

Enviro-Tech Communications

P.O. Box 593

Folsom, California 95763

May 15, 2002
DISCLAIMER

This document was developed for the Fire Emissions Joint Forum (FEJF) of the Western

Regional Air Partnership (WRAP) by Eastern Research Group, Inc., (ERG) and Enviro-Tech

Communications. Although the contents of this report have undergone extensive review by the

FEJF, the opinions, findings, and conclusions expressed represent those of ERG and EnviroTech Communications and not necessarily those of the members of the FEJF.
Vol. II: Non-Burning Management

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i

TABLE OF CONTENTS

Section Page

EXECUTIVE SUMMARY....................................................................................................... ES-1

1.0 INTRODUCTION............................................................................................................1-1

1.1 Study Objectives ..................................................................................................1-1

1.2 Data Collection Methodology ..............................................................................1-3

1.3 Document Organization .......................................................................................1-3

2.0 IDENTIFICATION OF NON-BURNING ALTERNATIVES........................................2-1

2.1 Research Strategy and Sources of Information....................................................2-1

2.2 Non-Burning Management Alternatives Identified..............................................2-3

2.2.1 Leaving Residues in Place........................................................................2-4

2.2.2 Improved Management Practices and Scientific Advancements .............2-4

2.2.3 Alternative Land Use ...............................................................................2-8

2.2.4 Residue Collection and Hauling for Use Offsite......................................2-9

3.0 METHODOLOGY FOR ASSESSING IMPACTS OF NON-BURNING

ALTERNATIVES............................................................................................................3-1

3.1 Defining and Establishing Criteria for Evaluating Impacts .................................3-2

3.1.1 Agronomic Impacts..................................................................................3-2

3.1.2 Environmental Impacts ............................................................................3-5

3.1.3 Health and Safety Impacts........................................................................3-6

3.1.4 Energy Impacts.........................................................................................3-6

3.1.5 Economic Impacts....................................................................................3-7

3.1.6 Social and Equity Issues.........................................................................3-13

3.1.7 Political Issues........................................................................................3-13

3.2 Methodology for Assessing Impacts..................................................................3-13

4.0 SELECTING NON-BURNING ALTERNATIVES: CASE STUDIES ..........................4-1

4.1 Rice Straw Case Study .........................................................................................4-1

4.1.1 Agronomic Impacts..................................................................................4-2

4.1.2 Environmental Impacts ............................................................................4-3

4.1.3 Health and Safety Impacts........................................................................4-4

4.1.4 Energy Impacts.........................................................................................4-4

4.1.5 Economic Impacts....................................................................................4-5

4.1.6 Social and Equity Issues...........................................................................4-9

4.1.7 Political Issues........................................................................................4-10

4.1.8 Summary of Impacts ..............................................................................4-10
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TABLE OF CONTENTS - CONTINUED

Section Page

4.2 Grass Seed Case Study.......................................................................................4-10

4.2.1 Agronomic Impacts................................................................................4-12

4.2.2 Environmental Impacts ..........................................................................4-12

4.2.3 Health and Safety Impacts......................................................................4-12

4.2.4 Energy Impacts.......................................................................................4-13

4.2.5 Economic Impacts..................................................................................4-13

4.2.6 Social and Equity Issues.........................................................................4-15

4.2.7 Political Issues........................................................................................4-15

4.2.8 Summary of Impacts ..............................................................................4-15

5.0 ACCOUNTABILITY MECHANISMS...........................................................................5-1

5.1 Research Strategy and Sources of Information....................................................5-1

5.2 Accountability Mechanisms Identified ................................................................5-2

5.2.1 Accountability Mechanisms 1 through 3 .................................................5-3

5.2.2 Accountability Mechanisms 4 through 6 .................................................5-6

5.2.3 Accountability Mechanisms 7 through 11 ...............................................5-7

5.2.4 Accountability Mechanisms 12 through 14 .............................................5-7

5.2.5 Accountability Mechanisms 15 through 17 .............................................5-8

5.3 Review and Discussion of the Accountability Mechanisms in Place in

the 15 Western States ...........................................................................................5-9

6.0 NON-STATUTORY ADMINISTRATIVE BARRIERS ................................................6-1

6.1 Research Strategy and Sources of Information....................................................6-1

6.2 Non-Statutory Administrative Barriers Identified................................................6-2

6.3 Project Case Study ...............................................................................................6-3

7.0 IMPLEMENTATION PLAN...........................................................................................7-1

7.1 Review of Project Background and Study Objectives .........................................7-1

7.2 Summary of Study Results...................................................................................7-2

7.3 Discussion of Results Pertaining to the Identification and Use of

Non-Burning Alternatives....................................................................................7-4

7.4 Developing Implementation Plans: Content .......................................................7-8

7.4.1 Strategic Plan............................................................................................7-9

7.4.2 Correctly Identified Target Audience and Stakeholders........................7-10

7.4.3 Clear Concise Messages and Program Purpose .....................................7-10

7.4.4 Effective Communication Tools and Strategies.....................................7-11

7.4.5 Effective Resource Allocation ...............................................................7-12

7.4.6 Reasonable Program Expectations.........................................................7-12
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TABLE OF CONTENTS - CONTINUED

Section Page

7.4.7 Solid Sustained Executive Commitment................................................7-13

7.4.8 Consistent Program Implementation......................................................7-13

7.5 Developing Implementation Plans: Recommended Strategy............................7-14

7.6 Agency Roles and Responsibilities....................................................................7-16

7.7 Strategies to Address Stakeholder Involvement.................................................7-18

7.8 Suggestions for Further Research and Information Development.....................7-22

8.0 REFERENCES.................................................................................................................8-1

APPENDIX A: LIST OF INFORMAL SURVEY PARTICIPANTS AND CONTACT

INFORMATION

APPENDIX B: PROJECT CASE STUDY: ALASKA AGRICULTURE PROJECT, DELTA

JUNCTION

APPENDIX C: RELEVANT VOLUME I TABLES
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FIGURES AND TABLES

Figures Page

Figure 4-1 Rice Straw - Cost of Implementing Non-Burning Alternatives...........................4-8

Figure 4-2 Grass Seed - Costs of Implementing Non-Burning Alternatives .......................4-14

Tables Page

Table ES-1 Average Percentage of Acres Harvested that are Burned for Selected Crops

in the Western United States ............................................................................. ES-4

Table 2-1 Non-Burning Alternatives Applicable by Fuel/Residue Type ............................2-5

Table 3-1 Impacts of Non-Burning Alternatives and Criteria for Assessing

Their Effects.........................................................................................................3-3

Table 3-2 Enterprise Budget for Tall Fescue Seed, Willamette Valley, Oregon (Dollars

Per Acre) ............................................................................................................3-10

Table 3-3 Summary of Criteria and Methods to Assess Impacts of Non-Burning

Management Alternatives ..................................................................................3-14

Table 3-4 Ranking of Non-Burning Management Alternatives .........................................3-16

Table 4-1 Rice Straw - Impacts of Non-Burning Alternatives...........................................4-11

Table 4-2 Grass Seed - Impacts of Non-Burning Alternatives...........................................4-16

Table 5-1 General Categories of Accountability Mechanisms Identified in the

15 Western States.................................................................................................5-4

Table 5-2 Accountability Mechanisms Important to the Use of Non-Burning

Alternatives ........................................................................................................5-10

Table 5-2a Comments Key for Table 5-2.............................................................................5-13

Table 6-1 Non-Statutory Administrative Barriers Identified in the 15 Western States........6-4
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ACRONYMS

ADEC Alaska Department of Environmental Conservation

AK Alaska

ARMS Agricultural Resource Management Study

ARS Agricultural Research Service

AZ Arizona

CA California

CARB California Air Resources Board

CDFA California Department of Food and Agriculture

CGE computable general equilibrium

CO Colorado

CO2 carbon dioxide

CRP Conservation Reserve Program

DEQ Department of Environmental Quality

ERG Eastern Research Group, Inc.

ETC Enviro-Tech Communications

FEJF Fire Emissions Joint Forum

FSA Farm Service Agency

GIS geographical information system

HI Hawaii

ID Idaho

KBG Kentucky bluegrass

MT Montana

NASS National Agricultural Statistics Service

ND North Dakota
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NM New Mexico

NOx nitrogen oxides

NRCS National Resources Conservation Commission

NV Nevada

OR Oregon

PM10 particulate matter less than 10 microns in aerodynamic diameter

QA/QC quality assurance/quality control

RIMSII Regional Input Output Modeling System, version 2

RL residue loading (tons/acre)

SD South Dakota

UC University of California

USDA United States Department of Agriculture

U.S. EPA United States Environmental Protection Agency

UT Utah

WA Washington

WESTAR Western States Air Resources Council

WGA Western Governors’ Association

WRAP Western Regional Air Partnership

WY Wyoming
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EXECUTIVE SUMMARY

The Western Regional Air Partnership and its Fire Emissions Joint Forum

(WRAP/FEJF) sponsored this project to investigate the alternatives to agricultural burning. The

geographical scope of the project includes the 15 Western states of Alaska, Arizona, California,

Colorado, Hawaii, Idaho, Montana, North Dakota, New Mexico, Nevada, Oregon, South Dakota,

Utah, Washington, Wyoming, and the tribal lands within these states.

The objectives of this project were designed to facilitate the development of crop

production and agricultural burning activity data to support analysis of alternatives to burning,

and they include:

• Development of a crop production database and an agricultural burning

activity database;

• Identification of the “universe” of potential non-burning management

alternatives;

• Design of a methodology to assess the impacts of alternatives (e.g.,

agronomic, environmental, economic, etc.);

• Identification of existing and potential accountability mechanisms for

tracking if, and which, non-burning alternatives are used by federal, state,

local, and tribal entities, and potential barriers to their implementation; and

• Development of a plan for implementing alternatives in the 15 Western

states.

This analysis was supported by a three-tiered approach to research. The three tiers

of sources included: (1) federal agencies such as the U.S. Department of Agriculture (USDA)

and the National Agricultural Statistics Service (NASS); (2) agencies such as the University

Agricultural Extension Services and state air agencies; and (3) private consortiums such as

growers, producers, distributors, and information clearinghouses.

The results of this project are documented in two reports under the title “NonBurning Management Alternatives on Agricultural Lands in the Western United States,” Volume

I and Volume II.
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Volume I: Agricultural Crop Production and Residue Burning in the Western

United States

The goal of the crop production database was to compile acres harvested by crop

at the county level for all major crops harvested and/or crops known to be burned in each of the

15 Western states. The crop production database was developed from three main sources of

information:

1. The NASS database;

2. State agricultural statistics data and reports; and

3. The 1997 Census of Agriculture.

Also, the Farm Service Agency (FSA) website was used to obtain information on lands included

in the Conservation Reserve Program (CRP). Although the target year for these data was 1996, it

was necessary to include 1997 data when 1996 data were missing for crops that were known to

be burned. The crop database underwent an extensive quality assurance/quality control (QA/QC)

process to ensure that at least 90 percent of the acres harvested of major (i.e., top 10) crops and

100 percent of all crops burned were accounted for in the database. In total, over 50 different

crops were grown in the 15 Western states which amounted to nearly 77,000,000 acres harvested

in a single year during the 1996/1997 timeframe. The resulting county-level data were mapped

using a geographical information system (GIS) (see Appendix B).

The agricultural burning database was developed for purposes of identifying the

extent of burning in the Western states, and to assist with the emissions inventory being

developed by the WRAP/FEJF. The burning database was compiled from three types of data

representing various geographical areas within the 15 Western states region:

• Burn permits issued or other mechanisms for determining actual burn

activity;

• Emissions inventory estimates;

• Anecdotal information from surveys sponsored by the WRAP/FEJF, the

Western States Air Resources Council (WESTAR); and

• Data resulting from peer review of the draft agricultural burn activity

database prepared for this project.
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Although a significant amount of data were obtained, burning was known to occur

in certain counties and states for which data were unavailable. A gap filling technique was

developed to provide estimates of acres and residues (tonnage) burned at the county level for

those unaccounted areas (i.e., North Dakota, New Mexico, and South Dakota). Table ES-1

shows the results of the overall database in terms of average percentage of acres burned by crop.

The resulting county-level data were mapped using GIS (see Appendix D).

Although the data that were collected and compiled were subject to specific

QA/QC procedures, some of the data and results have inherent uncertainty. These uncertainties

are due to such factors as use of “as is” data sets provided by the various sources and an

inconsistent definition of “agricultural burning” within these data sets. Also, the gap filling

averages used to provide missing data in some states cannot accurately depict actual burn activity

that occurred in those states. Even for some areas where gap filling was not used, information

originally provided for the draft database was revised with significantly different information

obtained during the peer review process (e.g., Utah). While it can be concluded that the peer

review process worked in this case, this result is illustrative of the need for a coordinated,

systematic process to collect agricultural burning data, establish data quality objectives, and

resolve conflicting data.

The researchers and peer reviewers contributing to the final agricultural burn

activity database made the following recommendations pertaining to future improvements of this

database:

1. Develop a mechanism (e.g., program, regulation, etc.) whereby the

relevant state, county, tribal, agricultural, and stakeholder entities establish

data quality objectives, define data sources, and compile data on a regular

basis to estimate the extent of agricultural burning in the Western United

States. Also, this mechanism should provide a consistent definition of the

residue types to be included in the agricultural burning category.

2. Conduct research to identify and/or calculate specific yield-based RL

factors for each geographical zone or area; and

3. Incorporate the impact of irrigated and nonirrigated land agricultural

practices.
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Table ES-1. Average Percentage of Acres Harvested that are Burned

for Selected Crops in the Western United States

Crop Acres Harvested1 Acres Burned

Overall Average

Percentage of Acres

Burned

Wheat 31,619,000 905,756 2.9%

Rice 500,000 254,706 50.9%

Corn 5,766,000 10,668 0.2%

Barley 5,696,900 137,872 2.4%

Sugarcane 42,900 30,000 69.9%

Orchards (Trees, Bushes, Vines) 2,497,767 530,100 21.2%

Grasses and Seeds 899,976 394,077 43.8%

CRP 286,1742 28,917 10.1%

Notes:

1

 Acres harvested and burned are for the 15 Western states, excluding Nevada because burning in that state was not identified for

specific crops .

2

 Value represents number of acres in the Conservation Reserve Program (CRP).
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Volume II: Non-Burning Management Alternatives and Implementation Plan

Strategies

The majority of information collected and reviewed in this study suggests that

states, local agencies, tribal communities, and fire control experts agree that the development and

use of non-burning alternatives is desirable. However, identification, development, and use of

these alternatives throughout the 15 Western states and tribal communities appears to be in the

fundamental research stages. This fact, in combination with the lack in most states of formal

requirements to implement non-burning alternatives, made identification and characterization of

alternatives a difficult task. Over 20 different non-burning alternatives were identified in the

following categories:

1. Leave residues in place either with or without infield residue treatment

(e.g., cut, mulch, and drop in place; soil incorporation);

2. Improved management practices and scientific advancements in

horticulture (e.g., genetic selection for disease/pest resistance or less fuel

residual);

3. Alternative land use (i.e., conservation tillage; land conversion to nonagricultural use; and plant crops with residues that do not need to be

burned); and

4. Residue collection and hauling for use offsite (e.g., haul to waste or

landfill facility; haul to ethanol production facility).

In order to determine the reasonableness, or feasibility, of implementing nonburning management alternatives, it is important to assess the impacts they have on agriculture,

the environment, and other aspects of society. In this study, the impacts to non-burning

alternatives were defined and criteria were established for assessing their effects and determining

the feasibility of implementation. The range of impacts due to implementation of non-burning

alternatives included:

• Agronomic impacts—what happens to the agricultural production unit

when an alternative is implemented, what the grower must do on the land

and how does that change affect the productivity of the land;

• Environmental impacts—what effect does the alternative have on

visibility, air quality, water quality, wildlife, and other vegetation;
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• Health and safety impacts—what hazards do alternatives present in the

workplace when implemented;

• Energy impacts—what are the impacts due to use of agricultural waste to

produce energy;

• Economic impacts—what is the cost of implementation considering the

difference in cost of agricultural operations between the traditional

burning operation and the new alternative approach;

• Social and equity issues—beyond cost considerations, how are the

growers, tribal communities, and other groups, affected by non-burning

alternatives, and what is the equity of controlling some burning/crops and

not others; and

• Political issues—when promotion of non-burning alternatives tends to

antagonize farmers and agricultural interest groups.

Criteria were developed to evaluate each potential impact relative to a particular

crop/alternative combination. A rating scheme using feasibility factors was developed that can be

applied to the potential impacts relevant to each alternative being evaluated (e.g., 0 = No impact;

1 = Some impact/problem; 2 = Definite problem; and 3 = Major problem). High ratings indicate

worse impacts relative to low ratings. This methodology is demonstrated in two case studies (for

rice straw and grass seed) in order to show how to quantify some impacts (e.g., costeffectiveness) and apply feasibility factors. As an example, the results showed for rice straw that

the average feasibility factors for the non-burning alternatives ranged from 1.1 (least negative

impact) for alternatives such as Cut/Collect and Haul to Ethanol Production Facility, to 2.1 (most

negative impact) for Land Conversion to Non-Agriculture.

Accountability mechanisms are procedures used for tracking if, and to what

extent, non-burning alternatives are used by local, state, tribal, or federal entities. In-place

mechanisms are categorized and discussed. How the mechanisms support or promote the use of

non-burning management alternatives is described in the implementation section (Section 7.0 of

Volume II). The information gathered on accountability mechanisms came from state, county,

local, and tribal environmental authorities representing all 15 Western states. The 17 different

accountability mechanisms were identified in the following categories:

a. Accountability initiated at the state or regional level (i.e., exemption or

inclusion of agricultural burning in regulations);
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b. Accountability at the state or local level that supports active regulation of

agricultural burning activities (e.g., existing regulations or rules

addressing agricultural burning activities);

c. Accountability at a programmatic level that supports a formal approval

and/or permitting process (e.g., smoke management programs);

d. Mechanisms that encourage accountability at the local level and provide

information for applying non-burning alternatives to current agricultural

burning practices (e.g., fuel types burned, emissions tracking); and

e. Mechanisms that facilitate and encourage the use of non-burning

alternatives (e.g., pre-burn permits, financial assistance).

The presence, or in some cases absence, of accountability mechanisms appears to

be an indicator of whether non-burning alternatives will be used in the Western states. In general,

for states with aggressive mandates to reduce agricultural burning such as Washington, Oregon,

and California, many accountability mechanisms are in place. These states also have the largest

number of non-burning alternatives in use. An important finding, which served to complicate the

identification and interpretation of information on accountability mechanisms, was the

inconsistent definition of “agricultural burning” in the 15 Western states. For example, in some

areas irrigation ditch, fenceline, and weed or land clearing for range land improvement is

included in regulations covering agricultural burning; in other areas these are not addressed.

Non-statutory administrative barriers are those situations, circumstances,

activities, or factors that serve to minimize, deter, or prevent the active use of non-burning

alternatives. Eighteen barriers that fall into the following four categories were identified:

• Economic challenges including labor costs; increased liability; disposal,

storage, packaging, or transport costs; availability and/or willingness of

investors to provide capital for new technologies or non-traditional

methods; market return; crop yield, quality, and production rates;

• Geographical limits due to climate or topography;

• Political, cultural, or religious practices including activities that center

around agriculture/harvest activities or tribal ceremonies; historical

promises of land as a lure to relocate;

• Public acceptance of a practice or program result (which may be closely

tied to aesthetics); and
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• Aesthetics including visual, olfactory, and auditory impacts, but possibly

nuisance due to plant debris or dust in or near homes and businesses.

A strategy for increasing the development and use of non-burning alternatives is

described as applicable to the 15 Western states. A detailed discussion lays out the critical

elements of an effective implementation plan, including items such as developing a strategic

plan, allocating resources, and providing consistent program implementation. Based on the

results of this study and the suggested guidelines, recommendations were made for developing

an successful non-burning alternatives program at the state, local, and tribal level:

1. Air quality or environmental program entities should conduct a focused

review to identify the nature and extent to which agricultural burning

contributes to air quality problems in the state, or local, or tribal area. A

starting point for this review could be the evaluation of agricultural

burning activity such as that presented in Section 3.0 of Volume II. A key

element of this review that should be included is a careful consideration of

the definition of “agricultural burning”. This is important so that accurate

comparisons can be made between other state, local or tribal programs.

2. If agricultural burning does not contribute significantly to local or

statewide air quality problems which fall under the jurisdiction of the

state, local or tribal entity, it is still recommended that the focused

program assessment also take into account, to the greatest extent possible,

the potential impacts agricultural burning may have on interstate regional

air quality.

3. If agricultural burning is not found to be a significant source of air

pollution for a given state, local region, tribal entity, or interstate region, it

may not be necessary to continue with non-burning alternatives program

development.

4. If agricultural burning is found to make a significant contribution to air

quality problems on either a local, state, tribal community, or regional

level, then the air quality or environmental agencies in authority in the

affected areas and the areas contributing to the problems should work

together to define solutions and develop non-burning alternatives

programs. This will help to ensure success on a regional level.

5. If agricultural burning is found to be a significant source of air pollution

for a given state, local region, tribal entity or interstate region, or if a given

entity desires to more effectively implement non-burning alternatives, then

an overall air quality review should be conducted to determine how to

integrate agricultural burning. One goal of this review would be to

determine which of the accountability mechanisms identified in Section
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5.0 of Volume II are in place and how they are being used. Table 5-2 of

Volume II can be used to determine specific accountability mechanisms

and tailor the agricultural burning program.

6. For those states, local regions, and tribal entities desiring to more

effectively address the use of non-burning alternatives in general, it is

recommended that a list of effective and economically viable non-burning

alternatives be developed (ideally including non-burning alternatives for

use by crop, by season, and by region or area). Table 2-1 of Volume II

(listing of non-burning alternatives by crop) can be used to identify

specific alternatives. The criteria, methodology, and case studies

described in Sections 3.0 and 4.0 of Volume II can be used to determine

feasibility.

7. It is further recommended that a list, or in some cases multiple lists, of

feasible non-burning alternatives should be maintained and updated

periodically by the participating lead public or private entity. The list(s)

should be made available using a variety of common effective

communication strategies, methods, and technologies.

8. If non-burning alternatives have not been previously identified or have not

been characterized for practical use an area, it is recommended that air

quality and environmental entities work closely with university and

agricultural extension scientists, affected agricultural community

stakeholders, and interested members of the public to identify and

characterize non-burning alternatives for specific use in their state or

region.

9. WRAP member states should form a technical working group or task force

to systematically identify and review the current use of non-burning

alternatives and to make recommendations, if desired, on how and where

the use of these non-burning alternatives may be improved or enhanced in

other states, local regions, and tribal communities.

10. WRAP member states should work together to begin to address ancillary

non-emission related program implementation issues, such as assisting the

affected agricultural community and local business developers with postresidue removal product development, manufacturing, distribution, and

marketing. Although this often falls outside the traditional charter of most

state air quality and environmental programs, it does not fall outside the

realm of services offered by other state agencies, boards and

environmental departments. Some states have taken steps to assist in the

research and development stages but their efforts have not extended to

distribution and marketing.
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11. It is highly recommended that the results of this and any of the above

mentioned program efforts be carried out in close coordination with a well

defined stakeholder outreach, education and communication program.

The agency roles and responsibilities associated with the identification,

development, and implementation of non-burning alternatives are not clearly identified for any

of the 15 Western states. It is recommended that as non-burning alternatives programs are

reviewed and developed in the future, that the air quality or environmental agency responsible

for developing the non-burning alternatives program (see Recommendation 4 above) be the

agency responsible for monitoring and implementation. Regional approaches to defining

responsibility for non-burning alternatives programs are also needed. This is in response to

instances such as the relocation of grass seed companies within the last five years from

Washington and Oregon to Wyoming where there are relatively less stringent air quality

regulations.

A well designed, closely coordinated, and consistently implemented stakeholder

involvement, outreach, and communication effort is essential to the success of any non-burning

alternatives program. Stakeholder involvement is not only an important way to encourage the use

of non-burning alternatives, it will be key in developing future alternatives to infield burning of

agricultural residues.

A number of directions for further research and information development are

recommended for the Western states and tribal communities in order to increase knowledge and

encourage use of feasible non-burning management alternatives:

• Better characterization of agricultural burning activities in the 15 Western

states and tribal communities, including development of a consistent

definition for “agricultural burning”;

• More thorough collection and evaluation of agricultural burning activity

data (e.g., daily acres burned by county, permits records, etc.) by

regulatory agencies and stakeholders;

• More thorough assessment of the air quality impacts from agricultural

burning;

• On-going investigation into effective non-burning alternatives;
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• Effective inclusion of stakeholders in the identification and

implementation of non-burning alternatives; and

• Development of a well designed, consistently implemented stakeholder

outreach, education, and communication programs that address local,

state, tribal, and regional issues pertaining non-burning alternative

program implementation.
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1.0 INTRODUCTION

Air emissions from burning agricultural residue, primarily consisting of fine

particulate matter (CARB, 1996), can impact visibility in Class I areas located near burns, as

well as those Class I areas located far away through regional transport. The Western Regional

Air Partnership (WRAP) and its Fire Emissions Joint Forum (FEJF) sponsored this study to

assess the non-burning alternatives to infield burning of agricultural residues, including their

impacts on the environment, economy, health and safety, society, politics, and on the business

and productivity of the agricultural industry. This study was performed under the Western

Governors’ Association (WGA) Contract 30203-31 by Eastern Research Group, Inc. (ERG) and

Enviro-Tech Communications (ETC).

In the context of this study, “agricultural burning” is defined as the burning of

organic crop residue consisting of field crops, wood, and leaves. Also, the burning of ditch banks

adjacent to, or associated with, crop production are included in this evaluation of alternatives to

agricultural burning. The geographical scope of the project includes the 15 Western states of

Alaska, Arizona, California, Colorado, Hawaii, Idaho, Montana, North Dakota, New Mexico,

Nevada, Oregon, South Dakota, Utah, Washington, and Wyoming, as well as tribal lands in these

states.

The temporal scope of the data collected for this project was 1996, chosen to

coincide with the WRAP base year emissions inventory effort. However, as described herein, it

was necessary to use data from 1997 or other years in some cases when 1996 data were not

available. This use of various years of data is an important limitation of the results of this

project. There is no assurance that 1996 crop production acreage, for example, is indicative of

2001 acreage due to factors such as increasing urbanization and regulatory impacts. Also, crop

rotations will impact year-to-year variations.

1.1 Study Objectives

The objectives of this study are diverse. They are designed to facilitate

development of crop production and agricultural burning activity data to support analysis of the

alternatives to burning—which is the main objective of this study. Also, these data are used for
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estimating emissions from agriculture burning under another project. The specific objectives of

this study are as follows:

1. Identification of crops grown and the extent to which residue is disposed

of through burning for the 15 Western states. The goal is to develop

county-level estimates of acres harvested and acres (or residues) burned by

crop for each of the 15 Western states.

2. Display of the crop and residue burned data using a geographical

information system (GIS). The goal is to illustrate the level of crop

production (acres harvested) and agricultural burning (acres or residues

burned in tons) within the 15 Western states. The GIS maps provide a

useful means to compare burning activity county-to-county, and to ensure

that all available data are included and that gap-filling procedures provide

accurate results.

3. Identification of potential alternatives to agricultural burning and

characterization of their agronomic, environmental, health and safety,

social, economic, and political impacts. A three-tiered approach to

collecting information on the potential impacts to non-burning alternatives

is employed. The three tiers include: (1) federal agencies such as the

United State Department of Agriculture (USDA); (2) state agencies such

as the University Agricultural Extension Services; and (3) private

consortiums such as growers, producers, distributors, and information

clearinghouses.

4. Development of criteria for selecting reasonable non-burning alternatives,

cost-abatement curves (i.e., cost of alternative by crop), and examples of

how to apply the criteria and cost-abatement curves (i.e., case studies) to

evaluate alternatives. The goal is to develop a global methodology that can

be used to assess the reasonableness of non-burning alternatives; thereby,

minimizing the need for region-and crop-specific assessment when

possible.

5. Identification of existing and potential accountability mechanisms for

tracking if, and which, non-burning alternatives are used by federal, state,

local, and tribal entities. The goal is to describe the specific mechanisms,

mainly statutory and currently in-place (e.g., required burn permits,

available financial incentives, agricultural burning exemptions, etc.), that

support, promote, or hinder the implementation of non-burning

alternatives.

6. Identification of existing and potential barriers to the use of non-burning

alternatives including non-statutory barriers (e.g., public acceptance,

cultural practices, etc.) and recommendations on how these can be

overcome. This objective presents the “flip-side” of Objective 5
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(accountability mechanisms) in order to understand the current limitations

(i.e., non-regulatory) to new program development and implementation of

non-burning alternatives.

7. Development of a plan for implementing a non-burning program based on

the analysis, findings, and recommendations developed in this study. The

goal of the implementation plan is to give the WRAP/FEJF a “course of

action” for implementing the recommendations developed under this

project. The plan recommends agency responsibilities for implementation,

and methods for disseminating information to stakeholders such as private

landowners and others who will ultimately be responsible for

implementing non-burning strategies.

1.2 Data Collection Methodology

Data were collected for this project based on a three-tiered approach. The first-tier

sources were expected to have the highest quality data; the second-tier sources were expected to

have readily available data; and, the third-tier sources were anticipated to provide additional

crop-, state-, or regional-specific information pertaining to the identification and use of nonburning management alternatives. The primary data sources used in this project were as follows:

• Tier 1 sources included the Farms Services Agency (FSA), Economic

Research Service, National Agricultural Statistics Service (NASS), USDA

within each state, several state Natural Resources Conservation Service

(NRCS) offices, Federal Agricultural Research Centers;

• Tier 2 sources included land grant universities, joint agency working

groups and task forces (e.g., California Advisory Committee on

Alternatives to Rice Straw Burning), State Agricultural Research Centers,

University Agricultural Extension Services, divisions or departments of

pesticide management; and

• Tier 3 sources included various private consortiums, farmers, distributors,

professional agricultural organizations, and information clearinghouses.

Specific data sources are discussed as they pertain to crop production and residue burning, and

identification and implementation of non-burning management practices.

1.3 Document Organization

This document is organized into two volumes that address all of the objectives of

the project. Earlier in-progress work was reported in three draft reports–the Task 1 Draft Report
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which addressed Objectives 1, 2, and 3; the Task 2 and Task 3 Draft Report which addressed

Objectives 4, 5, and (partially) 6; and, a Draft Final report which provided a complete initial

analysis addressing all objectives. A detailed description of the content of the final Volume I

and Volume II reports, and how the study objectives are addressed within each report is as

follows:

• Volume I: Agricultural Crop Production and Residue Burning in the

Western United States:

 Section 1.0 describes the project background and objectives. This

section also explains the data collection methodology and

organization and content of the Volume I and Volume II reports.

 Section 2.0 describes the development and results of the crop

production database (Objectives 1 and 2). This section quantifies

the level of crop production in each of the 15 Western states,

including the number of acres harvested by crop and county. The

results are presented in various tables and maps. A detailed quality

assurance/quality control (QA/QC) procedure ensures the accuracy

of the results.

 Section 3.0 describes the development and results of the

agricultural burning database (Objectives 1 and 2). This section

explains the data collection and compilation procedure used to

compile the burn activity data (e.g., acres and residues [tons]

burned by crop and county). Also, since only limited data on actual

burn activity is available in the 15 Western states, a gap-filling

procedure is employed to provide estimates in states/counties

where burning is known to occur, but records on specific quantities

are not tracked. The results are presented in various tables and

maps.

 Section 4.0 provides relevant conclusions and recommendations

pertaining to the crop production and agricultural burning

databases.

 Section 5.0 lists the references used in the development of Volume

I, including reports, journal articles, websites, and personal

communication.

 Appendix A contains a listing of the crop production data (i.e.,

acres harvested by crop, county, state).

 Appendix B contains the crop production GIS maps for each state.
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 Appendix C contains listings of the agricultural burning activity

data (i.e., residues burned [tons] by crop, county, state).

 Appendix D contains the agricultural burning activity GIS maps

for each state.

 Appendix E contains relevant tables from Volume II.

• Volume II: Non-Burning Management Alternatives and Implementation

Plan Strategies:

 Section 1.0 describes the project background and objectives. This

section also explains the data collection methodology and

organization and content of the Volume I and Volume II reports.

 Section 2.0 describes the “universe” of non-burning alternatives

which are in-use, or have been used in the past in the 15 Western

states (Objective 3). The alternatives are listed in a table based on

applicable crop and by category (i.e., leave in place, scientific

improvements, alternative land use, cut or collection and haul).

 Section 3.0 presents a methodology for assessing the impacts of

non-burning alternatives (Objective 4). First, the different types of

potential impacts are described (i.e., agronomic, environmental,

health and safety, energy, economics, social and equity issues, and

political). Criteria are presented to assist in evaluating the relative

feasibility of implementing alternatives (e.g., agronomic–soil

compression, increased water use; economic–not cost-effective,

substantial farm stress, etc.). A table shows available sources of

information and expected outcomes of the analysis for each of the

impacts. A methodology that can be used to evaluate these

impacts for various crops/alternatives is described.

 Section 4.0 contains two case studies that illustrate the

methodology developed to analyze the impacts of non-burning

alternatives (Objective 4). Impacts of non-burning alternatives for

two significant crops (rice and grass seed) are described. The

criteria developed in Section 3.0 are used to evaluate the impacts.

Cost curves display the economic impacts of implementing nonburning alternatives.

 Section 5.0 presents the accountability mechanisms currently in

place, or practiced in the past for implementing and tracking

progress of alternatives to agricultural burning (Objective 5). A

table lists the 17 mechanisms identified through an extensive

research effort, along with the state/county where each mechanism

is employed.
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 Section 6.0 describes the non-statutory administrative barriers

currently existing at the state level for each of the 15 Western

states (Objective 6). Where they exist, county- and local-level

barriers are discussed, along with barriers affecting tribal

communities’ ability to implement non-burning alternatives.

 Section 7.0 provides a summary of strategies for increasing the

development and use of non-burning management alternatives on

agricultural lands in the 15 Western states (Objective 7). A

summary of the overall results of the entire project is presented

along with conclusions and recommendations for future work. The

contents for each section of a “state-specific” implementation plan

are described, strategies to address stakeholder involvement are

given, and suggestions for further research and information

development are made.

 Section 8.0 lists the references used in the development of Volume

II, including reports, journal articles, websites, and personal

communication.

 Appendix A contains a detailed listing of the participants (i.e.,

name, affiliation, phone, fax, e-mail) contacted as part of the

informal survey conducted for this study.

 Appendix B gives a project case study (Alaska Agriculture Project,

Delta Junction) that presents realistic information on the success

and challenges encountered when developing and implementing a

non-burning program in the West.

 Appendix C contains relevant tables from Volume I.
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2.0 IDENTIFICATION OF NON-BURNING

ALTERNATIVES

This section describes the research approach used to identify and characterize

non-burning alternatives to infield burning of agricultural residues. Non-burning alternatives

that are currently in use, or have been used in the recent past, by crop residue (i.e., fuel type)

within the Western states are discussed.

2.1 Research Strategy and Sources of Information

The identification of existing non-burning alternatives is a complex task. In some

states, there are formal requirements to consider alternatives to infield agricultural burning of

residues prior to conducting field burning activities; however, there are typically no formal

requirements to actually implement non-burning alternatives. Information regarding the

availability, applicability, and cost effectiveness of non-burning alternatives is typically not

provided by the states. If alternatives are routinely used, the degree to which non-burning

alternatives are implemented is often not formally tracked. To collect the desired information

and to address the expectedly wide distribution of information sources, a systematic strategy to

collect necessary data was developed.

A comprehensive three-tiered approach was employed to identify and research the

various potential sources of information. The first level of sources included state environmental

agencies, boards and departments; their respective published reports and documents; and articles

and summary information posted on official state level websites. It was expected that if any

requirements to implement non-burning alternatives were in place at the state level (and if any

non-burning alternatives were identified, available, and in use) that this would be known by state

environmental agency contacts who had responsibility for implementing the agricultural burning

programs (Appendix A).

For states with aggressive mandates to reduce agricultural burning (e.g.,

Washington, Oregon and California) quality information on non-burning alternatives was readily

available. For those states with less aggressive smoke reduction programs or no formal

requirements to address agricultural burning, little or no direct information on non-burning
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alternatives was available. In these cases, additional contact persons and/or potential sources of

related information were obtained by talking with contact persons at the state environmental

agency, board and department level.

The additional contact persons and/or information sources identified were

typically directly affiliated with state or federal agricultural agencies. These comprised the

second level of information sources. The second level sources included state and federal

agricultural research centers, state university agricultural extension services offices, individual

university agricultural researchers, officially published research documents and reports, and

information posted on agricultural research related websites. For some states, the second level

sources extended to official state sanctioned or mandated, working groups that were examining

agricultural burning. These working groups were usually comprised of representatives from the

agricultural community, as well as state agricultural and state environmental agencies.

As the first and second level sources were investigated, a few third level sources

were identified. The third level information sources included various private businesses and

alternative agricultural information clearinghouses.

The first and second level sources which have provided information pertaining to

the identification and use of non-burning alternatives in each of the 15 Western states and tribal

lands, include in addition to other sources, the following:

• Informal telephone survey of state agencies (see Appendix A for a

complete list of contacts).

• California Air Resources Board:

 “The Economic Impacts of Alternatives to Open-Field Burning of

Agricultural Residues” (CARB, 1993);

 “Alternative Uses of Rice-Straw in California” (CARB, 1997a);

 “Progress Report on the Phase Down of Rice Straw Burning in the

Sacramento Valley Air Basin 1995-1996: 1997 Report to the

Legislature” (CARB, 1997b);

 “Rice Straw Diversion Plan” (CARB, 1998);
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• USDA Agricultural Research and Other Services:

 “ARS Helps Grass Seed Growers Produce Seed Without Field

Burning” (USDA, 1997a);

 “Less Fire, More Science for Grass Growers” (USDA, 1997b);

• Washington State Department of Ecology:

 “Cereal Grain Crops Best Management Practices” (WDOE, 2001);

 Washington Department of Ecology Agricultural Burning Task

Force (Pfeifer, 2001);

• Other sources:

 “Advisory Committee on Alternatives to Rice Straw Burning

Report” (SCAC, 1995);

 “Kentucky Bluegrass (KBG) Seed Crops–Agricultural

Methodologies for Reducing Air Emissions,” (USEPA, 2001a);

 “Best Management Practices when Harvesting Surplus Cereal

Straw,” (GOS, 2000);

 “Western States Agricultural Burning Survey”, (WESTAR, 1999);

 “Agricultural Burning Smoke Management Program Survey”,

2001, Draft Final Report, Contract No. 30202-11, (WRAP, 2001a);

 “Tribal Emission Inventories and Air Quality Data Gathering and

Assessment Project, Draft Report” (WRAP, 2001b); and

 “Earth Saver: Your Runoff and Sediment Control Solution”, (Earth

Saver, 2001).

2.2 Non-Burning Management Alternatives Identified

Historically, the types of non-burning agricultural management alternatives

available and/or in use have fallen into two categories: soil incorporation of residues in place,

and off-site residue use or disposal (CARB, 1993). However, currently non-burning alternatives

available and in use today in the Western states typically fall into four different categories and

they include:
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• Leave residues in place either with or without infield residue treatment;

• Improved management practices and scientific advancements in agronomy

and horticulture;

• Alternative land use; and

• Residue collection and hauling for use offsite.

A list of the non-burning alternatives identified by this project is shown in Table 2-1. These

alternatives are discussed in detail below.

2.2.1 Leaving Residues in Place

This category of non-burning alternatives includes simple cut and drop in place

residue treatments; more complex cut, mulch and drop in place methods; and traditional soil

incorporation of residues (wet or dry) including crimp and roll methods. It also includes more

complex field management strategies which utilize soil incorporation techniques coupled with

deliberate non-burning crop rotation or fallow field practices. Other non-small grain crops in the

rotations can utilize the residue quantity produced during the small grain sector soil

incorporation of the non-burning rotation (USDA, 1997c). Non-burning alternatives in this

category, if applicable to a given crop or fuel type, have the distinct advantage of being

convenient and typically less expensive initially; however, increased incidence of insect pest and

disease leading to reductions in crop quality and overall decreased profits have been identified.

Hidden costs associated with potential decreases in crop yields and increased use

of fertilizers and pesticides have also been cited as drawbacks to widespread use of these nonburning alternatives. More creative and complex field management strategies such as deliberate

fallow field or crop rotation practices to increase soil nutrients or break disease and pest cycles

offer promising improvements in the implementation of alternatives (NRCS, 2002). Factors such

as these are addressed during the assessment of impacts and barriers to the implementation of

these and other alternatives in Sections 3.0 through 6.0 of this report.

2.2.2 Improved Management Practices and Scientific Advancements

Non-burning management alternatives in this category include scientific advances

in horticulture which have led to the development of genetically distinct types of crops that have
Vol. II: Non-Burning Management 2-5

Alternatives, Final - May 2002

Table 2-1. Non-Burning Alternatives Applicable by Fuel/Residue Type

Fuel/Residue Leave Residues in Place

Scientific

Improvements

Alternative Land

Use Cut or Collect Residues 

Cut and Drop Residue in

Place

Soil Incorporation: Wet or

Dry

Soil Incorporation:

Fallow Field, Crop Rotation

Cut, Mulch, Drop

In Place; Leave Standing,

Crimp or Roll

Less Fuel Residual

Genetic Selection:

Genetic Selection:

Disease/Pest Resistance

Genetic Selection:

Other Tolerance

Plant Crops that do not Need

to be Burned

Land Conversion to NonAgricultural Use

Conservation Tillage

Practices

Cut, Mulch, and Haul

Residue

Haul to: Waste or Landfill

Facility

Haul to: Permitted

Burn Facility

Haul to: Power Generation

Facility

Haul to: Ethanol Production

Facility

Haul to: Redistribution

Facility

Haul to: Manufacturing/Use

Other

1

Fiberboard Facility

Grains and HayBarley •• • • • • • • ! • • ••• AK11 Corn • •• • • • ! •• • ••• • Hay; Alfalfa4 •• • • • • • • ! • • ••• • Hay; All Other •• • • • • • • ! • • ••• • Oats •• • • • • • • ! • • ••• AK11 Rice • CA • CA CA • CA CA ! CA CA CA CA CA CA CSorghum •• • • • • • • ! • • ••• • Wheat All • CA,

WA,

ND14

NM12

NM12,

ND14

• CA,

WA

• CA CA ! • CA CA,

NM12

CA CA CA,

AK11,

NM12

N

NM

Wheat; Winter All • ID13 ID13 •• • • • ! • • ••• ID13 Wheat; Other Spring •• • • • • • • ! • • ••• • Grain Other5 •• • • • • • • ! • • ••• • Grasses and SeedsSeeds; Alfalfa4 WA6 • • •• • • • ! • • ••• • Seeds; KentuckyBluegrass

• • WA,

OR, ID

WA,

OR, ID

• WA,

OR,

ID

WA,

OR,

ID

• • ! • • ••• • 

Seeds; Other7 • • WA,

OR, ID

WA,

OR, ID

• OR ••• ! • • ••• AK11 

OrchardAlmond CA •••• • CA CA CA • •Apple • • • • • •• • • • • Apricot • • • • • •• • • • • 
Table 2-1. Continued

Vol. II: Non-Burning Management 2-6

Alternatives, Final - May 2002 Fuel/Residue Leave Residues in Place Scientific Improvements Alternative Land Use Cut or Collect Residues a

Cut and Drop Residue in

Place

Soil Incorporation: Wet or

Dry

Soil Incorporation:

Fallow Field, Crop Rotation

Cut, Mulch, Drop

In Place; Leave Standing,

Crimp or Roll

Less Fuel Residual

Genetic Selection:

Genetic Selection:

Disease/Pest Resistance

Genetic Selection:

Other Tolerance

Plant Crops that do not Need

to be Burned

Land Conversion to NonAgricultural Use

Conservation Tillage

Practices

Cut, Mulch, and Haul

Residue

Haul to: Waste or Landfill

Facility

Haul to: Permitted

Burn Facility

Haul to: Power Generation

Facility

Haul to: Ethanol Production

Facility

Haul to: Redistribution

Facility

Haul to: Manufacturing/Use

Other1

Fiberboard Facility

Avocado • • • • • ••• • • •Cherry • • • • • ••• • • •Citrus • • • • • ••• • • •Grapes • • • • • ••• • • •Nectarines • • • • • ••• • • •Olive • • • • • ••• • • •Peach • • • • • ••• • • •Pear • • • • • ••• • • •Pecan • • • • • ••• • • •Plum and Prune • • • • • ••• • • •Walnut • •••• • CA CA CA • •Orchard Other8 • • • • • ••• • • •OtherAsparagus •• • • • • • • !Beans; Dry Edible • • •• • • • !Blueberries !Canola !Cotton • • •• • • !Mint •• • • • • • • !Peas, Dry Edible • • •• • • • !Peanuts !Pineapple HI • •• • • • ! ••• • • •Potatoes !Safflower • • • •• • • ! •Soybeans • • •• • • • !Sugarcane9 •• • • • !Other Fruits/Veg10 !
Table 2-1. Continued

Vol. II: Non-Burning Management 2-7

Alternatives, Final - May 2002 Fuel/Residue Leave Residues in Place Scientific Improvements Alternative Land Use Cut or Collect Residues 

Cut and Drop Residue in

Place

Soil Incorporation: Wet or

Dry

Soil Incorporation:

Fallow Field, Crop Rotation

Cut, Mulch, Drop

In Place; Leave Standing,

Crimp or Roll

Less Fuel Residual

Genetic Selection:

Genetic Selection:

Disease/Pest Resistance

Genetic Selection:

Other Tolerance

Plant Crops that do not Need

to be Burned

Land Conversion to NonAgricultural Use

Conservation Tillage

Practices

Cut, Mulch, and Haul

Residue

Haul to: Waste or Landfill

Facility

Haul to: Permitted

Burn Facility

Haul to: Power Generation

Facility

Haul to: Ethanol Production

Facility

Haul to: Redistribution

Facility

Haul to: Manufacturing/Use

Other1

Fiberboard Facility

Other Agricultural Related Fuels15Ditches • •Land ClearingRangelandSagebrush •• •Weeds •• •• = Potentially Applicable != Currently in practice in most of the 15 Western

states

WA, OR, etc. (i.e. State

1Includes cement products, building materials, paper packaging, and cardboard

manufacturing

2Includes food production such as mushroom composting, compost for dairy facilities manure

composting, animal bedding, landscaping

3Includes wind and soil erosion control, forestry rehabilitation, and landfill covering4Per John Burton, University of Nevada, Agricultural Extension office: "There are no

non-burning alternatives (in practice) for alfalfa in Nevada."

5Includes undefined grain and hay crops6Per Mark Wagoner, alfalfa seed farmer, Touchet, Washington.7Includes bermuda, fescue, rye, red clover and other grasses for seed production8Includes pistachio, nectarine, persimmon, kiwi, fig and other undefined orchard

crops/fuels

9Burning of sugarcane occurs prior to harvest so the use of non-burning alternatives that

address residues are not applicable (HARC, 2001).

10Includes cabbage, carrots, lettuce, tomatoes, green pe

coffee

11Per Phil Kaspari, University of Alaska Fairbanks, Ag12Per Denise McWilliams, New Mexico Cooperative E13Per Roger Veseth, University of Idaho, Agricultural E

these practices is highly dependent on rainfall in a gipotential is also a limiting factor. Less than 2% is haother products due to cost unfeasibility and limited m

14Per Duane Bergland, North Dakota University, Agric15The use of herbicides, including defoliants and pre-e

been considered in some research applications as an residues or to address the problem of weeds. Howevetypically found to be in use for agricultural field cropchemicals may interfere with subsequent crops. The be explored further as an alternative to irrigation ditc
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been selected because they offer a variety of desirable traits. The desirable traits can decrease

the need to burn subsequent crop residues. Such traits include increased plant resistance to pests

and disease. The development of crop varieties with increased resistance to pests and disease

increases the potential feasibility of implementing non-burning alternatives such as soil

incorporation.

These desirable traits also include genetic selection for less fuel residue.

Scientific advances such as this has made it possible to produce high quality grain, such as rice in

California, on crop varieties with shorter stalks. When harvested, these short stalk varieties

generate less residue (although this is somewhat offset by their relatively greater shoot density

and resulting residue biomass density). Scientific advances in horticulture have also led to the

genetic selection for such traits as increased tolerance to shade. For grass seed production in

states such as Washington and Oregon, this reduces the need to burn grass seed production crops

(i.e., ryegrass). Historically, agricultural burning was conducted to remove previous years’ leafy

residues and allow sunlight to reach the new growth areas. Removal via burning has also been

practiced to help control insects and disease, initiate quick growth, reduce seeding problems, and

increase seed production (USDA, 1997c).

This category also includes improved management practices such as crop rotation,

crop residue and tillage management alternate management, practices in combination with

limited burn activity, farm and equipment sanitation, and pest and nutrient management (NRCS,

2002). This category of alternatives is fairly new in its application to non-burning settings. It

will likely change greatly over time, but it offers several of the most promising alternatives

available to date. However, scientific improvements take time and a great deal of resources to

develop. It can take 10 years or more to develop improved traits and/or varieties.

2.2.3 Alternative Land Use

This category includes the use of alternatives to burning that actively change how

the agricultural land will be used. In some cases, growers and producers simply choose to plant

crops that do not require burning. In these cases a variety of economic, social and political

factors may play a role in the growers’ and producers’ decision. Such activity may come about

in response to a variety of factors, only some of which may be related to environmental concerns
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and the need to reduce air pollutants from the burning of agricultural residues. This category

also includes non-burning strategies which may take agricultural land completely out of crop

production. Again, these practices may or may not come about in response to the need to reduce

agricultural burning.

Based upon experience with agricultural burning practices and related issues

throughout the West as well as ongoing research on this project, it can be concluded that nonburning alternatives in this category are being implemented. However, it has not yet been

determined for what ultimate purpose and to what extent these non-burning alternative strategies

are actually being implemented. This category is presently much less defined than the other

three categories. Alternative agricultural non-burning land use decisions are expected to be more

related to economics and crop production environments, as well as land use pressures such as

urban growth and development, than they are to environmental pressures.

2.2.4 Residue Collection and Hauling for Use Offsite

This category of non-burning alternatives is quite broad in its applicability and

potential for widespread implementation. All non-burning alternatives in this category are based

on the premise that the crop residues, which remain after harvesting, are cut and/or otherwise

collected from the field and then mechanically hauled offsite. In some cases residues may be

collected and hauled away in alternate years in combination with some burning. Alternatives in

this category are largely defined by what happens to the crop residue once it leaves the field.

Non-burning management alternatives in this category include the following:

• General cut, mulch, and haul to some unspecified destination;

• Haul to a waste or landfill facility;

• Haul to a permitted burn facility;

• Haul to a power generation facility;

• Haul to fermentation facility for use in the production of ethanol and other

chemicals used in automotive fuels production;

• Haul to a redistribution facility;
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• Haul to a manufacturing or other use facility such as for cement, building

materials, paper packaging or cardboard;

• Haul to a fiberboard production facility;

• Haul to a particleboard facility;

• Haul to use as compost or mulch for food production or horticultural

practices;

• Haul to use as animal feed or bedding; and

• Haul to use for erosion control either as bales or as manufactured erosion

control products.

A number of these non-burning alternatives have been identified as either being in

use currently, or in use in the past, in Washington, California, North Dakota, Oregon and Idaho

(NDSU, 1998; OSUES USDA-ARS, 1989; OSU USDA-ARS, 1994; OSU USDA-ARS, 1995).

Decisions to implement alternatives from this category are related to economics, reliability of

residue production, consistent quality of residues available, and market demands for products

produced or the residue uses. These implications are addressed more extensively in Sections 3.0

through 7.0 of this report.
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3.0 METHODOLOGY FOR ASSESSING IMPACTS

OF NON-BURNING ALTERNATIVES

It is necessary to understand the impacts non-burning alternatives will have on

farms, the environment, and the regional society in order to assess the reasonableness of adopting

non-burning management alternatives. Often, in environmental policy, what seems like a good

idea to address one problem creates numerous unforeseen consequences in other areas.

In this section, impacts are assessed in several different ways in order to develop

reasonable criteria for use in determining adoption of non-burning alternatives. Also, the

impacts and criteria are summarized in such a manner as to provide an overall methodology for

assessing the impacts for different crop/non-burning alternative combinations. Section 4.0

contains two case studies that employ the criteria and methodology described here.

Changing agricultural practices affect not only the agronomy of the farm and its

economic well being but also effect the environment as the landscape changes and through

society as economic relationships shift and adjust. A shift to non-burning alternatives may have

profound effects on sub-regions and cultures. In this study, consideration of these impacts is

restricted in two ways.

First, this study does not consider changes in land use either as an alternative to

agricultural burning or as a consequence of regulation of agricultural practices. It is unclear

whether development of agricultural land for more urban uses reduces or increases overall air

emissions in an area. Urban land does not require burning of crop residues but automobiles,

home heating, barbecues, and lawn mowers contribute a variety of pollutants to the atmosphere.

The loss of farmland also reduces opportunities for ozone absorption in the area. In addition,

anecdotal evidence suggests that some growers, who find new burning regulation onerous, have

moved to states with fewer regulations. The grower’s decision to change crops or take land out

of agriculture is complex. The decision depends on local conditions, the economics of substitute

crops, the individual firm’s investment in machinery and equipment, and the owner’s attitude

toward rural life. Analysis of the decision requires different analytical tools than the assessment

of marginal changes in current practices. The decision analysis would entail modeling of all of

the grower’s options. These vary from crop to crop and region to region. Thus, likely price and
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production possibilities for many substitute operations in many different locations would need to

developed. To make a complete assessment, estimates of the likely environmental impacts of the

new crop’s production process would also be needed. The analysis described in this section, and

demonstrated in Section 4.0, is confined to the marginal changes in growing practices that can be

addressed with simpler analytical tools.

Second, many alternative practices having applicability to crops grown in the

Western states with implications for agricultural burning were identified (See Table 2-1).

Section 2.0 showed that a large subset of these nearly 1,000 possible combinations are feasible

non-burning alternative options. Since it is not possible to perform a detailed assessment of the

impacts of all of the feasible options with the time and resources available, a broad assessment of

the implications of adoption for all of the feasible combinations of crops and practices identified

in Section 2.0 was performed. This analysis provides a qualitative assessment of the issues that

would arise from promoting that crop-practice combination, and gives an indication of what may

or may not work and its implications.

3.1 Defining and Establishing Criteria for Evaluating Impacts

This section describes various possible impacts due to implementation of nonburning management alternatives and presents some criteria for evaluating their effects. The list

of impacts is not exhaustive, nor will all crops present the same effects. The assessment of any

alternative must be based on site specific information for the particular crop of interest. Some of

the elements which might be considered are summarized in Table 3-1 and discussed in detail

below.

3.1.1 Agronomic Impacts

The first consideration is what happens to the agricultural production unit. How

does changing to a non-burning alternative change what the grower must do on the land and how

does that change affect the productivity of the land? For example, the results of implementing a

non-burning alternative (e.g., cut and drop in place) on alfalfa seed residue resulted in increased

costs due to additional cultivation, and pesticide and herbicide applications, and decreased yield

(Wagoner, 2002). The field on which the alternative was used produced 1,070 tons/acre as

compared to other fields (where the residues were burned which produced 1,200 tons/acre. Also,
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Table 3-1. Impacts of Non-Burning Alternatives and Criteria

for Assessing Their Effects

Impact Criteria

Agronomic Soil compression

Soil erosion

Increased water use

Increased herbicide use

Increased pesticide use

Land constraint

Time or equipment constraint

Environmental Countervailing air emissions

Negative wildlife impacts

Water quality degradation

Health and Safety Increased equipment use

Increased chemical use

Energy No contribution to energy production

Increased energy use

Economics Not cost-effective

Moderate farm stress

Substantial farm stress

Negative regional impacts

Social and Equity Issues Raises tribal/cultural/historical issues

Raises small business issues

Impacts low resource farms

Political Issues Agricultural objections

Environmental objections
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since wheat was a rotation crop, additional land cultivation and water was needed to prepare soil

for wheat planting. Conversely, non-burning alternatives may well improve the quality and

structure of the soil. Each crop and region must be assessed independently to determine the

possible consequences of adopting a new technology. Some of the possible effects are outlined

here but the list is neither exhaustive nor all negative.

Farms may not have adequate land for storage of crop residue or labor time to

transport it. The basic logistics of the alternatives need to be assessed along with growers’

resources to accomplish them. For example, when ash is no longer left on the ground, soil

nutrient levels may be reduced. Burning also reduces weeds and plant pathogens as well as

removing refuges for insect pests. The alternative practice may require more passes over fields

with heavy equipment and so may compact the soil. Growers may need to increase application

of chemical fertilizers and pesticides to counteract these effects and maintain productivity over

the long term. In such cases where elimination of burning is not possible or desirable, a feasible

approach would be to combine burning with other non-burning management practices.

The results of field trials and experiences of early adopters of non-burning

alternative practices can be used to assess the impact of wider adoption of the practice. Variation

from place to place and crop to crop will need to be considered for each suggested alternative.

No single approach will be appropriate for all crops or all regions. This report focuses on

experiences in the 1990s. Time and budget constraints prevented a much deeper assessment of

earlier efforts or traditional approaches. Many possible alternatives discussed in this report are

somewhat speculative. Their assessment is based on anticipated changes in agriculture and

experience with similar new technologies. While these approaches may not be suitable for

adoption immediately, the charter for this project suggested the net be cast to include the

broadest array of alternatives foreseeable.

Information collected from experts is used to assess the field-level impacts of

each alternative. A more detailed assessment would require specific information from field trials

of the alternative practice in the crop of interest. Long term information would be especially

useful as long run productivity is the central agronomic impact. Substantiation and

quantification of changes in long-run productivity and non-air impacts, such as increased
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pesticide and herbicide use, would improve upon the assessment of feasibility using multi-year

crop budgets as was done in this study.

3.1.2 Environmental Impacts

The goal of promoting non-burning alternatives for agricultural activities is to

reduce the environmental impact of burning on visibility and air quality. However, it is expected

that the non-burning alternatives will entail new practices which may have their own

environmental consequences. For example, with increased tractor operations and transportation

of field and orchard debris, more diesel fuel will be burned. This may increase overall carbon

dioxide (CO2), nitrogen oxides (NOx), and particulate matter in the air. Also, primary particulate

matter from vehicle travel on paved and unpaved roads may increase. Additionally, increasing

tilling would increase airborne particulate matter. If power plant emissions are poorly

controlled, burning orchard or field crop wastes as fuel for electricity generation could reduce the

benefits of decreased open burning. Thus, reductions in emissions released from each nonburning alternative vis-à-vis current practices were determined. Also, the implications of using

agricultural waste for animal feed, mulch, and other uses were assessed by discussing the

environmental consequences of these alternatives with appropriate experts.

Fire is a powerful agent of ecological change. Wildlife adapts to the agricultural

practices in their environment. The timing of hay cutting, for example, has a tremendous effect

on the survival of ground-nesting birds. Any changes in burn practices are likely to alter these

adaptations. Follow-on effects from increased fertilizer and pesticide applications may have

negative water quality effects in surface or groundwater. These effects should be noted in

discussions with experts in the field who have experience with alternatives and highlighted

where applicable to alternatives.

Environmental impacts present a challenge for more detailed case studies.

Standard engineering data are used to estimate emissions increases from residue use that offset

emission reductions. However, for other types of impacts, only the relative significance of

adverse impacts (i.e., which non-burning alternatives raise the greatest environmental concerns)

were assessed in this analysis.
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3.1.3 Health and Safety Impacts

Alternatives must not increase the health or safety risks relative to current burning

practices. A literature review and interviews with local experts form the basis for assessing

qualitative changes in health and safety factors associated with current burning practices and the

major alternatives. Safety impacts must be carefully assessed for each alternative considered.

Where the alternative does not change the types of activities conducted appreciably, there is little

change in safety. Where the alternative entails using unusual equipment or operating equipment

in more perilous ways (e.g., driving tractors on steep slopes), then safety may be a serious

concern.

3.1.4 Energy Impacts

Crop residues can provide a renewable source of biomass for power generation.

Sugarcane bagasse and nutshell fueled furnaces have been added to sugar mills and nut

processing plants for many years. Existing stand-alone biomass power plants rely on urban and

lumber mill wood waste. They are capable of mixing in orchard prunings, but avoid non-woody

crop residues.

Field crop residues present several challenges for electricity generation. First,

they have a low heat content. It requires a large volume of straw to generate as much energy as a

cubic foot of natural gas. Collection is, therefore, often costly. Large volume also creates

handling problems in getting fuel into furnaces efficiently. Second, crop residues are seasonal.

Large amounts of straw need to be removed from fields at certain times of the year and may not

be available during the remainder of the year. Orchard pruning provides cuttings in late winter

but not at other times. As a consequence, large quantities of fuel will typically need to be stored

for considerable periods to keep a power plant operating continuously. Third, some residues

must be dried, chipped, or otherwise pre-processed to be efficient fuels. If energy must be

expended to process the residue, the possibility exists that it may require more energy to process

the fuel than the fuel provides when it is burned.

Even with these management issues, persistent high wholesale electricity prices

may make an agricultural residue burning power plant a viable option for some locations. CARB

(1993) and other sources have evaluated the prospect for new biomass power plants. In this
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study, each crop’s suitability as a fuel is scored. A detailed assessment would consider the

feasibility of power plants for the specific crop given the characteristics of the residue and prior

experience using it as a fuel.

3.1.5 Economic Impacts

The economic impact of adopting non-burning alternatives is an important

consideration. One criterion for selecting the preferable options will be cost effectiveness, e.g.,

the lowest cost per ton of particulate emissions reduced, such as particulate matter less than 10

microns in aerodynamic diameter (PM10). This is a useful standard since it can be used to

directly compare the agricultural non-burning alternatives with industrial and automotive PM10

source reduction programs. Costs of adopting a non-burning agricultural alternative are

measured by the difference in the cost of agricultural operations between the traditional burning

operation and the new alternative approach. Each alternative is assessed at the enterprise, farm,

and regional level. While the cost of implementing an alternative for a given farm field is a

component of the selection among alternatives, the viability of any alternative also depends on

the farm’s ability to remain profitable given the new labor, capital, and land requirements of the

new technology. The ability of farms to finance the change and continue in business must also

be assessed. Regionally, the non-burning alternatives may shift employment and supply

relationships.

In this analysis, information on whether the alternative is cost-effective,

affordable, and regionally sustainable was requested during an informal survey of stakeholders

affected by and knowledgeable of agricultural burning and alternatives (see Section 5.0). A more

detailed assessment would include comparative enterprise budgets, financial ratio analysis, and

regional impact analysis.

Cost-Effectiveness – Enterprise Level Assessment

Engineers can estimate the tonnage of PM10 released from agricultural burning of

different crops each year using residue loading factors (tons of residue per acre) and emission

factors (pounds of pollutant per ton of residue burned). (Usage of these factors is illustrated in

Section 4.0 of this report.) Each fuel source has a characteristic profile of burn products. While

the profile varies with weather conditions, average values will be used to estimate emissions per
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ton of fuel burned. This rate of emission can be expanded to an acreage basis using average fuel

production per acre harvested. Burn reduction programs in Washington and Oregon have

significantly reduced human exposure to particulates without eliminating burning by permitting

burns when the wind will carry pollutants away from population centers (WDOE, 1998a). A

detailed GIS system combined with regional wind pattern and population information could

conceivably develop estimates of expected population exposed to smoke under different

permitting scenarios. For alternative development, however, a reasonable goal is overall

reduction in particulate emissions, and thus considers cost effectiveness in terms of reduced

tonnage of emissions rather than reduced human exposures.

Crop production budgets are used to estimate the incremental costs per acre of the

alternatives. Basically, a farmer has four options:

1. Leave the residue in place,

2. Haul it somewhere else,

3. Use varieties selected for characteristics that reduce the need to burn; or

4. Use the land for some other purpose that does not require burning, either a

different crop or a non-agricultural use.

The first three options change operations on the farm and may affect operations

elsewhere (e.g., wherever you haul the residue). While these may be costly changes, the

producer continues to produce the same crop and the basic structure of the farm economy

remains intact. The fourth option is much more consequential. Although changing crops may be

a significant contributor to reduced particulate emissions, it raises large issues about the

character of rural areas and the future of rural development.

For example, in Maricopa County, Arizona, cotton is being replaced with alfalfa

resulting in a fewer air quality impacts to “neighbors” due to less frequent tillage and planting

(i.e., every year with cotton as compared to every three or four years with alfalfa) (Rogers,

2002). Although this switch from cotton to alfalfa appears to be driven mainly by economics due

to improving local markets for alfalfa, and is not related to implementation as a non-burning

alternative, the air quality benefits appear to be substantial. Also, the economic benefits from the

growing market for alfalfa is somewhat offset by the increased costs to farmers when switching
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due to several factors such as increased expenses associated with the need to buy new equipment,

cost of alfalfa seed, and employing laser leveling.

Crop production budgets for current agricultural practices show all of the

necessary tasks to raise the crop and their costs per acre by expenditure category for a well-run

operation. Budgets do not represent the average but generally show an idealized production

operation using the best practices suggested by the state cooperative extension service. Budgets

have also been produced for some non-burning alternative practices.

Many enterprise budgets show a loss whether or not the crop is actually viable. A

more accurate measure of profitability is revenues minus variable costs. Many growers will

continue to operate at a paper loss as long as their cash flow is adequate to cover variable costs

and the essential fixed costs (e.g. debt service). If the additional costs of the alternative practice

make the variable costs greater than revenues, then that alternative is definitely not affordable. If

the alternative practice reduces net income considerably, growers will reassess the profitability

of that enterprise and may switch to another crop or to a different non-burning alternative.

Table 3-2 shows a budget for producing tall fescue seed. The propane burn

alternative assumes straw is baled, stacked, and later burned or composted elsewhere on the

farm. It incurs additional variable costs of $28.16/acre and additional fixed costs of $18.47/acre

over the current open burn practice. Propane burn continues to have a positive net income and so

is a viable alternative. Crew-cutting also involves baling excess straw followed by one pass over

the field with a crew-cutter. The additional pass involves more equipment for a longer time

period so fixed costs are higher than the other alternatives. Although variable costs are slightly

lower than propane burning, the crew-cut alternative has a negative net income. However, crew

cut gross income minus variable costs is greater than the propane burn approach so crew cut is

also a viable option. This budget assumes yield is unchanged through time no matter which

option is selected so a simple analysis of an annual budget is appropriate.

Several alternatives have the possibility of producing revenue from new byproducts. A complete feasibility study should be conducted for any new product, including the

costs of marketing and delivering it. Such studies are well beyond the scope of work for this

project so this study only indicates where such opportunities may be available. In this study,
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Table 3-2. Enterprise Budget for Tall Fescue Seed,

Willamette Valley, Oregon (Dollars per Acre)

Alternative Difference from Conventional

Budget Element Open Burn Propane Burn Crew-Cut Propane Burn Crew-Cut

Total Gross Income 542.75 542.75 542.75 0 0

Total Variable Cost 278.75 306.91 304.24 28.16 25.49

Gross Income – Variable Cost 264.00 235.84 238.51 -28.16 -25.49

Total Fixed Cost 213.52 231.99 242.67 18.47 29.15

Total of All Costs 492.27 538.9 546.91 46.63 54.64

Net Projected Returns 50.48 3.85 -4.16 -46.63 -54.64

Source: Cross, et al.,1992.
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current prices of similar products are used to indicate the possible net revenues given current

market conditions. Where the alternative practice has long term effects on the productivity of

the land, such as by promoting pest survival, costs will be annualized over the cropping cycle to

determine the costs in terms of yield as well as the direct costs of the alternative. Annualization

converts a flow of unequal payments through a period of time to an equivalent series of equal

annual flows.

Cost effectiveness is measured as the change in budgeted expenditures to

implement the alternative per ton of PM10 avoided by adopting the alternative practice. Most

costs of the alternative practices are variable and emissions will be defined per acre, so

abatement cost curves will be essentially linear. Key assumptions can be tested by sensitivity

analysis.

Affordability – Farm Level

Growers will not adopt a new technology or practice unless it makes economic

sense for their farm as a whole, thus the impact of the alternatives on the agricultural production

farm’s profitability and financial stability should be assessed. This is often evaluated in terms of

changes in the farm’s income and financial ratios. If income falls significantly, or financial

ratios fall into a range where banks will hesitate to loan money, then the alternative may not be

affordable and will not be widely adopted. Crop budgets are used to assess whether a typical

well-managed operation would confront financial difficulties in implementing the alternative

technologies. Balance sheets and other information from the USDA Agricultural Resource

Management Study (ARMS), an annual survey, serve as a baseline for analysis (USDA, 2001).

The most intuitively direct measure of affordability is net income. As most farms

are privately held and only report financial information for tax purposes, they have a disincentive

to report positive net income. Percentage change limits are set such that a change in average

revenues minus variable costs of a given percentage is considered to indicate a moderate

affordability problem. U.S. EPA typically uses changes of 3 or 5 percent as indicators of

moderate stress. Negative net revenue indicates severe stress (USEPA, 2001b).

Debt-to-asset ratios should also be considered. Banks and other lenders have

criteria for lending to agricultural firms which include the levels of various asset ratios. If a
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farm’s debts become too high in proportion to its total assets, the long-term burden of debt can

require a large share of cash resources. The higher probability of default discourages banks from

lending additional funds to the farm, making equipment replacement costly and difficult. The

USDA considers a debt-to-asset ratio higher than 0.40 to be an indicator of financial distress

(USDA, 1999).

Indirect Impacts – Regional Level

Changes in farm operations can have impacts in the regional economy.

Collecting and transporting crop residue may require extra labor which may generate more

income for farm workers. Demand for additional labor may raise wage rates, changing the cost

structure for producers, and, ultimately, creating different optimal sizes and capitalization for

farming operations. New equipment that might be needed or faster depreciation of old

equipment may increase sales at agricultural implement dealers. Such effects generate ripple

effects throughout the regional economy. The California Air Resources Board (CARB, 1993)

used a computable general equilibrium (CGE) model to trace the impact on prices and quantities

of adopting different policy options for burning crop residue. CGE is particularly useful in

assessing agricultural income changes from switching crops or exiting agriculture. Only rice

straw burning in the Sacramento Valley was assessed with CGE in the CARB report.

Preliminary assessment of changes for other crops showed the regional impacts were unlikely to

be significant and did not merit a full CGE analysis. However, regional dislocations from

adoption of non-burning alternative practices can occur (e.g., relocation of grass seed production

from Oregon and Washington to Wyoming, which is discussed in Section 5.0 of this report).

In those case studies where alternatives appear to generate changes that may

ripple through the economy, publicly available multipliers from the Regional Input-Output

Modeling System, Version 2 (RIMS II) (USDC, 1997) are used to derive a first approximation of

the impact. The multiplier analysis will estimate indirect and induced changes in employment

and output for all sectors of the economy from output changes in the farm sector. CGE modeling

is more sophisticated than multiplier analysis and can answer a variety of questions about

possible outcomes and the effects of changing assumptions. CGE analysis may be useful at a

later stage in alternatives assessments to assess more detailed regulatory options.
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3.1.6 Social and Equity Issues

There may be burning practices or non-burning alternatives that have cultural

and/or historical implications unique to certain groups beyond cost considerations, such as small

growers, culturally diverse groups, or residents of tribal lands. (Survey respondents were asked if

they are aware of any special considerations with regard to non-burning alternatives; however,

no particular issues were raised.) A more detailed analysis would indicate likely air quality

results with and without a group’s adoption of non-burning alternatives and will explore state

options to address the issue.

3.1.7 Political Issues

Promotion of non-burning alternatives by government, even on a voluntary basis,

has the potential to antagonize agricultural interest groups. Most growers, producers, and

distributors are politically well organized. They routinely advocate their concerns in state

legislatures through crop specific organizations and more general agricultural lobbies.

Environmental and recreation interests are also well organized. Any effort to induce change may

face political pressure on several fronts. Survey respondents were asked if they are aware of any

specific groups with strong positions on agricultural burning. The strength and willingness to

compromise of the various interest groups varies from state to state. While stakeholders can

indicate potential pitfalls, governments seeking to implement a program of non-burning

alternatives will need to make their own assessments of the political viability of any alternatives

on a case-by-case basis.

3.2 Methodology for Assessing Impacts

Table 3-3 summarizes the potential impacts from implementing non-burning

alternatives and their associated criteria for evaluation. Also, the table gives a summary of the

methods and information sources needed to assess the impacts according to their applicable

criteria. The methods include a combination of qualitative (e.g., stakeholder surveys and

anecdotal information) and quantitative tools (i.e., crop budgets and RIMS multipliers) as

described above. Expected results are provided in order to help the assessor of the impacts to

focus the analysis on the most significant impacts, depending on the crop/alternative(s) chosen.
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Alternatives, Final - May 2002 Table 3-3. Summary of Criteria and Methods to Assess Impacts of Non-Burning Manag

Impact Criteria Information Sources Methods 

Agronomic: Soil compression Problem f

productiv

Soil erosion Problem fIncreased water use Little incrIncreased herbicide use Likely pr

burning

Increased pesticide use Likely pr

shelter in 

Land constraint May be pTime or equipment constraint

Prior trials;Agronomic experts Apply results from prior trials to prospective sites

May be p

Environmental:

Offsetting air emissions Burning facilities

emissions history

Compare emissions from burned fields with emissionsfrom facilities

Burning aless pollu

Negative wildlife impacts Prior trials Anecdotal evidence of changes in habitat Little chaWater quality degradation Prior trials Qualitative assessment of likely changes Little cha

Health and Safety:

Increased equipment useIncreased chemical use

Crop budgets;Agricultural Injurydatabase

Budgets will indicate extra equipment passes; applyinjury rates per hour and compare with injuries fromburning

Small incincreased 

Energy:

No contribution to energyproduction

Alternative description Use engineering information to estimate energy

produced by using residue as fuel

Some oppprices are 

Increased energy use Life cycle energy

assessment

Use agricultural engineering information to estimatechanges in energy use.

Small cha

Economics:

Not cost-effective Crop budgets; engineers’

emissions estimates

Estimate costs of farming practice changes per unit ofemissions reduced

Reducing cost effec

Moderate farm stress Crop budgets; ARMS

survey data

Estimate impact of changes in farm costs on farmfinancial ratios

Minor im

Substantial farm stress Crop budgets; ARMS

survey data

Estimate impact of changes in farm costs on farmfinancial ratios

Very few 

Negative regional impacts RIMS multipliers;

aggregated costs

Estimate employment and other changes from multiplierchanges

Small reg

Social and Equity Issues:

Raises tribal/cultural/historical issues

Survey Qualitative assessment Unknown

Raises small business issues Survey Anecdotal evidence Some proImpacts low resource farms Survey; Crop budgets;

ARMS data

Anecdotal evidence and estimated impacts from farmcosts

Some sm

Political Issues:

Raises agricultural objections Survey Anecdotal evidence Some objRaises environmentalobjections

Survey Anecdotal evidence Some obj
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After the impacts/criteria have been evaluated, the assessor can then estimate the

feasibility of a given alternative according to the ranking scheme shown on Table 3-4. The

assessor needs to assign a numerical value from 0 to 3 to indicate the existence and/or

significance of the negative outcome of the impact likely to occur (i.e., “0” means no problem

exists or is likely to occur if the alternative is implemented; “3” means a major problem exists or

is likely to occur if the alternative is implemented). While this is a somewhat subjective

assessment, it can be valuable in determining the relative severity of a potential impacts. The

same person should assign all feasibility factors for a given crop/alternative process. This simple

process can address alternatives where there is only a limited amount of information. By

assessing adoption of similar alternatives in similar situations, the rough scale of the alternative’s

impacts can be evaluated. When more information becomes available, a more sophisticated

measurement scheme can be employed. This methodology is used in Section 4.0 to evaluate two

case studies for implementation of non-burning alternatives.
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Alternatives, Final - May 2002 Table 3-4. Ranking of Non-Burning Management Alternatives1 Leave Residues in Place Cut or Collect Residues and Haul 

Potential Impacts and Criteria

Mulch Residue

Soil Incorporation:

Wet or Dry

Soil Incorporation:

Fallow Field

Waste Facility

Permitted Burn

Facility

Power Generation

Facility

Ethanol Production

Facility

Redistribution

Facility

Manufacturing or

Use Facility

Fiber Board

Facility

Particle Board

Facility

Use as Compost or

Mulch

Use as Animal Feed

Use For Erosion

Control

Agronomic:

Soil compression 1 3 2 2 2 2 2 2 2 2 2 2 2 2 Soil erosion 1 3 1 0 0 0 0 0 0 0 0 0 0 0 Increased water use 1 3 1 0 0 0 0 0 0 0 0 0 0 0 Increased herbicide use 2 2 2 0 0 0 0 0 0 0 0 0 0 0 Increased pesticide use 2 2 2 0 0 0 0 0 0 0 0 0 0 0 Land constraint 1 0 0 2 2 2 2 2 2 2 2 2 2 2 Time or equipment constraint 1 2 2 2 2 2 2 2 2 2 2 2 2 2 

Environmental:

Countervailing air emissions 0 2 1 2 1 1 1 1 1 2 2 0 1 1 Negative wildlife impacts 1 2 2 0 0 0 0 0 0 0 0 0 0 0 Water quality degradation 1 2 1 3 3 2 2 2 2 2 2 0 1 0 

Health and Safety:

Increased equipment use 1 1 1 2 2 2 2 2 2 2 2 2 1 2 Increased chemical use 1 1 1 2 2 2 2 2 2 2 2 2 1 2 

Energy Impacts:

No contribution to energy production 2 2 2 2 2 0 0 2 2 1 1 2 2 2 Increased energy use 2 2 2 2 2 0 0 2 2 1 1 2 2 2 

Economics:

Not cost-effective 2 2 2 3 3 1 1 1 1 1 1 2 2 2  Farm financial stress 2 2 2 3 3 1 1 1 1 1 1 2 2 2 Negative regional impacts 1 1 1 2 2 1 1 1 1 1 1 1 1 1 

Social and Equity:

Raises tribal/cultural/historical issues Raises small business issues 1 2 2 3 3 2 2 2 2 2 2 2 2 2 Impacts low resource farms 2 2 2 3 3 2 2 2 2 2 2 2 2 2 

Political:

Agricultural objections 2 2 2 3 3 0 0 0 0 0 0 0 0 0 Environmental objections 2 1 1 3 3 1 1 2 1 1 1 0 0 0 

Average Score 1.4 1.8 1.6 1.9 1.9 1.1 1.1 1.2 1.2 1.2 1.2 1.1 1.1 1.1 

1 See Section 4.0, Tables 4-1 and 4-2 for examples of using feasibility factors.

Steps for Ranking Non-Burning Management Alter

1. Assign feasibility factors to indicate a negative outcome as 

0 = No problem exists;1 = Problem may exist;2 = Problem does exist;3 = Major problem exists; andBlank= Not relevant or viable

2. Calculate the average score for each alternative using the 

factors for the relevant impacts.

3. The lowest scores indicate the most feasible alternatives.
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4.0 SELECTING NON-BURNING ALTERNATIVES:

CASE STUDIES

This section presents two case studies that assess impacts of non-burning

alternatives. These case studies illustrate the use of criteria to determine the feasibility of

adoption of the non-burning alternatives. The three-tier data collection effort first described in

Section 2.0, was implemented throughout the study, and provided data for the case study

analyses. The data that have been collected are described in detail in Section 5.0 of this report.

Open-field burning has been the traditional method to dispose of rice straw and

control disease. Alternatives to burning present different sets of challenges to rice producers and

their communities. A case study of rice straw alternatives demonstrates the methods of

assessment that lead to criteria for adoption. Burning has also been a traditional treatment for

grass seed fields. A second case study considers impacts of reduced burning on grass seed

producers.

4.1 Rice Straw Case Study

More than 400,000 acres are devoted to rice cultivation in California. When rice

fields are harvested, a standing crop of rice straw remains. The least costly means to dispose of

the straw is to burn the open field. Burning can create smoke in nearby communities, and

sometimes interfere with driving and air travel. Efforts have been underway since the 1970s to

reduce the extent of rice straw burning and ensure that it occurs only when meteorological

conditions are favorable. Since 1992, rice burning in the Sacramento Valley has been curtailed

from 90 percent of planted acreage to less than 30 percent. Beginning in 2001, the annual goal is

to burn the lesser of 25 percent of planted acres or 125,000 acres exclusively for disease control

purposes. In fact, the industry estimates that under this program, less than 20 percent of its

acreage will be burned (Buttner, 2002).

The legislated goal of reduced acreage burned has driven an effort to develop

alternatives to burning. Rice straw is a re-newable biomass resource that can be used in many

different processes and products. Among the uses being developed are ethanol production,

particleboard, paper, composite materials, erosion control products, cattle feed, animal bedding,
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and straw bale construction. Agricultural and construction industries use rice straw as a

mulching material and bale barrier to reduce sediment runoff from bare soil and promote new

growth. California has sought to promote alternative uses through grants and other mechanisms

to initiate markets for rice straw. These efforts continue to show promise even though they have

not yet been entirely accepted (CIWB, 1998).

4.1.1 Agronomic Impacts

After rice is harvested, rice straw is burned to prevent overwintering of disease

organisms, dispose of the straw, and prepare the field for planting. There are, basically, two

alternatives to burning rice straw. The first is to incorporate it into the soil in the field. The

other is to remove it and utilize it in some other fashion.

Continuous soil incorporation by chopping and discing or rolling the residue into

the soil can promote stem rot infection and changes soil tilth. In the long run, these changes may

lead to unsuccessful decomposition, decreased yields, and more difficult working conditions as

the fields become slower to dry out (REI, 1997). Yield decline represents the largest financial

risk to growers from soil incorporation (CARB, 1993). Chopping and discing takes considerably

more labor and machine time than burning, but probably does not require the farm to purchase

new equipment. Disease build-up may be offset with greater application rates for pesticides.

However, the consequences to soil structure of increased traffic over the field cannot be easily

mitigated. A combination of soil incorporation and occasional burns may be a viable alternative

to annual burning. Winter flooding can also mitigate many of the disadvantages of soil

incorporation and improve nutrient cycling and yields. However, it requires greater use of water

and fuel which contribute to higher costs (CARB, 1993).

Removing rice straw from the field avoids some of the agronomic issues of soil

incorporation but creates a large volume of material that must be used or disposed. Other than

burning or composting in windrows, removal techniques require baling straw for transport.

Purchasing a baler or hiring custom baling services is a significant cost of any removal

alternative. Baling standards for many alternative uses are quite stringent which adds to the costs

of removal (REI, 1997). Techniques requiring additional passes of machinery over the field

raises the risks of soil compaction and possible delays from wet field conditions due to excess
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soil compaction. These may be addressed with more expensive technological options, such as

tracks or flotation wheels on balers (REI, 1997).

Soil incorporation will continue to require burning or winter flooding of some rice

land each year to maintain yields. Removal of rice straw for other uses may be a viable

alternative if the producer can offset the added costs of removal with profits from sale of the

product.

4.1.2 Environmental Impacts

The goal of promoting non-burning alternatives for agricultural activities is to

reduce the environmental impact of burning on visibility and air quality. Alternatives, however,

have environmental consequences of their own. Soil incorporation of rice straw reduces smoke

and carbon dioxide emissions but increases methane production as organic matter decomposes in

the wet soil. Methane is a powerful greenhouse gas with 20 times the heat trapping potential of

carbon dioxide. Methane emissions increase 3 to 12 times when rice straw is added to the soil

rather than burned (REI, 1997). Clearly, there is a local/global trade-off in environmental

impacts from soil incorporation.

Other alternative uses of rice straw offer different trade-offs. Burning rice straw

for power generation, for example, can reduce the production of particulate matter and methane

because the burning conditions can be tightly controlled. However, the high silica content in rice

straw tends to foul boiler tubes and disposal of ash also presents a new challenge. Non-burning

alternatives require greater use of tractors and other equipment to chop and disk, or bale and

remove, the rice straw. This added activity increases diesel and dust emissions. While the diesel

emissions have a considerably smaller volume than the straw burning smoke, particulate

emissions from diesel-fueled engines are listed by the California Air Resources Board (CARB)

as a toxic air contaminant (CARB, 2001a). Also, increased vehicle traffic on paved and unpaved

roads, and in fields, will increase particulate matter emissions. Relative risks from each source

need to be considered as alternatives are assessed.

Alternative uses of rice straw that result in aerobic decomposition have fewer

balancing emissions issues than soil incorporation. These include uses such as animal bedding,

erosion control, and weed suppression. Rice straw is particularly well-suited as a mulch because
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it is slow to decay and carries few upland/non-aquatic weed seeds (REI, 1997). Uses that

preserve the straw for an extended period or displace the use of other more valuable resources

sequester excess carbon and so alleviate global warming without significant negative trade-offs.

These include straw bale construction, building materials, and paper-making.

Wildlife adapts to the agricultural practices in their environment. California rice

fields have been significant resources for migratory waterfowl (CARB, 2001a). If a non-burning

alternative resulted in a change in the flooding regime, historical patterns of waterfowl migration

could be affected. Ultimately, waterfowl populations could be reduced. Increased rice

production in Arkansas and Texas is considered an important contributor to the over-population

of mid-continent white geese and the subsequent destruction of their arctic breeding habitat

(FWS, 1999). Such over-population issues have not arisen on the West Coast but indicate the

interconnectedness of agriculture and wildlife.

Uses that consume large volumes of straw are also preferable environmentally.

Composite materials made from rice straw are another potential use (REI, 1997). Such

production, however, will consume only a small portion of the total rice straw harvest even when

technological and financial hurdles are overcome. Proven uses which require large volumes of

straw may be more successful in developing straw markets in the near term.

4.1.3 Health and Safety Impacts

Farm safety impacts do not appear to be a strong criterion for differentiating

among rice straw burning alternatives. None of the alternatives appear to be unusually

hazardous compared to other agricultural work.

4.1.4 Energy Impacts

Rice straw can provide a renewable source of biomass for power generation.

However, it presents several challenges for electricity generation as described below:

• It has a low heat content. It requires a large volume of straw to generate

as much energy as a cubic foot of natural gas. Collection is, therefore,

costly. Large volume also creates handling problems in getting fuel into

furnaces efficiently.
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• Straw supplies are seasonal. Large amounts of straw need to be removed

from fields in the fall and may not be available during the remainder of the

year. As a consequence, large volumes of fuel will typically need to be

stored for considerable periods to keep a power plant operating

continuously. This problem can also be mitigated by using multiple

biomass fuel sources which would be available in different seasons.

• Rice straw must be dried and chopped to be an efficient fuel. If energy

must be expended to process the low energy fuel, more energy may be

required to transport and process the fuel than it provides.

• Rice straw has an ash content of 14 to 20 percent, compared to wood that

typically has an ash content of from less than 2 percent to 4 to 8 percent

(typically used in power generators). Therefore, it leaves more ash to be

disposed in landfills or similar facilities.

The California Air Resources Board concluded that the use of rice straw to

generate electricity is precluded by technological constraints (CARB, 1993). Clearly, high

energy prices or subsidies will be needed to solve the technological problems and overcome the

logistical issues. Straw-burning district heating systems are common in Denmark where

subsidies have been offered to curtail open-field burning (REI, 1997). Although, it is not

possible within the scope of this project to speculate about possible incentive structures to

establish a biomass energy industry, it is noted that rice straw has some unusual characteristics

that make it particularly unattractive as boiler fuel.

4.1.5 Economic Impacts

The economic impact of adopting non-burning alternatives is an important

consideration. One criterion for selecting the preferable options is cost effectiveness (i.e. the

cost per acre per pound of particulate emissions reduced). The costs of adopting a non-burning

agricultural alternative are measured by the difference in the cost of agricultural operations

between a traditional burning operation, about $3 per acre, and alternative non-burning

approaches, about $31 to $47 per acre (CARB, 2001a). The viability of any alternative also

depends on the farm’s ability to remain profitable given the new labor, capital, and land

requirements of the new technology. Financial incentives can help overcome or offset the cost of

implementing non-burning alternatives. (These are discussed in more detail in Section 7.3 of this

report under Accountability Mechanism 16.)
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Cost-Effectiveness – Enterprise Level Assessment

Engineers estimate that each ton of rice straw burned emits 6.3 to 9 pounds of

PM10 (CARB, 2000). The emission factor used in this estimate was 6.9 pounds of PM10 per ton

(Jenkins, 2002). A typical acre of rice yields approximately 3 tons of rice straw residue after

harvest. Thus, each acre burned emits approximately 20.7 pounds of PM10 each year. Limiting

burning to weather conditions that reduce the probability that smoke will reach cities can reduce

the impact of smoke emissions on society. However, since the air quality goal is overall

reduction in particulate emissions, cost effectiveness is determined in terms of reduced pounds of

emissions rather than reduced human exposures.

Crop production budgets for current agricultural practices show all of the

necessary tasks to raise the crop and their costs per acre by expenditure category for a well-run

operation. Budgets do not represent the average but generally show an idealized production

operation using the best practices suggested by the state cooperative extension service. The

University of California (UC) Cooperative Extension Service (Williams, 2001) has produced a

rice crop budget that contemplates a farm using a mix of burning and non-burning alternative

practices.

An expanded budget that estimates the costs of four alternative straw management

strategies was developed by the California Air Resources Board (CARB, 2001a). Rice growers

actually use a variety of practices depending on field characteristics, past performance, and the

prices of water and fuel. The CARB options range in cost from $31 to $47 per acre with the two

most popular practices (Chop/Stubble Disc/Winter Flood and Chop/Chisel/Stubble Disc/Winter

Flood) averaging about $43 per acre. The UC rice budget also indicates that the least costly nonburning alternatives are to chop and disc ($37 per acre) or chop, flood, and roll ($32 per acre).

However, neither of these methods can maintain yields without resorting to occasional burning.

The UC rice budget suggests that 15 percent of rice land may need to be burned in

a given year. Thus, the costs to abate burning rise by $1.40 per pound abated [($32-$3)/(20.7 lbs

PM10)] until 85 percent of acreage is managed by the chop, flood and roll method. To avoid

releasing the last 15 percent of PM10 emissions, a more sustainable winter flooding regime must

be adopted at an increased cost of $2.13 per pound abated [($47-$3)/(20.7 lbs PM10)]. The cost
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of complete abatement reaches approximately $31.25 per acre. Figure 4-1 illustrates the

relationship between cost of reduced burning and potential reductions in PM10 emissions on a per

acre basis for rice straw.

The UC rice budgets do not estimate the costs of baling rice straw, storing, and

transporting it to alternative uses. These activities are more costly as they involve investment in

a baler or hiring custom baling as well as more fuel and labor time in transit. The California Air

Resources Board estimates field removal costs of $75 per acre based on field clearing costs of

$60 per acre plus transportation costs of $15 per acre (CARB, 2001a). However, if a market for

rice straw evolves, a compensating income could be obtained from baled straw. Furthermore,

incentives offered by the state can influence the level of harvesting and use of rice straw. While

use as compost or mulch, animal feed, or erosion control are the most likely alternative uses to

consume large quantities of straw, there are many possible substitutes which will keep the price

of straw for these uses relatively low. Hence, the costs of baling and hauling rice straw may not

be recouped at competitive prices.

Affordability – Farm Level

Growers will not adopt a new technology or practice unless it makes economic

sense for their farm as a whole. Rice acreage on farms that grow rice tends to be greater than

the specific crop acreage of other commodity farms (Chambers and Childs, 2000). Rice farming

is also more capital intensive than any field crop, other than cotton. This suggests a greater

reliance on a single crop and the possibly a higher degree of borrowing by rice farmers than

other producers. (Debt load information specific to California rice farming was not available.)

The UC rice enterprise budget shows producers’ operating, overhead, and capital

recovery costs are $188 greater than their revenue given current federal rice program payments

and a price of $8.00 per hundredweight. Even a well-managed farm is operating at a long run

loss. A more closely watched measure of profitability is revenues minus operating costs. Many

growers will continue to operate at a paper loss as long as their cash flow is adequate to cover

variable costs and the essential fixed costs (e.g., debt service). The UC rice budget indicates a

net return above operating costs of $150 per acre. Additional costs to achieve complete

abatement of PM10 of $35 per acre represents 21 percent of the farm's net return. The U.S. EPA,
Vol. II: Non-Burning Management 4-8

Alternatives, Final - May 2002 Figure 4-1. Rice Straw - Cost of Implementing Non-Burning Alternatives

$0$5

$10$15$20$25$30$35

0 10 20

Pounds PM-10 abated per Acre

Incremental Cost per Acre
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4-9

as an example, typically considers changes in net income of 3 to 5 percent as indicators of

moderate stress (USEPA, 2001b). It is unlikely that farms can support such a high level of

abatement costs in the long term without earning some return from rice straw sales. Thus,

criteria should favor credible alternatives that encourage markets for rice straw.

Indirect Impacts – Regional Level

Changes in farm operations can have impacts in the regional economy.

Collecting and transporting crop residue may require extra labor which may generate more

income for farm workers. New equipment that might be needed or faster depreciation of old

equipment may increase sales at agricultural implement dealers. Such effects generate ripple

effects throughout the regional economy. The California Air Resources Board used a

computable general equilibrium (CGE) model to trace the impact on prices and quantities of

adopting different policy options for rice straw burning (CARB, 1993). Their baseline

information indicated that agriculture provides about 10 percent of the Sacramento Valley’s

value added and employment. Rice production and processing accounts for about 13 percent of

the region’s agricultural value added and 7 percent of its agricultural employment. So, about one

percent of the region’s employment and value added come from the rice sector. The conclusion

is that small changes in the output of this sector would have very small effects in the regional

economy as a whole (CARB, 1993).

4.1.6 Social and Equity Issues

National trends over the last 10 years indicate that the number of large rice farms,

measured both in terms of acreage and sales, has been growing faster than other field crop

operations (Chambers and Childs, 2000). Very small farms (i.e., less than 100 acres) have also

been disappearing rapidly. Large farms have greater yields per acre because they have better

access to yield enhancing technologies such as precision leveling and permanent levees

(Chambers and Childs, 2000). They may also be more profitable because they distribute fixed

costs over a larger output. As a result, large farms may be able to absorb the added costs of nonburning alternatives more easily than small farms. Providing small producers access to straw

markets and greater burning flexibility can mitigate the differential impact of adopting non-
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burning alternatives. Another equity issue is the stringent control and reduction in rice straw

burning in the Sacramento Valley without equal control of other crop residue burning.

4.1.7 Political Issues

Promotion of non-burning alternatives by government, even on a voluntary basis,

has the potential to antagonize agricultural interest groups. The California Rice Commission

routinely advocates growers’ concerns in the state. Environmental and recreation interests are

also well organized. Surveyed stakeholders did not cite any specific groups with strong positions

on agricultural burning but noted general concerns about implementation of the rice straw

burning phase down in the Sacramento Valley.

4.1.8 Summary of Impacts

Table 4-1 summarizes the discussion above by indicating the severity of each

potential impact for each alternative to burning rice straw on a scale from zero to three. Blank

indicates "not relevant" or "no information." The factors in Table 4-1 are phrased in the negative

so that a high number in the table always indicates a stronger degree of negative consequences

for that alternative. An alternative with many 3’s in its column is probably not a viable option.

A total or average of these scores indicates an overall weight of problematic impacts. However,

this also implies an equal weighting among the impacts listed, which is unlikely among different

interest groups.

The cut and haul residue to a waste facility or permitted burn facility alternatives

contain several 3’s because they incur the additional costs of baling and hauling without any

hope of compensation for the grower. These alternatives are economically and politically

untenable. The conversion of land to a non-agricultural use in detail received many 3’s because

conversion to a developed use is likely to require greater water and energy use as well as

generating other forms of air emissions.

4.2 Grass Seed Case Study

Grass for seed is widely grown in Washington, Oregon, and Idaho. Legislation

that allows burning only under favorable weather conditions has reduced the number of smoky

days experienced in Spokane and other cities (WDOE, 1998a). While burning is a convenient
Vol. II: Non-Burning Management 4-11

Alternatives, Final - May 2002

Table 4-1. Rice Straw - Impacts of Non-Burning Alternatives1

Leave Residues

in Place Cut or Collect Residues and Haul

Potential Impacts and Criteria

Mulch Residue

Soil Incorporation:

Wet or Dry

Soil Incorporation:

Fallow Field

Waste Facility

Permitted Burn

Facility

Power Generation

Facility

Ethanol

Production Facility

Redistribution

Facility

Manufacturing or

Use Facility

Fiberboard Facility

Particleboard

Facility

Use as Compost or

Mulch

Use as Animal

Feed

Use For Erosion

Control

Agronomic:

Soil compression 1 3 2 2 2 2 2 2 2 2 2 2 2 2 Soil erosion 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Increased water use 1 3 1 0 0 0 0 0 0 0 0 0 0 0 Increased herbicide use 2 2 2 0 0 0 0 0 0 0 0 0 0 0 Increased pesticide use 2 2 2 0 0 0 0 0 0 0 0 0 0 0 Land constraint 1 0 0 2 2 2 2 2 2 2 2 2 2 2 Time or equipment constraint 1 2 2 2 2 2 2 2 2 2 2 2 2 2 

Environmental:

Countervailing air emissions 0 2 1 2 1 1 1 1 1 2 2 0 1 1 Negative wildlife impacts 1 2 2 0 0 0 0 0 0 0 0 0 0 0 Water quality degradation 1 2 1 3 3 2 2 2 2 2 2 0 1 0 

Health and Safety:

Increased equipment use 1 1 1 2 2 2 2 2 2 2 2 2 1 2 Increased chemical use 2 2 2 0 0 0 0 0 0 0 0 1 0 1 

Energy Impacts:

No contribution to energy production 2 2 2 2 2 0 0 2 2 1 1 2 2 2 Increased energy use 1 1 1 2 2 2 2 2 2 2 2 2 2 2 

Economics:

Not cost-effective 2 2 2 3 3 1 1 1 1 1 1 2 2 2  Farm financial stress 2 2 2 3 3 1 1 1 1 1 1 2 2 2 Negative regional impacts 1 1 1 2 2 1 1 1 1 1 1 1 1 1 

Social and Equity:

Raises tribal/cultural/historical issues Raises small business issues 1 2 2 3 3 2 2 2 2 2 2 2 2 2 Impacts low resource farms 2 2 2 3 3 2 2 2 2 2 2 2 2 2 

Political:

Agricultural objections 2 2 2 3 3 0 0 0 0 0 0 0 0 0 Environmental objections 2 1 1 3 3 1 1 2 1 1 1 0 0 0 

Average Score 1.3 1.8 1.6 1.9 1.9 1.1 1.1 1.2 1.2 1.2 1.2 1.1 1.1 1.1 

1 Feasibility factors are phrased to indicate a negative outcome. Higher ratings indicate worse consequences for that impact and alternative.Blank = not relevant or viable 0 = no problem exists 1 = problem may exist 2 = problem does exist 
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disposal method for rice straw, it is an ecological necessity for grasses that evolved in fire-prone

environments. Burning stimulates crown and tiller development which enhances seed head

production. Cessation of all open field burning results in production losses of 23 to 31 percent

even with the best mechanical residue management practices (WDOE, 1998a). Thus,

evaluations of burning cessation in grass seed production often entail assumptions about farms

converting to alternative crops, most often wheat.

4.2.1 Agronomic Impacts

After the seed is harvested, the remaining stubble is burned to prevent

overwintering of disease organisms and condition the field for future growth. Alternatively, the

straw must be cut, baled, and stacked and a crewcut vacuum used to remove the secondary

residue. Soil incorporation is not an option as the grass is established as a long-lived stand and is

not tilled each year. Repeated passes with equipment increase the risks of soil compaction, root

damage, and possible delays from poor field conditions. Unlike rice straw, creating markets for

grass straw will not mitigate all of the disadvantages of the non-burning alternative. Yields

cannot be maintained by mechanical means so the consequences of farms shifting from grass to

other crops must be considered. For example, growth of Meadowfoam has been explored as a

rotation crop for annual ryegrass in Oregon’s Willamette Valley. Meadowfoam seed produces

oil that has had fluctuating market demand in the cosmetics industry.

4.2.2 Environmental Impacts

Non-burning alternatives require greater use of tractors and other equipment to

cut, bale, and remove the straw. This added activity increases diesel and dust emissions. While

the diesel emissions have a considerably smaller volume than the straw burning smoke,

particulate emissions from diesel-fueled engines are listed by CARB as a toxic air contaminant

(CARB, 2001a). The most likely alternative crop, wheat, exposes soil to wind and water erosion

for much longer periods than grass production. Substantial volumes of particulate matter may be

raised during wheat operations.

4.2.3 Health and Safety Impacts

Grass is often the crop of choice on relatively sloping sites because of its ability to

hold the soil and limited need for cultivation. Non-burning alternatives require more mechanical
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4-13

operations and so increase the risk of tipping accidents injuring workers operating machinery on

steep slopes. Washington state regulations permit burning on steep slopes and so avoid this risk

(WDOE, 1998b).

4.2.4 Energy Impacts

Straw can provide a renewable source of biomass for power generation. Like rice

straw, it has a low heat content, seasonal supplies, and processing requirements. However, the

ash content of grass straw is more comparable to other biomass fuels, so it is preferable to rice

straw.

4.2.5 Economic Impacts

The economic impact of employing non-burning alternatives on grass stubble is

discussed below.

Cost-Effectiveness – Enterprise Level Assessment

Engineers estimate that each ton of grass straw burned emits 16 to 102 pounds of

PM10 (CARB, 2000). The emission factor used in this estimate was 18.0 pounds of PM10 per ton

(Jenkins, 2002). A typical acre of grass yields approximately 2 tons of straw acre after harvest.

Thus, each acre burned emits 36 pounds of PM10 each year.

Washington Department of Ecology estimates the cost of mechanical straw

management strategies as $70 per acre (WDOE, 1998a). The costs to the farmer to abate burning

rise by $1.86 per pound abated [($70-$3)/(36 lb PM10)]. This impact is illustrated by the cost

curve shown in Figure 4-2.

If farmers burn every third year rather than every year, burning can be reduced by

two-thirds while yields are maintained near traditional levels. Thus, a diminution in yield effect

becomes significant if more than two-thirds of the emissions are curtailed. The loss of output is

part of the cost of abatement so costs rise sharply in Figure 4-2 if more than two-thirds of

emissions are curtailed. Yield reductions of one-quarter to one-third have been observed which

would reduce revenues per acre by $90 to $120 dollars, more than doubling the $70 direct costs

of straw management itself.
Vol. II: Non-Burning Management 4-14

Alternatives, Final - May 2002

Figure 4-2. Grass Seed - Costs of Implementing Non-Burning Alternatives

$0

$20$40$60$80

$100$120$140$160$180$200

0 10 20 

Pounds PM-10 abated per Acre

Incremental Cost per Acre
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Affordability – Farm Level

Researchers have developed an enterprise budget for annual ryegrass that shows

producers net return per acre with open-field burning is $73 at a price of $0.20 per pound

(Taylor, Michael, et al, 1990). Additional costs to achieve complete abatement of PM10 of $70

per acre (not including yield effects) represents 96 percent of the farm’s net return.

Indirect Impacts – Regional Level

Changes in farm operations can have impacts in the regional economy.

Mechanical residue management employs more labor than open-field burning and so smoke

abatement increases farm employment slightly (WDOE, 1998a).

4.2.6 Social and Equity Issues

A survey of stakeholders did not reveal any special considerations about social or

equity issues among grass seed non-burning alternatives.

4.2.7 Political Issues

Promotion of non-burning alternatives by government, even on a voluntary basis,

has the potential to antagonize agricultural interest groups. Survey respondents did not cite any

specific groups with strong positions on agricultural burning but noted general concerns about

implementation of new burning regulations in Washington. Any new regulation would have the

potential to ignite legal controversies. Litigation over regulatory issues can become very costly

to state governments.

4.2.8 Summary of Impacts

Table 4-2 summarizes the discussion above by indicating the severity of each

impact in relation to each alternative to burning grass straw on a scale from zero to three. None

of the “Leave Residues in Place” alternatives are viable for grass seed production because of

agronomic issues so they are assigned all blanks. The waste and permitted burn facility

alternatives cannot be sustained without subsidies because of the high cost to bale and transport

straw without creating a saleable product.
Vol. II: Non-Burning Management 4-16

Alternatives, Final - May 2002

Table 4-2. Grass Seed – Impacts of Non-Burning Alternatives1

Leave Residues

in Place Cut or Collect Residues and Haul

Potential Impacts and Criteria

Mulch Residue

Soil Incorporation:

Wet or Dry

Soil Incorporation:

Fallow Field

Waste Facility

Permitted Burn

Facility

Power Generation

Facility

Ethanol Production

Facility

Redistribution

Facility

Manufacturing or

Use Facility

Fiberboard Facility

Particleboard

Facility

Use as Compost or

Mulch

Use as Animal Feed

Use For Erosion

Control

Agronomic:

Soil compression 2 2 2 2 2 2 2 2 2 2 2 Soil erosion 0 0 0 0 0 0 0 0 0 0 0 0 Increased water use 0 0 0 0 0 0 0 0 0 0 0 Increased herbicide use 0 0 0 0 0 0 0 0 0 0 0 Increased pesticide use 0 0 0 0 0 0 0 0 0 0 0 Land constraint 2 2 2 2 2 2 2 2 2 2 2 Time or equipment constraint 2 2 2 2 2 2 2 2 2 2 2 

Environmental:

Countervailing air emissions 2 1 1 1 1 1 2 2 0 1 1 Negative wildlife impacts 0 0 0 0 0 0 0 0 0 0 0 Water quality degradation 3 3 2 2 2 2 2 2 0 1 0 

Health and Safety:

Increased equipment use 2 2 2 2 2 2 2 2 2 2 2 Increased chemical use 2 0 0 0 0 0 0 0 0 0 0 0 

Energy Impacts:

No contribution to energy production 2 2 0 0 2 2 1 1 2 2 2 Increased energy use 1 2 2 2 2 2 2 2 2 2 2 2 

Economics:

Not cost-effective 3 3 1 1 1 1 1 1 2 2 2  Farm financial stress 3 3 1 1 1 1 1 1 2 2 2 Negative regional impacts 2 2 1 1 1 1 1 1 1 1 1 

Social and Equity:

Raises tribal/cultural/historical issues Raises small business issues 3 3 2 2 2 2 2 2 2 2 2 Impacts low resource farms 3 3 2 2 2 2 2 2 2 2 2 

Political:

Agricultural objections 3 3 0 0 0 0 0 0 0 0 0 Environmental objections 3 3 1 1 2 1 1 1 0 0 0 

Average Score 1.9 1.9 1.1 1.1 1.2 1.2 1.2 1.2 1.1 1.2 1.1 

1 Feasibility factors are phrased to indicate a negative outcome. Higher ratings indicate worse consequences for that impact and alternative.Blank = not relevant or viable 0 = no problem exists 1 = problem may exist 2 = problem does exist 
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5.0 ACCOUNTABILITY MECHANISMS

This section describes the strategies used to research, identify, and characterize

accountability mechanisms of greatest importance in supporting the development and use of nonburning alternatives within the 15 Western states. Accountability mechanisms are procedures

used for tracking if, and to what extent, non-burning alternatives are used by local, state, tribal,

or federal entities.

Where possible, accountability mechanisms which are currently in place and are

actively in use at the state, county, and local levels, as well as in the tribal community setting, are

identified in this report. In addition, a discussion of how each accountability mechanism is

important in supporting or promoting the development and use of non-burning alternatives is

provided. Accountability mechanisms important to the implementation and use of non-burning

alternatives by individual burners are also discussed in greater detail in Section 7.0.

5.1 Research Strategy and Sources of Information

The identification and characterization of accountability mechanisms of

importance in the development, consideration, and use of non-burning alternatives was a

complex process. It required a thorough assessment, understanding, and interpretation of current

agricultural burning practices in the West. It also required a thorough assessment of the

regulatory and programmatic structures in place for addressing agricultural or open burning

activities in each state (and where applicable for each county or local air authority). An

understanding of the variety of practical, technical, political, and economic forces affecting

stakeholders involved in or currently conducting agricultural burns was also critical for the

successful identification and characterization of accountability mechanisms in this effort.

To collect the desired information and to address the expectedly wide distribution

of information sources, the same three-tiered approach discussed in Section 2.0 was employed.

This approach included contacting and/or researching the availability of information from three

different levels of information sources. It was expected that these sources would provide varying

information perspectives and levels of programmatic detail. The majority of the information

pertaining to this task came from the first level of information sources.
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The first level of information sources investigated included state environmental

agencies, boards and departments as well as state, county and local air pollution control

authorities. Information important to this effort was collected from the respective administrative

and statutory rules and regulations, formal published reports and documents, and articles or

summary information posted on official state level or county level websites. For all 15 Western

states, the presence, or in some cases the absence, of accountability mechanisms important in the

identification, development, consideration and use of non-burning alternatives, was clearly

documented by these information sources.

To ensure efficiency and effectiveness in the collection of data for this task, a

process for reliably identifying, collecting, and documenting information obtained was

developed. As part of this process, an informal survey was designed for in-house use only.

Contacts at the various state, county, local or tribal environmental authorities were identified for

all 15 states. Information was collected by phone or e-mail. Responses to a series of questions

designed to identify and characterize accountability mechanisms were used to document

information collected for this task. The contact persons have been identified and referenced in

Appendix A.

As appropriate, contact was made with secondary sources identified by the first

level sources. A focused review of prior agricultural burning survey reports, documents and

other information produced by larger and more comprehensive multi-agency environmental and

or governmental organizations was also conducted. These organizations included the WGA,

WRAP, and its various task forces such as the FEJF. (GCVTC, 1996; WESTAR, 1999; WRAP,

2001a; WRAP 2001b).

5.2 Accountability Mechanisms Identified

Seventeen accountability mechanisms were identified that are important to the use

of non-burning alternatives to agricultural burning in the West. The accountability mechanisms

identified include the following:

1. Agricultural Burning is Exempt from all Regulations or Rules.

2. Agricultural Burning is Effectively Exempt from Regulations or Rules.
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3. Agricultural Burning is Included in Regulations or Rules.

4. Specific Agricultural Burning Regulations or Rules Exist.

5. General Open Burning Regulations or Rules Exist.

6. Other Burning Sources are More Important.

7. Formal Agricultural Burning Approval Process Exists.

8. Agricultural Burning Permit is Required.

9. Agricultural Burning Permit Fees are Charged.

10. Smoke Management is Required.

11. Agricultural Burning Activity Enforcement Process Exists.

12. Requirement to Estimate Fuels, Acreage and Emissions on a Pre-Burn

Permit Exists.

13. Requirement to Confirm Fuels, Acreage and Emissions on a Post-Burn

Report Exists.

14. Agricultural Burning Activity Data is Reviewed and Included in

Inventories.

15. Requirements to Consider the Use of Alternatives Exist.

16. Financial Incentive(s) are Available for Using Alternatives.

17. List of Alternatives is Available.

The results of this effort clearly suggest that the presence, or in some cases the

absence, of identified accountability mechanisms may effectively determine whether nonburning alternatives will be used in the 15 Western states. The 17 mechanisms identified above

fall into five main categories of accountability. These categories, (a) through (e), are shown in

Table 5-1. The 17 accountability mechanisms are discussed in detail below.

5.2.1 Accountability Mechanisms 1 through 3

The most important mechanisms in the initial determination of whether nonburning alternatives will be employed are found in category (a) in Table 5-1. Accountability

mechanisms in this category are initiated at the state or regional level. These mechanisms either

absolutely (Mechanism 1) or in practice effectively (Mechanism 2) exempt agricultural burning

from regulation. Conversely, they actively include agricultural sources for potential regulation
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Table 5-1. General Categories of Accountability Mechanisms Identified in the

15 Western States

General Category and

Description Accountability Mechanism

(a) Accountability Initiated

at the State or Regional

Level

1. Agricultural Burning is Exempt from all Regulations or Rules

2. Agricultural Burning is Effectively Exempt from Regulations or

Rules

3. Agricultural Burning is Included in Regulations or Rules

(b) Accountability at a State

or Local Level that

Supports the Active

Regulation of Agricultural

Burning Activities

4. Specific Agricultural Burning Regulations or Rules Exist

5. General Open Burning Regulations or Rules Exist

6. Other Burning Sources are More Important

(c) Accountability at a

Programmatic Level that

Supports a Formal

Approval and/or Permitting

Process

7. Formal Agricultural Burning Approval Process Exists

8. Agricultural Burning Permit is Required

9. Agricultural Burning Permit Fees are Charged

10. Smoke Management is Required

11. Agricultural Burning Activity Enforcement Process Exists

(d) Mechanisms that

Encourage Accountability

at the Local Level that

Support the Tracking of

Emissions and Program

Effectiveness

12. Requirement to Estimate Fuels, Acreage and Emissions on a

Pre-Burn Permit

13. Requirement to Confirm Fuels, Acreage and Emissions on a

Post-Burn Report

14. Agricultural Burning Activity Data is Reviewed and Included in

Inventories

(e) Mechanisms that

Facilitate and Encourage

the Use of Non-Burning

Alternatives

15. Requirements to Consider the Use of Alternatives Exist

16. Financial Incentive(s) are Available for Using Alternatives

17. List of Alternatives is Available
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(Mechanism 3). Mechanism 3 effectively establishes whether agricultural burning is defined

and/or included in any state or local regulation or rule.

State environmental regulatory agencies throughout the 15 Western states either

include agricultural burning in statute or they exempt agricultural burning completely from their

regulations and rules. They may do this for a variety of reasons. Absolute exemption may occur

because agricultural burning may not be a significant source of air pollution in the region, state

or air basin. Agricultural burning may not be a source of air pollution because climate,

topography, crops planted, or current agricultural practices may not support the need to burn.

Also, agriculture activities may not exist or occur in a given state or air basin such that burning

of residues or stubble is needed.

In contrast, agricultural burning may be an important and/or significant source of

pollution in the state, tribal community, or an air basin in general. It may also be an important,

significant source at certain times of the year and not others. However, in spite of this, some

states still exempt agricultural burning sources from regulation. In these cases, political, social,

economic, regulatory resource, or regulatory climate factors may make it impractical for states to

include agricultural burning in their regulations as an air pollution source that can be controlled.

In other cases, state agencies or local air authorities may essentially, in practice,

exempt agricultural burning even if it is identified in regulations as a source of air pollution.

This occurs for a variety of reasons but for the most part it results from either a programmatic

focus on other areas or sources of air pollution of greater concern, or from political, social,

economic, regulatory resource, or regulatory climate factors that de-emphasize regulation of

agricultural burning sources. Regardless of the reasons why this may occur, if agricultural

burning is absolutely exempted or effectively exempted in practice from regulation at the state or

regional level, there is little practical incentive, (private or governmental) to develop or

implement alternatives to agricultural burning. When agricultural burning is identified in statute

as a source of air pollution, the chances of identifying, developing, and employing non-burning

alternatives increase substantially.
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5.2.2 Accountability Mechanisms 4 through 6

Category (b) mechanisms provide accountability at the state or local level that

supports the active regulation of agricultural burning activities. Category (b) mechanisms

include mechanisms 4 through 6. If agricultural burning activities are included in state

environmental or health statutes, there is a greater likelihood that non-burning alternatives will

be identified, developed, and used. If agricultural burning is not otherwise exempted from

regulation, the degree to which it will or may be regulated is closely tied to the regulatory

strategy embraced by the environmental agency or air quality authority. The extent to which

agricultural burning is practically regulated is also dependent on the form and subsequent

effectiveness of the regulations used to address agricultural burning as a source of air pollution.

The degree to which agricultural burning regulations serve as motivating factors in the

identification, development, and use of non-burning alternatives can often be predicted based on

the following factors:

• Whether there is a formal rule or regulation in place to address agricultural

burning;

• The type or types of regulations or rules in place which address

agricultural burning; and

• The relative degree to which agricultural burning is important as a source

of air pollution compared to other sources in the state, regional or air

basin.

Accountability mechanisms 4 and 5 support the active regulation of agricultural

burning at the state and local levels. Mechanism 4 provides for clearly defined regulations or

rules specifically designed to address agricultural burning activities. Mechanism 5 provides for

the inclusion of agricultural sources in a more general open burn regulation or rule. Both

mechanisms increase the likelihood that non-burning alternatives will be identified, developed

and used. However, the more specific the regulation, typically the more detailed and ideally

effective a regulation or rule may be in addressing a particular source or class of pollutant

sources.

Mechanism 6 is also important in the identification, development and use of nonburning alternatives since it has the potential to deter, under some circumstances, the active
Vol. II: Non-Burning Management

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5-7

addressing of agricultural burning sources. In Mechanism 6 other burning activities such as range

management, land clearing or forest management may be more important sources of air pollution

from a programmatic implementation standpoint. This may develop because of technical,

political, or economic factors, or a combination of the same. In these cases, even though rules or

regulations to address agricultural burning are in place at the state level, other vegetative burning

sources receive higher implementation priority. In some cases, this may contribute to the

effective exemption of agricultural burning activities although it may encourage the development

of non-burning alternatives for other vegetative burning sources.

5.2.3 Accountability Mechanisms 7 through 11

Accountability mechanisms that support regulation of agricultural burning fall

into category (c): Accountability at a Programmatic Level that Supports a Formal Approval

and/or Permitting Process. Mechanisms in this category support more systematic approaches to

the review and approval of proposed burn activities, overall program implementation and

consistent enforcement of programs which include regulations or rules that address agricultural

burning. Accountability mechanism 7 provides for a formal burn activity approval process.

Accountability mechanisms 8 and 9 address pre-burn permit requirements and associated permit

fees. Mechanism 10 provides for the accountability of smoke released from ongoing burn

activities. Mechanism 11 supports compliance with existing regulations or rules as well as

provides a forum for education on smoke program benefits through a formal enforcement

process. All of these mechanisms provide information and in some cases economic motivation

that supports the identification, development, and use of non-burning alternatives.

5.2.4 Accountability Mechanisms 12 through 14

Mechanisms that provide information for applying non-burning alternatives to

current agricultural burning practices fall into category (d). These include Mechanisms 12

through 14 which encourage accountability at the local level by supporting the tracking of

emissions and program effectiveness. Mechanisms 12 through 14 support the formal

identification, tracking, and inventorying of burn activity parameters important in the

implementation and review of an agricultural burning program effectiveness and extent of

implementation. Some of the most important parameters addressed by these mechanisms include
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the identification of fuel types burned, the number of acres burned, and the resulting emissions

from all identified agricultural burning sources. Mechanism 12 requires potential burners to

estimate parameters such as fuel type, fuel loading, acreage impacted, and in some cases,

potential emissions released from any proposed burn activity. This information is usually

provided on a pre-burn permit application or even the permit itself. Mechanism 13 increases the

assurance of quality data collection by requiring a post-burn report that confirms the parameters

initially estimated on the pre-burn permit or permit application.

Mechanism 14 increases the likelihood that non-burning alternatives will be

identified and used since it provides a mechanism for formal burn permit data review and the

inclusion of important data in statewide inventories and implementation plans. As significant

agricultural burning emissions are identified and documented at the state and regional levels,

comparison to other more traditionally well-documented sources of air pollution becomes

possible. In areas where agricultural activities are economically significant, motivation to

continue agricultural production and related activities typically remains high despite the release

of potentially significant air emissions. This type of atmosphere can provide motivation and

support for, as well as stimulate interest in, the identification, development, and use of effective

non-burning alternatives. This is especially true if agricultural source contributions can be

documented and the stakeholders can be assured their efforts to use non-burning alternatives will

be worthwhile. A more comprehensive discussion of these mechanisms and how they might be

used in the effective implementation of non-burning alternatives can be found in Section 7.0.

5.2.5 Accountability Mechanisms 15 through 17

The fifth and final category is category (e). Mechanisms that facilitate and

encourage the use of non-burning alternatives are found in this category. While it might seem in

some cases that these mechanisms should be the only ones considered, it is unlikely that these

mechanisms alone will produce the desired results in any but the most advanced agricultural

burning management programs settings. Mechanisms 1 through 14 are essential for the support

and validation of Mechanisms 15, 16, and 17. Mechanisms 15, 16, and 17 provide accountability

at the state or local level that facilitates the active identification of, and encourages the consistent

use of, effective non-burning alternatives in conjunction with, or as a substitute to, more

traditional existing agricultural burning practices. Mechanism 15 provides incentive to actively
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consider non-burning alternatives by making it a requirement of pre-burn approval. This usually

occurs during the pre-burn permitting process. If no pre-burn permitting process exists, in all but

the most unique of circumstances, it is impractical and unrealistic to expect non-burning

alternatives will be considered to any significant extent.

Mechanism 16 provides financial assistance in one form or another to burners

who implement non-burning alternatives. This serves to help overcome one of the most often

voiced oppositions to the use of non-burning alternatives which is that of cost “ineffectiveness”.

Mechanism 17 has the potential to provide useful, practical incentives to the increased use of

non-burning alternatives by providing a list of alternatives that are available and/or in use

successfully in the area. This mechanism would eliminate another readily voiced opposition to

the use of non-burning alternatives, which is that non-burning alternatives do not exist or cannot

be used effectively. A more comprehensive discussion of these mechanisms and how they might

be used in the effective implementation of non-burning alternatives can be found in Section 7.0

of this report.

5.3 Review and Discussion of the Accountability Mechanisms

in Place in the 15 Western States

A review and discussion of the accountability mechanisms identified during this

effort and found to be in place in the 15 western states is included here to more fully explain the

survey results presented in Table 5-2. (Relevant comments are provided in a comment key in

Table 5-2a.) The authors of this report are making the assumption that if accountability

mechanisms 3-17 are in place then there is a greater likelihood that non-burning alternatives to

agricultural burning will be identified and implemented in areas where agricultural burning

significantly contributes to air quality issues. This assumption appears to be supported by the

results of the survey effort for those states with more aggressive mandates to address agricultural

burning as a significant source of air pollution. However, this does not preclude the possibility

that non-burning alternatives may be identified and implemented for other reasons or by other

means or methods.

The authors recognize that the development of air pollution emission source

reduction programs is a complex process involving countless stakeholders and many years of
Vol. II: Non-Burning Management 5-10

Alternatives, Final - May 2002 Table 5-2. Accountability Mechanisms Important to the Use of Non-Burning Altern

Accountability Mechanisms that Support Identification and Use of Non-Burning Alternatives

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 

State-County(ies)

or Area

Agricultural Burning is Exempt from all

Regulations or Rules

Exempt from Regulations or Rules

Agricultural Burning is Effectively

Agricultural Burning is Included in

Regulations or Rules

Specific Agricultural Burning Regulation

or Rule

General Open Burning Regulation or Rule

Other Burning Sources More Important

Formal Agricultural Burn Approval

Process

Agricultural Burning Permit is Required

Agricultural Burning Permit Fees are

Charged

Smoke Management is Required

Agricultural Burn Activity Enforcement

Process Exists

Requirement to Estimate Fuels, Acreage,

& Emissions: Pre-Burn Permit

Requirement to Confirm Fuels, Acreage,

& Emissions: Post Burn Report

Agricultural Burn Activity Data is

Reviewed & Included in an Inventory

Requirements to Consider Use of

Alternatives

Financial Incentive(s) are Available for

Using Alternatives

AK !! !

!2,3 ! !! 

AZ ! ! ! !! ! AZ-Pima

!1 !1 !1 !1 !1 !1 

AZ-Pinal

!1 !1 !1 !1 !1 

AZ-Yuma

!2 !2 !2 !2 !1 !1 !2 

AZ-Maricopa

!

!1 

CA

!

!1 !1 !1 !1 !1 !!! 

CA-Lake

!1 !1 !1 !1 !1 !1 !1 !1 !1 !1 

CA-SacramentoValley Counties

!1 !1 !1 !1 !1 !1 !1 !1 !1 !1 

CA-San JoaquinValley Counties

!1 !1 !1 !1 !1 !1 !1 !1 !1 !1 

CA-South CoastCounties

!1 !1 !1 !1 !1 !1 !1 !1 !1 !1 

CO ! ! HI ! ! ! ! !! ! ID !!! ! ! ! !!!!! MT ! ! !! !! ! 
Table 5-2. Continued

Vol. II: Non-Burning Management 5-11

Alternatives, Final - May 2002 Accountability Mechanisms that Support Identification and Use of Non-Burning Alternatives 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 

State-County(ies)

or Area

Agricultural Burning is Exempt from all

Regulations or Rules

Exempt from Regulations or Rules

Agricultural Burning is Effectively

Agricultural Burning is Included in

Regulations or Rules

Specific Agricultural Burning Regulation

or Rule

General Open Burning Regulation or Rule

Other Burning Sources More Important

Formal Agricultural Burn Approval

Process

Agricultural Burning Permit is Required

Agricultural Burning Permit Fees are

Charged

Smoke Management is Required

Agricultural Burn Activity Enforcement

Process Exists

Requirement to Estimate Fuels, Acreage,

& Emissions: Pre-Burn Permit

Requirement to Confirm Fuels, Acreage,

& Emissions: Post Burn Report

Agricultural Burn Activity Data is

Reviewed & Included in an Inventory

Requirements to Consider Use of

Alternatives

Financial Incentive(s) are Available for

Using Alternatives

ND !! ! !1 ! NM !! ! ! NV ! ! NV-Pershing ! ! OR ! ! ! ! !!! !! OR-Jefferson !1 !1 !2 !1 !1 !1 !1 !1 OR-Umatilla !1 !1 !1 !1 !1 !1 !1 !1 OR-Union !1 !1 !1 !1 !1 !1 !1 !1 OR-Willamette !1 !1 !1 !1 !1 !1 !1 !1 SD ! UT ! WA ! ! ! ! ! !!! WA -Benton !1 !1 !1 !1 !1 !1 !1 !1 WA-Columbia !1 !1 !1 !1 !1 !1 !1 !1 WA-NW region !1 !1 !1 !1 !1 !1 !1 !1 WA-SW region !1 !1 !1 !1 !1 !1 !1 !1 WA-Walla Walla !1 !1 !1 !1 !1 !1 !1 !1 
Table 5-2. Continued

Vol. II: Non-Burning Management 5-12

Alternatives, Final - May 2002 Accountability Mechanisms that Support Identification and Use of Non-Burning Alternatives

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 

State-County(ies)

or Area

Agricultural Burning is Exempt from all

Regulations or Rules

Exempt from Regulations or Rules

Agricultural Burning is Effectively

Agricultural Burning is Included in

Regulations or Rules

Specific Agricultural Burning Regulation

or Rule

General Open Burning Regulation or Rule

Other Burning Sources More Important

Formal Agricultural Burn Approval

Process

Agricultural Burning Permit is Required

Agricultural Burning Permit Fees are

Charged

Smoke Management is Required

Agricultural Burn Activity Enforcement

Process Exists

Requirement to Estimate Fuels, Acreage,

& Emissions: Pre-Burn Permit

Requirement to Confirm Fuels, Acreage,

& Emissions: Post Burn Report

Agricultural Burn Activity Data is

Reviewed & Included in an Inventory

Requirements to Consider Use of

Alternatives

Financial Incentive(s) are Available for

Using Alternatives

WY ! !! Tribal

!

!3

;

!4; !5

!1

;

!2

;

!3

;

!4

;

!5

!1

;

!2

;

!3

;

!4

;

!5

Notes:! = State Level!1 = County or Local Authority!2 = Rural Fire District!3 = Natural Resources Authority!4 = Tribal Authority!5 = Federal Land Management Authority

AK = AlaskaAZ = ArizonaCA = CaliforniaCO = ColoradoHI = HawaiiID = IdahoMT = MontanaND = North Dakota

NM = New MexicoNV = NevadaOR = OregonSD = South DakotaUT = UtahWA = WashingtonWY = Wyoming
Vol. II: Non-Burning Management 5-13

Alternatives, Final - May 2002 Table 5-2a. Comments Key for Table 5-2 No. Comments 1 Ann Lawton, AK State Dept. Env. Quality, ERG/ETC Informal Survey 2001 (see Appendix A): No agricultural crops burned. 

date is for land clearing; may be more in future. Limited to fall and spring because of climate, tourism, and fire danger. Burning only. Rest of AK no agricultural burning at all. Permits are required for burns greater than 40 acres in size only. Most of the smpermitted burns. 2 Varma Sunil, AZ State Dept. Env. Quality, ERG/ETC Informal Survey 2001: Typically agricultural burning is not addressed in 

management program. Most burning occurs in Yuma county. 8,000 acre/yr limit via State Implementation Plan. Non-agricultuYuma and Maricopa Counties.

3 Bill Maxwell, Pima County Dept Env. Quality, ERG/ETC Informal Survey 2001: Most burning is tumbleweeds, year round via 

burn/no-burn days program. No smoke management plan is required and emissions are not tracked.

4 Donald Gabrielson, Pinal County Dept. Env. Quality, ERG/ETC Informal Survey 2001: Principal agricultural burning is for irr

Occurs in Spring. Most other permitted burning is for residential use burn barrels. Some rural agricultural burning. If okayed foburn anything up to 320 contiguous acres.

5 Varma Sunil, AZ State Dept. of Env. Quality and Kurt Foster, Yuma County Fire Dept, ERG/ETC Informal Survey 2001: Mos

Implementation Plan up to 8,000 acre/yr. It typically includes citrus and other orchard fuels burning for orchard retirement and destructor.

6 Rick Hado, Maricopa County, ERG/ETC Informal Survey 2001: No burning for agricultural residues occurs in county. Major

tumbleweeds, fenceline clearing and land clearing. Do often use high temperature propane burners for ditch banks and best man

7 WRAP, 2001a: Agricultural burning is allowed under state law. It is typically permitted at the county air authority level. Many 

rice, wheat and other grains. Orchard prunings are also burned by permit. The newly adopted statewide Title 17 Smoke Managand Prescribed burning in CA provides authority, direction and guidance to the local air authorities (air quality management anregulation and management of burning. Smoke management plans are required of each local air authority. There is considerablimplementation of local rules and regs and little systematic statewide review of programs or emissions estimates.

8 WRAP, 2001a: Almost any crop can be burned any time of the year.9 Coleen Campbell, CO State Dept. of Public Health and Phyllis Woodford, CO State Dept. of Public Health, ERG/ETC Informa

only of range land and irrigation ditches. Regulations exempt agricultural residues but do encourage good burning practices. Ssunflower burning may occur in Western counties/Grand Junction area. Approval to burn via courtesy burn/no-burn calls.

10 Lisa Young, HI State Dept. of Health and Janet Ashman, HI Agricultural Research Center; ERG/ETC Informal Survey 2001: T

the acres planted in any year would be burned the following year for both sugar cane and pineapples. Estimate 40,000 to 50,000 production. Roughly 30,000 acres sugarcane is burned in any given year. Acreage burned for pineapples is unknown. Sugarcadifficulties due to competition with sugarbeet production in other states. Sugarcane burning will likely decrease the future.

11 Diane Riley, ID State Dept. Env. Quality, ERG/ETC Survey 2001; Dan Redline, Coeur d'Alene Regional Office, ERG/ETC Inf

Thornberg, ID Dept. of Agriculture, ERG/ETC Informal Survey 2001, Robert Wilkosz, ID Dept. Env. Quality, WESTAR (199the state. Some data on grass and cereal grains is available for the Kootenai and Benewah counties. Voluntary smoke managemand Benewah counties. Grass seed and cereal crops are burned in the fall (Aug-Sept). Alfalfa, mint and other perennial forage cand fall. Ditch banks are burned in the spring. Individual burners make the burn/no-burn decisions. Open burning rule specificclippings and burning for weed control.
Table 5-2a. Continued

Vol. II: Non-Burning Management 5-14

Alternatives, Final - May 2002 No. Comments 12 Bob Habeck, MT State Dept Environmental Quality, ERG/ETC Informal Survey 2001: Data on acreage burned are not tracked

Feb otherwise burner gets to decide when to burn and not burn. Program is geared toward wildlands and forest management, noburn in summer months because of fire danger. Burning that does occur addresses ditches and sagebrush land conversion. 13 Chuck McDonald, ND State Health Dept., ERG/ETC Informal Survey 2001: Wheat is burned in fall and only in northeastern a

are high, similar to rice in CA. Do not track emissions at all. Agriculture is exempt. Open burning is prohibited but variances aof forest lands. One particle/fiberboard plant is highly successful in the state.

14 Brad Musick, NM State Dept of Environment, ERG/ETC Informal Survey 2001: Orchard prunings are the main issue. No emis

burned in eastern portion of the State. Pecans are the main crop. Prunings, hulls etc. are burned in the Dona Ana (Rio Grande) airrigation ditches are burned routinely as a way of life in some areas to supply pecan orchards with water.

15 Colleen Cripps, NV State Dept. Env. Quality, ERG/ETC Informal Survey 2001 and WRAP, 2001a: Agricultural burning is ess

regulation occurs in parts of the state with greater community concerns. This includes the Lovelock Valley.

16 Brian Finneran, OR State Dept. Env. Quality, ERG/ETC Informal Survey 2001: Grains burned July-Sept. Basically track emis

geographically distinct field burning programs. All three programs publish annual emissions reports. Largest source of burning Complex state run program. Orchard burning is typically allowed statewide.

17 Chris Hansen, SD Dept of Environment and Natural Resources, ERG/ETC Informal Survey 2001; Tim Rogers, SD State Dept 

Resources, ERG/ETC Informal Survey 2001: agricultural burning is not regulated in the state. No Tracking, no records kept, aagricultural burning in the state. Grasses burned in spring (March - May) and fall (Sept - Oct). Grain is burned in March and Aptreated woods, wastes, etc. is prohibited.

18 Francis Bernards, UT State Dept. Env. Quality, ERG/ETC Informal Survey 2001; Steven Parkin, UT State Division of Air Qua

does not track acres burned. Large agri-farming occurs in nearly every county. No burning occurs during Ozone season, (June - 

19 Grant Pfeifer, WA State Dept of Ecology, Agricultural Burn Task Force, ERG/ETC Informal Survey 2001; Chad Akins, WA S

1999: Burning occurs in Benton, Columbia, Island, Skagit and Whatcom counties. Wheat is burned in March, April and July-NSpring burning occurs March-May. Crops burned include wheat, barley, grass seed, pasture and alfalfa seed. A post-burn “Repfrom these sources are tracked. Burning incidental to agricultural residue is allowed without a permit. This type of burning inclirrigation and drainage ditches. Emissions are not tracked from these sources. State of WA does support research to explore alte

20 WRAP 2001a: Most of the burning in the county is orchard removal.21 WRAP 2001a: Spring burning in March through April; Fall burning in Mid-Sept through October22 WRAP 2001a: Very small amount of acreage burned. 475 total acres in year 2000.23 WRAP, 2001a: Little agricultural burning occurs in this county. Less than 50 acres in 2000, none were grain or grass seed cro

because so little occurs in the county.

24 WRAP, 2001a: Most burning is done in spring. Fall burning is being phased out.25 Darla Potter, WY Dept. Env. Quality, ERG/ETC Informal Survey 2001: Emissions are not tracked at all. Burn permits are requ

Recently grass seed companies from OR and WA have been relocating to WY which may increase burn emissions from these s
Table 5-2a. Continued

Vol. II: Non-Burning Management 5-15

Alternatives, Final - May 2002 No. Comments 26 WRAP, 2001b: There are 240 Indian reservations in the Western Regional Air Partnership (WRAP) region representing more t

Historically each tribal entity manages their own lands independently. No centralized agricultural burning activity data presentoccurs on approximately 50% of the reservations within the WRAP region of the 15 Western states. Types of burning include agricultural. Often burns are part of an overall annual burn or land management plan but some are completely independent. Moformal smoke management program although some do. Coordination with other off-site land management entities and air qualamong the tribes.

27 State of Alaska, Department of Environmental Conservation, Open Burning Policy and Guidelines document. http://www.state28 State of Arizona, Department of Environmental Quality, Arizona Guidelines for Open Burning and Permit Application Form, T

http://www.adeq.state.az.us/environ/air.

29 State of Hawaii, Administrative Rules, 11-60.1-51: Open Burning, and Application for Agricultural Burning Permit, http://www

60.PDF.

30 State of Idaho, Statute Title 22, Agriculture and Horticulture, Chapter 48, Smoke Management and Crop Residue Disposal, http31 State of Montana, Department of Environmental Quality, Rules Title 17, Chapter 8, Air Quality, Open Burning. http://www.de32 State of North Dakota Air Pollution Control Rules, Chapter 33-15-04, Open Burning Restrictions, http://www.health.stat.nd.us/33 State of Nevada, Division of Environmental Protection, Smoke Management Program, NAC 445B.381 Open Burning,

http://www.state.nv.us/ndep/bao/smoke1.htm.

34 State of Oregon, Department of Agriculture, “Field Burning Rules”, http://arcweb.sos.state.or.us/rules35 State of Oregon, Department of Agriculture Natural Resources Division, http://www.oda.state.or.us/Natural_Resources/smoke.36 State of Oregon, Administrative Rules, Department of Environmental Quality, “Pollution Control Tax Credits”,

http://arcweb.sos.state.or.us/rules/OARS_300/OAR_340/340_tofc.html

37 State of South Dakota, Department of Environment and Natural Resources, “Air Quality Guidelines for Open Burning”,

http://www.state.sd.us/denr/DES/airquality/regulations

38 State of Utah, Administrative Code, Title R307, “Environmental Quality, Air Quality”, Section 307-202-1, http://www.rules.sta39 State of Utah, Statute, Title 19, “Environmental Quality code” Chapter 2, “Air Conservation Act”, http://www.le.state.ut.us40 State of Washington, Department of Air Quality, Best Management Practices and Administrative Code, “Agricultural Burning”

http://www.ecy.wa.gov

41 State of Wyoming, Air Quality Standards and Regulations, Chapter 10, Section 2, “Open Burning Restrictions”, http://deq.state42 State of New Mexico, Environmental Protection Air Quality, “Open Burning”, Title 20, Chapter 2, Part 60.43 State of California, Title 17 “Smoke Management Guidelines for Agricultural Burning and Prescribed Burning”, California Co

et. Seq. California Air Resources Board, http://www.arb.ca.gov

44 State of California, Lake County Air Quality Management District, Rules and Regulations: Chapter VIII, Agricultural Burning

http://www.arb.ca.gov/DRDB/lak/CURHTML/LKRulebook7-13-01-PDF

45 State of California, Sacramento Metropolitan Air Quality Management District, Rule 407: Open Burning,

http://www.arb.ca.gov/DRDB/SAC/CURHTML/R407.htm and Rule 501: Agricultural Burning, http://www.arb.ca.gov/DRDB/

46 State of California, San Joaquin Valley Unified Air Pollution Control District, Rule 4103: Open Burning,

http://www.arb.ca.gov/DRDB/SJU/CURHTML/R4103.PDF

47 State of California, South Coast Air Quality Management District, Rule 444: Open Fires, http://www.arb.ca.gov/DRDB/SC/CU
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time and effort. The authors also recognize that the identification and development of nonburning alternatives is something that will likely evolve over time. The results of the survey

effort here clearly represent only “a snap shot in time” for all the programs reviewed. The results

of this effort are not intended and should not be interpreted as to be predictive of what states or

tribal entities may or may not intend to do in the future. Nor should the results of the survey

effort reported here be interpreted as necessarily a reflection on state or tribal entities or their

staffs commitment or desire to address agricultural burning as a source of air pollution through

the identification and implementation of non-burning alternatives. An assessment of state and

tribal entity future plans and/or desire or intent to address agricultural burning and the

identification and implementation of non-burning alternatives was not included in this effort.

The results of this survey effort simply reflect which of the previously identified

accountability mechanism appear to be in place for each state, local area or tribal entities in

general. It is important for the reader to keep in mind that this section is intended to be positive

and constructive. This section is intended to serve as a useful tool for those state or tribal entities

desiring to address the use of non-burning alternatives more effectively. One way to approach

this challenge is to compare how different states or tribal entities are addressing accountability

mechanism in their programs. Where specific states are used as examples the intent is to provide

useful comparisons of different program content. With this in mind the following review and

discussion is presented below.

The presence or, in some cases, the absence of Mechanisms 1-17 appears to

reflect whether non-burning alternatives will be used in the 15 Western states. In general, for

states with aggressive mandates to reduce agricultural burning, such as Washington, Oregon and

California, a large number of the accountability mechanisms identified in Table 5-2 were found

to be in place. These states have mechanisms in place that fall into all five categories of

accountability. These states also currently have the largest number and greatest variety of nonburning alternatives in use.

In those states with less aggressive smoke reduction programs or no formal

requirements to address agricultural burning, essentially no accountability mechanisms were

found to be in place. This was the case for Colorado, Nevada, South Dakota, and Utah. As a
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consequence, little or no direct information on non-burning alternatives was available for these

states. However, this finding in and of itself may not be significant. For states where

agricultural burning may not be a significant source of air pollution, it makes sense that their

programs would focus on other more relevant sources.

For those states that in practice effectively exempt agricultural burning from

regulation, few if any accountability mechanisms were found to be in place. Those that were

found to be in place were often in place to address other sources of open burning such as forest

and range land management activities. This was the case for Alaska, Arizona, New Mexico,

Montana, North Dakota, and Wyoming. No agricultural burning is indicated as occurring in

Alaska (see Volume I, Section 3.0).

For those states that have little or no agricultural crop production, such as Alaska,

Montana, and Wyoming, air quality programs may of practical necessity be focused on other

sources such as forest or rangeland management practices. (Crop production in these states is

documented in Volume I, Section 2.0.) Burn programs in general may also be in place to address

fire safety issues. However, in other states where a number of accountability mechanisms appear

to be in place, political, social, economic and practical programmatic resource factors may play a

significant role in the overall de-emphasis on addressing agricultural burning as a source of air

pollution in the state or region. This may be the case in North Dakota, Arizona, and New

Mexico.

In other states such as Idaho and Hawaii, a number of accountability mechanisms

are in place. In fact there are mechanisms in place for these states in all five categories of

accountability. However, the number of non-burning alternatives identified and in use for these

states remain insignificant. Patterns such as this suggest that additional research may be needed

to better identify and characterize the nature of the apparent inconsistency. It may be that

significant political, social, economic or practical programmatic resource factors are playing a

role here.

In tribal communities there appear to be agricultural burning review and approval

mechanisms in place. However, these appear to be less formal in nature with little emphasis on

agricultural burning per se and essentially no coordination with neighboring non-tribal land
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managers. The implementation of these mechanisms also appear to be more widely distributed

across local, county, tribal, state, and federal authorities than any of the 15 states in general. This

is likely a reflection of the wide variety of types of burning that occurs on the more than 54

million acres of tribal lands (WRAP, 2001b). It is also likely a reflection of the historically

independent and self-reliant nature of more than 240 tribal communities found in the 15 Western

states. However, this could simply be a reflection of the fact that very little air pollution from

agricultural burning sources may result from tribal activities and that air quality programs may of

practical necessity be focused on other sources such as forest or range land management

practices. Burn programs in general may also be in place to address fire safety issues on tribal

properties. As states and other entities gather more information on the extent of agricultural

burning activities on tribal lands, the identification and use of non-burning alternatives and the

presence of absence of accountability mechanisms in place at tribal government levels should be

possible.

Overall, the incentive and motivation to identify and use non-burning alternatives

are lacking in many of the 15 Western states. This may be due to a lack of effective

accountability mechanisms in place at the state and local program levels. In some states there are

formal requirements to consider alternatives to infield agricultural burning of residues prior to

carrying out field burning activities (Alaska, California, Hawaii, Idaho, New Mexico, Oregon,

and Washington). Although in some cases economic incentives do exist, such as in Oregon and

California, there are typically no formal requirements to actually implement non-burning

alternative management practices in any states. Furthermore, routine information regarding the

availability, applicability, and cost effectiveness of non-burning alternatives is typically not

provided by the states in any comprehensive or coordinated fashion. If alternatives are routinely

used, the degree to which non-burning alternatives are implemented is often not formally

tracked, making it difficult to appropriately credit the proactive participants in the non-burning

alternatives community. A more comprehensive discussion of the role these mechanisms might

play in furthering the identification, development, consideration and use of non-burning

alternatives in those of the 15 Western WRAP member states and tribal communities where

agricultural burning appears to be a significant source of air pollution in the region, state or air

basin can be found in Section 7.0 of this report.
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In some cases statutory changes may be required in order to provide for adequate

availability and implementation of the desired accountability mechanisms. In other cases lead

agencies may consider the development and implementation of voluntary accountability and/or

non-burning alternatives implementation programs. However, it is very important to note that

while voluntary programs may facilitate program development and implementation, in cases

where this would result in increased economic costs and changes in practical business operations

or management, voluntary programs alone are not typically effective in meeting overall air

quality program objectives. Voluntary programs under these circumstances often do not provide

adequate incentives to bring about significant changes in current practices.

Lastly, a critically important aspect of the burn program and accountability

mechanism review is the inconsistent definition of agricultural burning. How agricultural

burning is defined varies extensively throughout the regulations and rules reviewed for the

Western states. In some cases, agricultural burning defines only row or field crops. In some

cases, orchard and vineyard prunings are included as agricultural residues while in others they

are not. There is no consistency within the state regulations and rules with respect to how

irrigation ditch, fence line, or weed or land clearing for range land improvement or other

agricultural purposes are addressed. This complicates the interpretation of the findings of the

accountability mechanisms provided here. This issue is discussed further in Section 7.0 of this

report.
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6.0 NON-STATUTORY ADMINISTRATIVE

BARRIERS

This section describes the strategies used to research, identify, and characterize

non-statutory administrative barriers. In practice, non-statutory administrative barriers have the

potential to limit new program development and implementation to a greater extent than do

statutory barriers. Non-statutory administrative barriers are those situations, circumstances,

activities, or factors that serve to minimize, deter, or prevent the active use of non-burning

alternatives. These barriers are not defined in statute, rules, or regulations. These typically

result from, or are defined by, administrative practices associated with the implementation of

agricultural or open burning programs in the West. They can also develop as a result of political,

social, economic, cultural, and religious pressures that hinder or impede the development and use

of non-burning alternatives.

The non-statutory administrative barriers currently in place at the state level for

each of the 15 Western states (and where possible, at the county local, or tribal level) are

identified and discussed in this section. A discussion of how each non-statutory administrative

barrier may be addressed to increase the support, development, and use of non-burning

alternatives in each case identified is included in Section 7.0 of this report.

6.1 Research Strategy and Sources of Information

For this task, the same comprehensive three-tiered approach to identifying and

researching the various potential sources of information discussed in detail in prior chapters of

this report was used. The three-tiered approach included contacting and/or researching the

availability of information from three different levels of information sources.

The first level of information sources investigated included state environmental

agencies, boards and departments, county and local air pollution control authorities; their

respective administrative and statutory rules and regulations; formal published reports and

documents; and articles or summary information posted on official state level or county level

websites. As expected, the presence, or in some cases absence, of non-statutory administrative

barriers relevant to non-burning alternatives were known to staff at the state and county or local
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level environmental agencies and air authorities having responsibility for implementing

agricultural or open burning programs.

The second level of information sources researched were the agricultural

extension services agencies for all 15 Western states. The third level of sources included private

sector stakeholders identified during the first and second level research efforts. The most relevant

and comprehensive information regarding the identification and characterization of non-statutory

administrative barriers has come from informal survey information collected from state and local

air quality program staff, agricultural extension research staff and individual stakeholders who

currently use or desire to use to some degree, non-burning alternatives. Additional information

has also been collected from published reports and literature.

6.2 Non-Statutory Administrative Barriers Identified

There are many non-statutory administrative barriers (i.e. situations,

circumstances, activities and elements) which may minimize, deter and/or prevent the active use

of non-burning alternatives in the West. Non-statutory administrative barriers include the

following categories:

a. Economic challenges including labor costs; increased liability; disposal,

storage, packaging or transport costs; availability and/or willingness of

investors to provide capital for new technologies or non-traditional

methods; market return; crop yield, quality, and production rates;

b. Geographic limits due to climate or topography;

c. Political, cultural or religious practices;

d. Practical issues such as supply and demand of essential materials (e.g.,

seed or seedlings, storage facilities, machinery), reporting mechanisms,

timing and effectiveness of the non-burning alternative, and short- or longterm effects on the farm unit or agricultural operation;

e. Public acceptance of a practice or program result, which may be closely

tied to aesthetics; and

f. Aesthetics (e.g., visual, olfactory, and auditory, but also possibly nuisance

factors such as plant debris or dust infiltration or deposition in or near

homes and businesses).
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Eighteen non-statutory administrative barriers, which fall into four of the

categories as defined above, were identified. These currently exist in specific situations in the 15

Western states and are summarized in Table 6-1. No non-statutory administrative barriers were

identified for aesthetic or for public acceptance reasons, numbers (5) and (6) above.

6.3 Project Case Study

Case studies can be very useful tools in identifying what is working in a program

and what may need enhancing or improving. Case studies can provide this information in a

succinct format designed specifically for an audience comprised of environmental program

coordinators and/or state level executive decision-makers. One case study, entitled “Alaska

Agricultural Project, Delta Junction” in located in Appendix B. This case study illustrates how

the Alaska Department of Environmental Conservation (ADEC) successfully worked with the

agricultural community to address the issue of timing as a smoke management tool pertaining to

burning of wastes from land clearing in preparation for agricultural use.
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Table 6-1. Non-Statutory Administrative Barriers Identified in the 15 Western S

General Category and Description Non-Statutory Administrative Barriers

a. Economic Challenges • Transport costs to remove agricultural residues from the field, orchard or vineyard mu

• Labor and machine costs to bail and stack or otherwise collect field residues for offsit• Capital for investing in new technologies is limited.• Availability of investors and willingness to invest in new methodologies is limited.• Decreased market return, crop yield, crop quality, and production rates can occur with 

disease.

• Availability of economic incentives for burners to try new non-burning alternatives is • Program implementation of existing economic incentive programs is fractured and un• Water costs in the arid West and Southwest increase costs substantially for field resid

alternatives.

• Costs to remove straw can be up to 10 to 15 times greater than the costs to burn.• High cost of plowing for soil incorporation.• No or limited markets for marketing products made with residues.• Low market price of products made with residues do not offset costs.• Increased costs are associated with the need for more skilled labor to carry out special

incorporation activities.

b. Geographic Limits • The steep terrain in some mountainous states make it impractical to implement some n

• Climate barriers that affect crop yields.

c. Political, Cultural and/or Religious

Practices

• Cultural practices in at least one state center around agricultural burning activities. Ch

significantly impact local community cultural events.

• In at least one circumstance, historical promises play a role in the social and cultural a

burning alternative. During the great Dust Bowl, state officials lured farmers away frland and an agricultural way of life. Any changes to that way of life are difficult to ad

d. Practical Issues • Soil compaction and decreased drainage resulting from collection and bailing of straw

• Methane poisoning of soils with soil incorporation and increased release of a greenho• Increased water usage for soil incorporation.• Increased use of diesel harvesting and transport equipment which could increase air p• Decreased crop yields unless burning is allowed on at least a rotating basis.

• Increased soil erosion associated with increased fallow periods.• Disturbance of soil micro-organisms and soil fauna with soil incorporation practices.• Genetically improved plant varieties for various tolerances do not provide as high of y• Increased incidence of pest and weed infestations with many types of non-burning alte

e. Public Acceptance None identified.f. Aesthetics None identified.
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7.0 IMPLEMENTATION PLAN

This section provides a summary of general strategies for increasing the

development and use of non-burning alternatives in the 15 Western states. This section also

provides a summary of the overall results of this project to date and identifies some conclusions

that may be drawn based on the information, results and conclusions found in prior sections of

this report. The main conclusions provided here pertain to the identification and use of nonburning alternatives, the identification and implementation of program accountability

mechanisms, and the identification of non-statutory administrative barriers.

7.1 Review of Project Background and Study Objectives

 The Western Regional Air Partnership and its Fire Emissions Joint Forum

sponsored this project to provide more complete information about the identification and use of

non-burning alternatives to the common practice of infield burning of agricultural residues in the

West. The geographical scope of the project includes the 15 Western states of Alaska, Arizona,

California, Colorado, Hawaii, Idaho, Montana, North Dakota, New Mexico, Nevada, Oregon,

South Dakota, Utah, Washington, and Wyoming. State, as well as tribal, jurisdictional issues

were addressed.

The project objectives include the following:

1. Identification of current crops and the extent to which residue is disposed

of through burning for the 15 Western states (Sections 2.0 and 3.0 of

Volume I);

2. Display of the crop and agricultural burning data in a geographic database

using a geographical information system (Appendices B and D of Volume

I);

3. Identification of potential alternatives to agricultural burning and

characterization of their agronomic, environmental, health and safety,

social, economic, and political impacts (Section 2.0 of Volume II) ;

4. Development of criteria for selecting “reasonable” non-burning

alternatives, cost-abatement curves (i.e., cost of alternative by crop) and

examples of how to apply the criteria and cost-abatement curves to

evaluate alternatives (Sections 3.0 and 4.0 of Volume II);
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5. Identification of existing and potential accountability mechanisms for

tracking if, and which, non-burning alternatives are used by local, state,

tribal, or federal entities (Section 5.0 of Volume II);

6. Identification of existing and potential barriers to the use of alternatives,

including non-statutory barriers (e.g., public acceptance, cultural practices,

etc.), and recommendations on how these can be overcome (Section 6.0 of

Volume II); and

7. Development of a plan for implementing a non-burning program based on

the analysis, findings, and recommendations developed under this project

(Section 7.0 of Volume II).

The methodologies used to carry out this effort and to address the main objectives

noted above have been described in each of the previous sections. The overall results of this

effort and general conclusions that may be drawn as they pertain to the potential identification

and use of non-burning alternatives in the 15 Western states and tribal communities are presented

here.

7.2 Summary of Study Results

In addition to review of formal reports and articles, air quality agency,

environmental agency, agricultural extension services, and/or state university research

representatives from all 15 states as well as representatives from a variety of local regions within

several states were contacted (See Appendix A: List of Informal Survey Participants and Contact

Information). The information gained by contacting these representatives is presented here as

well as throughout this report.

Straw or residue management treatments can impact many aspects of agricultural

production and land management. Straw management practices, including the use of prescribed

fire, can impact levels of soil nutrients such as nitrogen (RCAAFC, 1998). Agronomists often

recommend returning unburned crop residues to the soil to help maintain soil organic matter

levels and to maintain or improve soil aggregation which inhibits erosion (NDSUCE, 1974).

Often it is highly desirable to keep crop stubble standing and residues in place on the soil surface

to protect from soil erosion, especially after seeding when the soil is most vulnerable (SAF,

1999). In some cases the need to burn, as a field residue, orchard, or vineyard management

technique, has been established to address disease incidence, pest infestation, or crop production
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(UCCE, 2001). For example, burning grass pastures can result in short-term increases in

nitrogen mineralization which results in short bursts of nutrient availability. It can also be used

to control weeds and sagebrush can be nearly eradicated from rangelands when burned in the late

fall when it is dry (MSUES, 1998).

However, in the majority of cases throughout the West, agricultural burning has

not been based on scientific reasoning but rather on many practical aspects of farm management

such as economics, crop production, expediency, tradition and ease of use (USDA, 1997c).

Today these practical aspects also include, in some cases, the absence of effective and

economically viable non-burning alternatives. In other cases, effective and economically viable

non-burning alternatives may exist, but the affected agricultural community may not have

knowledge of their existence or, for a variety of practical reasons may not be willing or able to

put them into practice in their daily operations.

Burning of crop residues was found to occur for all of the major crop groups (i.e.,

grains and hay, grasses and seeds, orchard, and fruits and vegetables). Also, other crops are

burned as well including sugarcane. In total, residues from more than 35 different crops are

burned in the states of Arizona, California, Colorado, Hawaii, Idaho, Montana, North Dakota,

Nevada, New Mexico, Oregon, South Dakota, Utah, Washington and Wyoming. Other

agricultural related fuels such as ditches and ditch banks, and CRP lands are reported as burned

in Idaho and Washington, respectively. (Appendix C of this report includes a copy of Table 3-5

from Volume I. This table shows the quantity of residues burned by state for various years.

Care should be taken not to compare quantities between states where the data represent different

years.)

More than 20 different non-burning alternatives organized into at least 4 different

major category types were identified in this effort (see Table 2-1 of this report). Qualitatively

one or more of these non-burning alternatives were found to be in use today or in the past in at

least 7 of the 15 states addressed by this effort. The quantitative extent to which non-burning

alternatives are in use in these states is highly variable and largely undocumented. It is possible

that these or other non-burning alternatives may in be use by the agricultural community in other

states or regions of the Western states; however, the documentation of this does not appear to
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exist at this time. Records which document the extent to which non-burning alternatives are

being used in lieu of open field burning were not found to be kept by any state or local agency

contacted during this research effort. This finding is further explained by the results of the

accountability mechanism assessment provided in Section 5.0 of this report. This is a

considerable obstacle in the identification and use of non-burning alternatives that has the

potential to significantly impact program implementation efforts.

Some states are now taking action to correct this gap in essential data collection.

These states include California (with its recent changes to Title 17 of the California Code of

Regulations) Washington (with its post-burn report card efforts), Alaska, and Nevada. However,

data collected to date remains in handwritten form. It has not been routinely input into electronic

form, quality checked, or included in emissions inventories (Pfeifer, 2001: informal survey

response from Grant Pfeifer, Washington Department of Ecology, Agricultural Burn Task

Force). Any data slated for collection in the future by California and other states was by

definition unavailable for this research effort. It is reasonable to expect that these data will

remain unavailable until states have fully implemented changes to their existing agricultural

burning programs; the data has been collected, and then made available for review. Responses

from a variety of other air quality and environmental agency representatives indicate that other

states are looking forward to collecting better data on agricultural burning practices in general, as

well as documenting the use and effectiveness of non-burning alternatives. For many states

significant changes in statutory authority (or in seemingly all cases, increases in essential

programmatic resources) are required before agencies and organizations or their representatives

can move forward in these program areas.

7.3 Discussion of Results Pertaining to the Identification and

Use of Non-Burning Alternatives

The majority of information collected and reviewed suggests that states, local

agencies, tribal communities and fire control experts agree that the development and use of nonburning alternatives is desirable for a number of reasons throughout the 15 Western states and

tribal communities. However, the identification, development and use of non-burning

alternatives throughout the Western states appear to be in the fundamental research stages. A

number of non-burning alternatives have been considered for a variety of crops in several states
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(CARB, 1993; CARB, 1997a; CARB, 1997b; CARB, 1998; CARB, 2001b; CIWB, 1998;

CIWB, 1999a; CIWB, 1999b; CIWB, 2000a; CIWB, 2000b; CIWB, 2001a; CIWB, 2001b;

CIWB, 2001c; CIWB, 2001d; MSUES, 1998; NDSUCE, 1974; NDSU, 1998; OSU USDA-ARS,

1994; OSU USDA-ARS, 1995; OSUES USDA-ARS, 1989; SAF, 1999; SCAC, 1995; UCCE,

2001; USDA, 1997c).

 However, there is considerable debate within the scientific community regarding

the potential impacts, benefits and/or dis-benefits of burning versus not burning. There is

considerable debate in the scientific community regarding the effectiveness and potential

agronomic impacts of the various non-burning residue treatments. There is also extensive debate

among researchers, air quality entities and affected agricultural parties regarding what is

“reasonable” or “feasible” when it comes to the use of non-burning alternatives. In many cases,

the need to conduct some form of burning, even if only under special circumstances, has been

supported by a number of agriculture experts.

As a consequence, the identification and large scale practical use of non-burning

alternatives was not found to exist in any state addressed in this effort. Although a few

potentially effective non-burning alternatives have been identified and are in use for some crops

grown in the West, the practical use has been limited to a very few crops, such as grass seed,

wheat, or rice. The practical use has also been limited to a few states or regions of the West.

These include Washington, Oregon and California. It is expected that this can be explained

largely by the programmatic limitations and overall practical development and implementation

issues identified in the assessment of accountability mechanisms outlined in Section 5.0 of this

report.

During the survey effort it was found that none of the 15 states surveyed currently

have or can provide a list of non-burning alternatives for any crops grown and otherwise known

to be burned in their states or agricultural burning regions. This is an important finding of this

effort. Representatives contacted during this effort routinely pointed to published research

reports and agency summary documents which discussed the issues surrounding the

identification and potential use of alternatives that were considered. However, none were able to

provide succinct summaries or lists identifying and supporting the practical use of known
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alternatives in settings appropriate for their state or region. This is not likely a reflection of the

lack of agency staff commitment to the non-burning program efforts; it is more likely a reflection

of incomplete statewide or regional program development and inadequate, or in some cases

nonexistent, interagency coordination. It is also more likely a reflection of incomplete or

inadequate stakeholder outreach, education, and overall involvement in the process to identify

and develop successful alternatives to burning in the state or local areas under their jurisdiction.

Accountability mechanisms play an important role in the identification,

development, consideration and use of non-burning alternatives to agricultural burning in the

West. The results of this effort suggest that the presence, or in some cases the absence, of

identified accountability mechanisms appear to effectively determine whether non-burning

alternatives will be used in the 15 Western states. The 17 mechanisms identified in this report

fall into five main categories of accountability (see Table 5-1). It was expected, and therefore

not surprising, that different states had varying numbers and types of accountability mechanisms

in place to address agricultural burning as a source of air pollution and visibility impairment.

For states where agricultural burning has not been identified as a significant source of air

pollution it seems reasonable that a limited number of mechanisms, if any, would be put in place

and that accountability mechanisms to address other more significant sources might be

emphasized instead. However, in those states and regions where agricultural burning does

significantly impact air quality, including visibility, it would be ideal to see the development and

implementation of a number of accountability mechanisms to address the issue of agricultural

burning.

Mechanisms 1 through 14 are essential for the support and validation of

Mechanisms 15, 16 and 17 (see Table 5-2 of this report). The degree to which these

accountability mechanisms are in place and in use by the various states is highly variable. There

are a number of important mechanisms in place for several of the states or regions which have

identified agricultural burning as a significant source of air pollution. These mechanisms

actively support the management of agricultural burning activities. However, several of the most

important mechanisms necessary for the identification and actual use of non-burning alternatives,

such as mechanisms 15, 16 and 17, do not appear to be in place in the majority of the 15

Western states and tribal communities studied, even in those states or regions where agricultural
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burning appears to have the potential to significantly impact air quality. These mechanisms

actively address the identification of effective non-burning alternatives, establish requirements to

consider the use of alternatives to burning prior to burn approval, and offer practical assistance in

offsetting costs to implement the typically more expensive non-burning alternatives.

Mechanisms 15, 16 and 17 provide accountability at the state or local level that

facilitates the active identification of, and encourages the consistent use of, effective non-burning

alternatives in conjunction with or as a substitute to traditional existing agricultural burning

practices. Mechanism 15 provides incentive to actively consider non-burning alternatives by

making it a requirement of pre-burn approval. This usually occurs during the pre-burn

permitting process. If no pre-burn permitting process exists, in all but the most unique of

circumstances, it is impractical and unrealistic to expect non-burning alternatives will be

considered to any significant extent. The relationship between the requirement to secure

approval prior to burning and the requirement to consider or practically implement some form of

non-burning alternative to at least a portion of the slated burn acreage is key to encouraging the

consideration and use on non-burning alternatives in the West.

Mechanism 16 provides financial assistance in one form or another to burners

who implement non-burning alternatives. This serves to help overcome one of the most often

voiced oppositions to the use of non-burning alternatives which is that of cost “ineffectiveness”.

Cost “ineffectiveness” is the most often cited reason for not using or implementing non-burning

alternatives. Practical use or effectiveness is another reason (see Table 6-1 of this report). The

latter may be overcome in time by more scientific research and close coordination with the

agricultural community. The former remains a significant barrier for most state, regional, or

local level entities who are trying to implement non-burning alternatives programs. In some

cases subsidies, tax credits, permit fee reductions, or rebates may be an effective way to address

this barrier. However, it is not always feasible for public entities to accommodate these financial

incentives. Although it may not always be feasible to provide financial assistance to offset direct

costs, it might be feasible for state air quality or environmental agencies to identify, if not

actually recruit, other state or local experts in the areas of manufacturing, product development,

marketing, and distribution to assist in the economic development of some types of non-burning

alternatives. In at least one case during this research effort, it was found that members of the
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agricultural community were willing and able to develop and manufacture highly desirable

products from rice straw stubble; however, they have been unable (to date) to overcome state

level administrative obstacles in storing, distributing and selling their product (informal survey

response, Jerry Maltby, Broken Box Ranch; see Appendix A).

Mechanism 17 has the potential to provide useful, practical incentives for the

increased use of non-burning alternatives by providing a list of viable, practical, economically

feasible alternatives that are available, currently in use, or have been used in the past. This

mechanism alone, if put into practice in each of the 15 Western states and tribal communities,

has the potential to eliminate another readily voiced opposition to the use of non-burning

alternatives which is that non-burning alternatives do not exist or cannot be used effectively.

If effective non-burning alternatives do exist, but the agricultural community is

unaware of their existence or is otherwise unconvinced of their effectiveness, it is impractical

and somewhat unrealistic to expect that non-burning alternatives will be considered to any

significant extent in any state or region of the West. If viable non-burning alternatives do exist

and can be used effectively in a particular state or region of the state, then it seems reasonable

that air quality and environmental agencies (with the support and input of the affected

agricultural community, other stakeholders, university and extension services researchers) should

be able to provide a consolidated well documented list, as needed, to anyone interested in

identifying and using non-burning alternatives for a particular crop type in areas or regions of

interest in the state. Historically, a number of the 15 states included in this effort have provided

significant amounts of funding to support the research and development of non-burning

alternatives. This is commendable and an excellent start to addressing this issue; however, these

efforts to date do not appear to have contributed significantly to the practical use of non-burning

alternatives in the majority of the Western states. Fortunately, this and other related nonstatutory administrative barriers may be largely addressed by increased research efforts and

improved stakeholder involvement, outreach, and communication efforts.

7.4 Developing Implementation Plans: Content

The results of this effort suggest a very clear starting point and overall path for

increasing the identification and use of non-burning alternatives in the West. One important step
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is the development of effective non-burning alternatives program implementation plans.

Programs that have the potential to be effectively implemented have several critical elements in

common (Black, 2000). These include the following eight essential elements:

• Element #1: Program-Specific Strategic Plan;

• Element #2: Correctly Identified Target Audience and Stakeholders;

• Element #3: Clear Concise Messages and Program Purpose;

• Element #4: Effective Communication Tools and Strategies;

• Element #5: Effective Resource Allocation;

• Element #6: Reasonable Program Expectations;

• Element #7: Solid Sustained Executive Commitment; and

• Element #8: Consistent Program Implementation.

7.4.1 Strategic Plan

The most essential element of any successful environmental program

implementation plan is the development of a program-specific strategic plan. A well developed

strategic plan serves as a road map for the entire program effort. It is essential for identifying

target audiences and for the development and delivery of, easily understood program messages.

In addition to clearly identifying goals and outlining reasonable objectives, a well developed

strategic plan will assist decision makers in defining the reasons for implementing a non-burning

alternatives program.

A strategic plan may be very simple in nature with only one or two clearly

defined goals and a few reasonable objectives; or it may be highly complex with numerous goals

and extensive accompanying objectives. It may encompass the entire organizational state level

program or it may address only those aspects related to agricultural burning in a given area.

Whatever form and complexity the strategic plan ultimately takes, for a non-burning alternatives

program to be successful the first step should be to deliberately develop a strategic program plan.
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7.4.2 Correctly Identified Target Audience and Stakeholders

To be successful, non-burning alternatives implementation programs must

correctly identify the target audience or stakeholders intended to be reached or ultimately

impacted by the implementation effort. The stakeholders identified will be tightly tied to the

purpose the air quality entities have for developing the programs. In some cases, it may be

important for the non-burning alternatives implementation program to incorporate stakeholder

expertise and comments in the identification and development of non-burning alternatives. In

other cases the implementation program may be limited to enhancing and encouraging the use of

previously identified alternatives.

In most cases, it is expected that plans will be developed to address both these

needs in most states or tribal communities where agricultural burning has been identified as a

significant source of air pollution. The target audiences or stakeholders identified will also

determine what communication tools are necessary for the overall implementation program

success. Whether these audiences include members of the regulated community or highly vocal

opposition members of environmental groups, if the stakeholders are not clearly identified, the

non-burning alternatives implementation program has essentially no chance of success.

Fortunately, target audiences and stakeholders can be clearly identified if strategic planning

activities are properly conducted.

7.4.3 Clear Concise Messages and Program Purpose

For any environmental program to succeed, it is essential that the program

purpose be clearly identified at the beginning. Only after the reason(s) for addressing

agricultural burning and for developing non-burning alternatives have been defined does it

become possible to develop clear messages which can be communicated to the affected

stakeholders and interested members of the public. The most successful non-burning programs

developed will have implementation plan elements that effectively deliver clear messages to the

target audiences and stakeholders that air quality and environmental entities would like to reach.

The collection and presentation of easily understood facts, data comparisons,

emissions estimates, case studies, success stories, photographs, images and diagrams is essential

to the success of this portion of the program development and implementation effort. Without
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documentation of current burning practices, emissions and air quality impacts, as well as proof of

the practical effective infield use of non-burning alternatives, it is difficult to establish program

purpose and credibility even with the most well designed and professionally implemented

communications program. This appears to be an area where incomplete or uncollected data

pertaining to agricultural burning activities and the identification and use of effective nonburning alternatives in the 15 Western states and tribal communities may play a significant role

in the development of non-burning alternatives implementation plans. This finding also helps to

prioritize which program development elements should be addressed initially for most states as

they go on to develop non-burning alternatives implementation programs.

7.4.4 Effective Communication Tools and Strategies

The most successful non-burning alternatives implementation programs will be

specifically designed to take advantage of the latest and most effective communication tools

available today. These tools will of necessity be tailored to address the communication skills and

needs of interested stakeholders as well as the communication skills and resources available to

the state, regional, local or tribal agencies. In this age of electronic media, stakeholders have

greater access to more information in shorter timeframes than ever before in the history of

civilization. Technology has made it possible for motivated members of the public and the

regulated community to follow, almost on a real time basis, environmental issues that may

impact their lives. Motivated stakeholders have become more informed about environmental

issues. As a consequence, they have become in many ways more demanding of service in their

search for knowledge. Their expectation of timeliness in the delivery of information has risen

exponentially. This changes the way public sector entities must reach out to and communicate

with the targeted stakeholders in their non-burning alternatives program implementation efforts.

However, this does not mean that to be successful, public sector entities need to

procure state-of-the-art communication technologies. It does mean that they should use what

they have effectively and secure the resources in the future to grow as they can. Public sector

entities do need to employ effectively those tools that they have at their disposal as well as assess

whether the tools they are using will be effective in reaching interested stakeholders. Whatever

communication tools and strategies are employed, it is essential that it be easy for stakeholders to

obtain information and to participate in the implementation program efforts. If agencies do not
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have in-house expertise to at least identify the available non-burning alternatives program

communication resources, and define effective strategies for addressing stakeholder

communication needs, they may want to consider procuring outside professional assistance.

Environmental programs that do not have effective communication tools and strategies in place

typically have little chance of successful implementation (USEPA, 2000a).

7.4.5 Effective Resource Allocation

Low, even “no budget”, non-burning alternatives program efforts can be

tremendously successful if they are carefully planned, consistently implemented, and

conscientiously include affected and interested stakeholders (see Section 6.0 and Appendix B of

this report). It is worth noting that a “rule of thumb” often applied to environmental program

implementation efforts is “the less money and resources spent on a program, the more time it

will take to successfully implement any given program”. Programmatic resources that are

available should be spent in those areas most likely to provide programmatic value. These areas

can be effectively identified in a well conducted strategic program planning effort.

7.4.6 Reasonable Program Expectations

The most successful non-burning alternatives implementation program efforts will

clearly identify and subsequently set reasonable program expectations. These expectations, if

identified correctly, should address a variety of program elements including implementation

timelines as well as program outcomes, deliverables, and progress measurement methodologies.

If air quality and environmental entities do not set reasonable program expectations and

communicate those expectations to interested stakeholders, the chances are very great that the

stakeholders will develop their own expectations. These expectations may not match those of

the air quality experts. These mismatches in expectations often create unnecessary

miscommunications and misunderstandings which often result in conflict. This can ultimately

create barriers to the successful implementation of otherwise important programmatic efforts.

Program challenges such as these can largely be avoided if reasonable program expectations are

established at the beginning of the implementation plan effort. The development of reasonable

program expectation often comes out of a well conducted strategic program planning effort.
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7.4.7 Solid Sustained Executive Commitment

A solid sustained executive commitment to support an implementation program is

essential to the success of any public program. A positive attitude triggers enthusiasm for any

effort (Chapman, 1995). This enthusiasm can often be felt even if it is not always seen on a

daily basis. However, as competing political, social and economic forces draw agency executive

resources and focus toward other often more imminent and seemingly urgent issues, executive

commitment to existing programs often wanes. This waning, although not always immediately

evident, usually always results in decreased program resources, staffing, and commitment to the

original program goals. This decreased commitment more often than not becomes readily

apparent to affected stakeholders. From the affected stakeholders’ perspective, if air quality and

environmental entities expect them commit to modify current agricultural practices and in some

cases cultural activities, the commitment on the part of the public agency to support and sustain

the implementation of the program will likely be expected.

7.4.8 Consistent Program Implementation

It takes time to effectively implement any public environmental program,

especially environmental programs to address air quality concerns which are inherently

intangible and can be difficult to grasp. Because of this, it is essential that non-burning

alternatives program implementation efforts be designed around reasonable program

expectations. To be successful in implementing non-burning alternatives programs, the way

people think and feel about agricultural practices, about burning and air quality in general, may

need to change. Changing the way people approach business activities, or think about complex

environmental issues takes time and consistent program implementation.

The timeframes needed to effectively implement any program will vary based on

the target stakeholder audiences identified and the overall non-burning alternatives program

purpose. In many cases, implementation programs will be designed to address several purposes

and to reach different target audiences or affected stakeholder groups. In these cases, multiple

time lines may need to be developed. Program expectations should also be adjusted accordingly.

Fortunately, reasonable program expectations and realistic time frames can be readily developed

once the program purpose has been defined and the target stakeholder audiences have been

identified through a well thought-out strategic planning effort.
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7.5 Developing Implementation Plans: Recommended Strategy

The results of this effort suggest a very clear starting point and methodology for

developing implementation plans to increase the identification and use of non-burning

alternatives in the West. Based on the results and conclusions found in the prior sections of this

report, the following strategy for developing successful non-burning alternatives program

implementation plans is recommended for any state, region or tribal entity desiring to increase

the identification and use of non-burning alternatives:

1. Air quality or environmental program entities should conduct a focused

review to identify the nature and extent to which agricultural burning

contributes to air quality problems in the state, or local, or tribal area. A

starting point for this review could be the evaluation of agricultural

burning activity presented in the companion Volume I document to this

report. A key element of this review that should be included is a careful

consideration of the definition of “agricultural burning”. This is important

so that accurate comparisons can be made between other states, local or

tribal programs. The review should also take into account the potential

impacts that agricultural burning may have on interstate regional air

quality.

2. If agricultural burning does not contribute significantly to local or

statewide air quality problems which fall under the jurisdiction of the

state, local or tribal entity, it is still recommended that the focused

program assessment also take into account, to the greatest extent possible,

the potential impacts agricultural burning may have on interstate regional

air quality.

3. If agricultural burning is not found to be a significant source of air

pollution for a given state, local region, tribal entity, or interstate region, it

may not be necessary to continue with non-burning alternatives program

development. This may be the case for some states that appear to lack

accountability mechanisms as noted in Section 5.0 of Volume II.

4. If agricultural burning is found to make a significant contribution to air

quality problems on either a local, state, tribal community or regional

level, then the air quality or environmental agencies in authority in the

affected areas and the areas contributing to the problems should work

together to define solutions and develop non-burning alternatives

programs. This will help to ensure success on a regional level.

5. If agricultural burning is found to be a significant source of air pollution

for a given state, local region, tribal entity or interstate region, or if a given

entity desires to more effectively implement non-burning alternatives, then
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an overall air quality review should be conducted to determine how to

integrate agricultural burning as a source. One goal of this review would

be to determine which of the accountability mechanisms identified in

Section 5.0 of this report are in place and how they are being used. Table

5-2 can be used to determine the specific accountability mechanisms and

tailor the agricultural burning program. In some cases statutory changes

may be required in order to provide for adequate availability and

implementation of the desired accountability mechanisms. In other cases

lead agencies may consider the development and implementation of

voluntary accountability and/or non-burning alternatives implementation

programs. However, it is very important to note that while voluntary

programs may facilitate the development and implementation of portions

of programs in some settings, in other cases they may not be effective.

For example, in where program development and implementation are

associated with increased economic costs and changes in practical

business operations or management, voluntary programs alone are not

typically effective in meeting overall air quality program objectives.

Voluntary programs under these circumstances often do not provide

adequate incentives to bring about significant changes in current practices.

6. For those states, local regions, and tribal entities desiring to more

effectively address the use of non-burning alternatives in general, it is

recommended that a list of effective and economically viable non-burning

alternatives be developed (ideally including non-burning alternatives for

use by crop, by season, and by region or area). Table 2-1 (listing of nonburning alternatives by crop) can be used to identify specific alternatives.

The criteria, methodology, and case studies described in Sections 3.0 and

4.0 of this report can be used to determine feasibility.

7. It is further recommended that a list, or in some cases multiple lists, of

feasible non-burning alternatives be maintained and updated periodically

by the participating lead public or private entity. The list(s) should be

made available using a variety of common effective communication

strategies, methods, and technologies.

8. If non-burning alternatives have not been previously identified or have not

been characterized for practical use an area, it is recommended that air

quality and environmental entities work closely with university and

agricultural extension scientists, affected agricultural community

stakeholders, and interested members of the public to identify and

characterize non-burning alternatives for specific use in their state or

region.

9. WRAP member states should form a technical working group or task force

to systematically review the identification and current use of non-burning

alternatives and to make recommendations, if desired, on how and where
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the use of these non-burning alternatives may be improved or enhanced in

other states, local regions, and tribal communities.

10. WRAP member states should work together to begin to address ancillary

non-emission related program implementation issues, such as assisting the

affected agricultural community and local business developers with postresidue removal product development, manufacturing, distribution, and

marketing. Although this often falls outside the traditional charter of most

state air quality and environmental programs, it does not fall outside the

realm of services offered by other state agencies, boards and

environmental departments. Some states have taken steps to assist in the

research and development stages but their efforts have not extended to

distribution and marketing.

11. It is highly recommended that the results of this and any of the above

mentioned program efforts be carried out in close coordination with a well

defined stakeholder outreach, education and communication program.

7.6 Agency Roles and Responsibilities

The agency roles and responsibilities associated with agricultural burn program

implementation were found to vary greatly throughout the 15 Western states and tribal

communities addressed in this effort. It was found that the accountability for agricultural

burning program development, coordination and implementation, although typically originating

at the state level, was in many cases delegated directly to local or regional entities (see Tables

5-2 and 5-2a of this report). In some states, where the primary concerns regarding agricultural

burning impacts were fire hazard and public safety, the authority to approve burning was

delegated to local fire agencies or even private contract fire control businesses. In no cases was

it found that local implementing agencies were required to quantitatively report back to the state

or region level on the status of the agricultural burning program implementation.

There was found to be essentially little or no coordination between tribal and nontribal burn entities (WRAP, 2001b). The authority to approve burns on tribal lands was found to

be exceptionally variable and spanned the entire range of agency authority from rural fire district

authority to federal land management agency.

The agency roles and responsibilities associated with the identification,

development and implementation of non-burning alternatives are not clearly identified for any of

the 15 Western states. In one case, the primary contact for the identification and use of non-
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burning alternatives was the state Waste Management Program (informal survey response, Tim

Rogers, South Dakota Department of Environment and Natural Resources; see Appendix A). In

another case, it was found that while a state level air quality agency and legislative authority had

generously developed and made available a monetary subsidy to support and encourage the

alternative use of rice straw, the program implementation was delegated to another agency (the

Department of Food and Agriculture). It appears that since the rice straw subsidy program was

not one of their own programs, the staffing and implementation priority were not given. The end

result of this agency role and responsibility inconsistency was the existence of a potentially

helpful economic subsidy provided by the state, the availability of several qualified applicants

currently using rice straw for other purposes, and more than a 2 year (and counting) wait for

application acceptance and subsidy funding (Public testimony provided by Jerry Maltby, Broken

Box Ranch Feedlot and Compost, California Air Resources Board public meeting to discuss the

impacts of legislative mandate to phase-down rice straw burning in the Sacramento area, June

28, 2001; see Appendix A).

As non-burning alternatives programs are reviewed or developed in many states,

it is recommended that the air quality or environmental agency responsible for initiating the

identification and development of non-burning alternatives also be responsible for monitoring

and implementing the non-burning alternatives program at the local level. While it makes sense

to work closely with the affected agricultural community through existing pathways, such as the

agricultural extension offices, natural resources conservation offices, local fire agencies or the

local and state departments of agriculture, unless these agencies and departments are fully

invested in statewide or even local or regional air quality program efforts, it may be difficult to

get the program implementation results desired. Nonetheless, these existing pathways can be

hugely valuable in the successful implementation of non-burning alternatives programs if they

are effectively incorporated, and relationships are clearly defined, in the air quality or

environmental entity’s strategic planning process.

Regional approaches to defining agency roles and responsibilities, where possible

are highly desirable as well. In another case, because Washington and Oregon have more

stringent air quality regulations, in the last 3-5 years grass seed companies have been relocating

to Wyoming where air quality regulations are less stringent (informal survey, Darla Potter,
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Wyoming Dept of Environmental Quality, 2001; see Appendix A). Clearly, the air quality and

environmental agency roles and responsibilities, whether defined by statute or delegated by the

same statutory authority, play an important role in the development and implementation of nonburning alternatives in the West.

7.7 Strategies to Address Stakeholder Involvement

Stakeholder acceptance of any effort to address environmental challenges will

always be tightly bound to the success of the lead environmental entity’s public outreach and

communication efforts to address the subject. It will also be tightly bound to their efforts to

include stakeholders in developing and implementing solutions to the identified challenges. This

is true for any state, region, local area or tribal community. To be successful in these efforts,

lead environmental agencies should provide the following critical program information to

interested parties and stakeholders:

• Clearly identified problem(s) or challenge(s);

• Carefully quantified significance or effect of the problem(s) or

challenge(s);

• Clearly identified solution(s) to the problems or challenges or, at a

minimum, a clearly defined method for identifying or obtaining critical

information necessary to develop solutions; and

• Clearly identified plan for addressing the problems or challenges

identified.

Not surprisingly, a well designed, closely coordinated and consistently

implemented stakeholder involvement, outreach and communication effort incorporating this

critical program information is also essential to the success of any non-burning alternatives

program. Not only will stakeholder involvement be essential for promoting the use of nonburning alternatives, it will likely be key in developing future alternatives to the current practice

of infield or onsite burning of residues. In this age of electronic media and the Internet, people

have become much more knowledgeable and increasingly more demanding of timely service in

their search for that knowledge. Unless the commitment to identify and implement the use of

non-burning alternatives is understood and its value embraced and shared by the public as well
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as the regulated agricultural communities, the implementation of non-burning alternatives will

likely remain marginal in many of the 15 states and tribal communities addressed in this effort.

Stakeholder involvement, education and communication efforts can be handled on

a one-on-one basis as an organization’s staff come in contact with stakeholders and other

members of the public or they can be addressed with a formalized, organization supported and

endorsed outreach effort. Although it is still based in part on one-on-one contacts, the latter is

much more effective and is preferred.

To be more successful in these efforts, air quality agencies and environmental

managers must develop non-burning alternatives implementation programs that contain solid

well supported public outreach and communication efforts that also increase stakeholder

involvement. The strategies and tools needed to address stakeholder outreach in the 15 western

states and Tribal communities included in this effort were not assessed directly. This was not

within the scope of this current effort. However, based on the results of the accountability

mechanisms assessment provided in Section 5.0 of this report, stakeholder involvement is

expected to vary greatly.

Those states with more aggressive mandates to address agricultural burning, in

general, may already have in place fairly adequate stakeholder outreach programs. States that

are just developing programs to address agricultural burning are less likely to have well

developed programs to address stakeholder involvement. Taking into consideration the results of

the accountability mechanisms assessment found in Section 5.0 of this report, if they do desire to

address the use of non-burning alternatives more effectively, it is likely that all 15 Western states

and tribal entities identified in this effort could benefit greatly from well designed, focused, and

consistently implemented non-burning alternatives stakeholder involvement, outreach and

education programs. A careful assessment of current stakeholder involvement efforts is

recommended for each state, local, regional or tribal entity interested in addressing agricultural

burning through the use of non-burning alternatives.

No matter what the ultimate goal of a non-burning alternatives implementation

program is, historical burning practices will always remain more familiar, more immediately

tangible and likely more cost effective. This is because existing agricultural operations are
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already set up to conduct business in the traditional fashion. In some cases, whole cultures and

communities have grown up around specialized agricultural operations.

This is the case in New Mexico where centuries-old farming practices rely on the

communal management of water delivered by an elaborate system of irrigation ditches. These

irrigation ditch systems, or “acequia,” are maintained by the entire community. Acequias formed

the basis for settlement of New Mexico’s Indo-Hispanic communities between two and four

hundred years ago (NMAA, 2002). Today, a statewide organization of communities

representing the 1000 or so autonomous organizations that maintain their own acequia and share

water by custom and tradition has been formed and it is called the New Mexico Acequia

Association. There are often community celebrations and cultural activities centered around the

maintenance of the acequias. The maintenance of acequias in many parts of New Mexico also

involves the annual burning of weeds that grow in these irrigation ditches (informal survey

response, Brad Musick, New Mexico Environmental Department Air Quality Bureau; see

Appendix A). Changing agricultural practices in these communities and possibly many others

throughout the West is very challenging since it may require in some cases the modification or

ultimate abandonment of some cultural practices. In some cases, this practically equates to

changing the way people have lived their lives and conducted business in their communities for

generations.

As urban communities encroach on these more rural agriculturally based

communities, public pressure to decrease or eliminate burning may play a role. Although the

fuel source and agricultural practices may differ in New Mexico, this is much the same situation

as seen in most all of the growing Western states. It is expected that political and social

pressures supporting the need to find and make use of viable non-burning alternatives will come

into play to a greater extent in the future. It is also expected that these will have an impact on

how stakeholder involvement is carried out in each of the 15 Western states and tribal

communities identified in this effort. Program implementation success will be greatly tied to an

agency’s ability to communicate to the public and affected industries it serves, why the program

is valuable and provide valid information as to why it is expected that the program will be

successful. The public is intelligent and informed and more than capable of understanding the

need to address air quality concerns. However, neither the public nor the regulated agricultural
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communities will accept what they can not understand or what they do not value (USEPA,

2000b). It is up to the air quality and environmental management entities to effectively

communicate the need to identify and utilize alternatives to burning in the West.

Lastly, it is important to note that program implementation planning and timing is

very important in the development and implementation of programs to encourage the use of nonburning alternatives. When in place, statutorily mandated 30 and 60 public noticing

requirements often dictate the assignment of communication program and implementation

timelines for regulatory activities. However, these statutory requirements often have little or

nothing to do with the actual timeframes needed to develop and implement effective public

communication programs. Instead, although expectedly unintended, they are often instrumental

in defining unreasonable communication and program implementation expectations.

While statutory deadlines must be met, reasonable program expectations should

also be set if a public communication program and stakeholder involvement effort is to be

successful in addressing the identification and use of non-burning alternatives. The key to

addressing the issue of program implementation and timing is to involve stakeholders in the

beginning of any process. The key is also to allow adequate time for the communication and

stakeholder involvement effort to work. It is reasonable to expect that effective stakeholder

involvement and communication efforts may take on the order of 1 to 3 years or more to

implement.

For most states surveyed as part of this research effort, few if any of the four

essential information areas necessary for developing and implementing effective stakeholder

outreach and involvement efforts as noted above, have been adequately addressed. This is an

area where additional work is recommended for those states and tribal communities that desire to

address the use of non-burning alternatives. Fortunately most states desiring to address

agricultural burning appear to be aware of these issues and are taking steps to begin addressing

these program development and implementation challenges. However, in light of the time

frames discussed here and the program information data gaps discussed here and elsewhere, it

seems clear that good strategic planning and program development will be essential for any state,
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local, regional or tribal entity desiring to address the use of non-burning alternatives more

effectively.

7.8 Suggestions for Further Research and Information

Development

A number of directions for further research and information development

necessary for Western states and tribal communities to begin addressing the identification and

use of non-burning alternatives more effectively have been identified through this study. These

fall into the following main categories:

1. Better characterization of agricultural burning activities in the 15 Western

states and tribal communities addressed in this effort, including the

development of a consistent definition for “agricultural burning”;

2. More consistent and thorough collection and evaluation of agricultural

burning activity data by regulatory agencies and stakeholders;

3. More thorough assessment of the impacts agricultural burning has on air

quality and visibility in the participating states, local areas, tribal

communities and WRAP member state regions;

4. On-going identification, characterization and accounting of effective nonburning alternatives and their use;

5. Effective inclusion of stakeholders in the identification and

implementation of non-burning alternatives; and

6. Development of well designed, consistently implemented stakeholder

outreach, education and communication programs that not only address

state or local issues but bridge gaps in interstate and regional

communication and provide consistent, readily understood messages.
Vol. II: Non-Burning Management

Alternatives, Final - May 2002

8-1

8.0 REFERENCES

Black, K., 2000. “The Eight Essential Elements of a Successful Prescribed Burning Program

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Buttner, P., 2002. Paul Buttner, California Rice Commission, Sacramento, California, personal

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CARB, 1997b. “Progress Report on the Phase Down of Rice Straw Burning in the Sacramento

Valley Air Basin 1995-1996: 1997 Report to the Legislature”, California Air Resources Board,

Sacramento, California.

CARB, 1998. Rice Straw Diversion Plan. Downloaded 5/18/01 from: http://www.arb.ca.gov/

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CARB, 2000. “Agricultural Burning Emission Factors”, Technical Memorandum from Dale

Shimp, Manager, Emission Inventory Analysis Section, to Beverly Werner, Manager, Regulatory

Assistance Section. California Air Resources Board, Sacramento, California. August 17.

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Down of Rice Straw Burning in the Sacramento Valley Air Basin: Proposed 2001 Report to the

Legislature”, California Air Resources Board, Sacramento, California. June.

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17, California Code of Regulations, Sections 80100, et. Seq. Adopted January 2001. California

Air Resources Board, Sacramento, California.

Chambers, B.N. and Childs, 2000. “Characteristics of U.S. Rice Farming”, Rice Situation and

Outlook. Chambers, Bill and Nathan Childs. November.

Chapman, E. 1995. Attitude-Your Most Priceless Possession. Third edition. Crisp Publications,

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8-2

CIWB, 1998. Feasibility Study on the Expanded Use of Agricultural and Forest Waste in

Commercial Products. Publication 431-98-019. Downloaded 11/9/01 from: http://www.ciwmb.

ca.gov/publications/markets/43198019.doc. California Integrated Waste Management Board,

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Sacramento, California.

CIWB, 1999b. Results of Northern California Compost Demonstrations. Downloaded January,

2002 from: http://www.ciwmb.ca.gov/publications. California Integrated Waste Management

Board, Sacramento, California.

CIWB, 2000a. Compost Demonstration Project, Placer County: Use of Compost and CoCompost as a Primary Erosion Control Material. Downloaded January, 2000 from:

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Sacramento, California.

CIWB, 2000b. Avocados Grow Better with Chips. Downloaded November, 2000 from:

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CIWB, 2001a. Assessment of California’s Compost- and Mulch-Producing Infrastructure.

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Waste Management Board, Sacramento, California.

CIWB, 2001b. Biomass to Energy. Downloaded 6/20/01 from: http://www.ciwmb.ca.gov/

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California.

CIWB, 2001d. Non-Yard Wood Waste Report. Draft. Downloaded 6/16/01 from: http://

www.ciwmb. ca.gov/publications. California Integrated Waste Management Board, Sacramento,

California.

Cross, T., M. Mellbye, B. Young, and M. Taylor, 1992. “Enterprise Budget: Tall Fescue Seed,

Willamette Valley Region”, Oregon State University Extension Service publication EM 8495.

Corvallis, Oregon. March .

Earth Saver, 2001. Earth Saver: Your Runoff and Sediment Control Solution. Downloaded

5/17/01 from: http://www.earth-savers.com. Winters, California.

FWS, 1999. “Arctic Ecosystems in Peril: Report of the Arctic Goose Habitat Working Group”,

Downloaded 10/31/01 from : http://migratorybirds.fws.gov/issues/arcgoose/ partii/factors.html.

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8-3

GCVTC, 1996. “Report of the Grand Canyon Visibility Transport Commission to the United

States Environmental Protections Agency”, Grand Canyon Visibility Transport Commission,

June 1996.

GOS, 2000. “Best Management Practices when Harvesting Surplus Cereal Straw”, Government

of Saskatchewan.

HARC, 2001. Letter from Stephanie Whalen, Hawaii Agricultural Research Center, Aica,

Hawaii, to Paula Fields, ERG, Inc. August 24.

Jenkins, B. M., 2002. Air Pollutant Emission Factors used in Development of the 2018

Emissions Inventory for Agricultural Burning; developed for the WGA/WRAP Fire Emissions

Joint Forum by Dr. Bryan M. Jenkins and the Fire Emissions Joint Forum/Emissions Task Team.

May 1.

MSUES, 1998. “Burning Stubble: A Frequent Question”, James W. Bauder, Agronomy Notes

Series 129, Montana State University Extension Services, January 30.

NDSU, 1998. Straw Can Be An Economical Cow Feed, News Release, North Dakota State

University Agricultural Extension.

NDSUCE, 1974. “Effects of Burning Crop Residue”, D.F. Wagner, Cooperative Extension

Service, North Dakota State University, September.

NRCS, 2002. “California NRCS Field Office Technical Guide”, Downloaded 5/1/02 from:

http://www.ca.nrcs.usda.gov/rts/fotgintco.htm. U.S. Department of Agriculture, Natural

Resource Conservation Service, Resource Technology Section, Davis, California.

NMAA, 2002. New Mexico Acequia Association, Downloaded from:

http://www.nmacequias.org.

OSU USDA-ARS, 1994. “Seed Production Research,” Oregon State University USDA-ARS

Cooperating, Edited by William C. Young III, Department of Crop and Soil Science Ext/CrS

102. April.

OSU USDA-ARS, 1995. “Seed Production Research,” Oregon State University USDA-ARS

Cooperating, Edited by William C. Young III, Dept of Crop and Soil Science Ext/CrS 106.

March.

OSUES USDA-ARS, 1989. “Burning Grass Seed Fields in Oregon’s Willamette Valley, The

Search For Solutions,” Oregon State University Extension Service, Oregon Agricultural

Experiment Station, and USDA-ARS Cooperating, Extension Miscellaneous 8397.

Pfeifer, G., 2001. Grant Pfeifer, Washington State Department of Ecology, Agricultural Burning

Task Force, Informal survey response. April 16.
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Alternatives, Final - May 2002

8-4

RCAAFC, 1997. “Effect of Straw Management and Nitrogen Fertilizer on Selected Soil

Properties as Potential Soil Quality Indicators of an Irrigated Dark Brown Chernozemic Soil, J.F.

Dormaar and J.M. Carefoot, Research Center, Agriculture and Agri-Food Canada, LRC

Contribution no. 3879735, March.

REI, 1997. “Alternative Uses of Rice-Straw in California. Final Report 94-330”, Prepared for

California Air Resources Board by the Renewable Energy Institute.

Rogers, K., 2002. Kevin Rogers, Cotton and Alfalfa Farmer, USDA Air Quality Task Force

Member, Phoenix Arizona, Informal survey response. May 13.

SAF, 1999. Best Management Practices when Harvesting Cereal Straw (Interim Farm Fact),

Saskatchewan Agriculture and Food. Downloaded from: http:/www.agr.gov.sk.ca.

SCAC, 1995. “Advisory Committee on Alternatives to Rice Straw Burning Report”, Special

California Advisory Committee on Alternatives to Rice Straw Burning.

Taylor, Michael, et al, 1990. “Enterprise Budget, Annual Rye Grass Seed, Willamette Valley

Region”. Oregon State University Extension Service, EM 8423. February.

UCCE, 2001. “In-field Shredding of Almond Prunings as an Alternative to Burning”, Roger

Duncan, Stanislaus County UC Cooperative Farm Advisor. Website: efarm.org.

USDA, 1997a. ARS Helps Grass Seed Growers Produce Seed Without Field Burning.

Downloaded 5/18/01 from: http://www.ars.usda.gov/is/pr/1997/970821.htm. U.S. Department

of Agriculture, Agricultural Research Services.

USDA, 1997b. Less Fire, More Science for Grass Growers. Downloaded 5/18/01 from:

http://www.ars.usda.gov/is/pr/1997/turf0897.htm. U.S. Department of Agriculture, Agricultural

Research Services.

USDA, 1997c. “Burning on Croplands”, Prepared by: Dr. Jerry Lemunyon, United States

Department of Agriculture Air Quality Task Force, Technical Subcommittee, Bob Odom,

Chairman, November 20.

USDA, 1999. Financial Performance of U.S. Farm Businesses. Downloaded 6/20/2001 from:

http://www.ers.usda.gov/Briefing/FarmFinancialMgmt/brief99.htm. U.S. Department of

Agriculture, Economic Research Service, Farm Financial Management Staff, Washington, DC.

December.

USDA, 2001. Agricultural Resource Management Study (ARMS) Survey Webpage.

Downloaded 6/28/01 from: http.//www.ers.usda.gov/data/ARMS/index.htm. U.S. Department of

Agriculture, Economic Research Service (USDA/ERG). Data released August, 2000.

USDC, 1997. Regional Multipliers, A User Handbook for the Regional Input-Output Modeling

System (RIMS II) (Third Edition), U.S. Government Printing Office. U.S. Department of

Commerce, Bureau of Economic Analysis, Washington, DC. March.
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8-5

USEPA, 2000a. Risk and Decision Making Workshop Manual, U.S. Environmental Protection

Agency, Region 9, San Francisco, California.

USEPA, 2000b. Risk Communication and Public Involvement Workshop Manual. U. S.

Environmental Protection Agency, Region #9, San Francisco, California.

USEPA, 2001a. Kentucky Bluegrass (KBG) Seed Crops—Agricultural Methodologies for

Reducing Air Emissions, U.S. Environmental Protection Agency, Region 10, Seattle,

Washington.

USEPA, 2001b. Economic Analysis of the Proposed Revisions to the National Pollutant

Discharge Elimination System and Effluent Guidelines for Concentrated Animal Feeding

Operations, EPA-821-R-01-001. Downloaded 6/20/01 from: http://www.epa.gov/ost/guide

/cafo/economics.html. U. S. Environmental Protection Agency, Office of Water, Washington,

DC. January.

Wagoner, M., 2002. Mark Wagoner, Alfalfa Seed Farmer, Tonchet, Washington, informal

survey response, May 8.

WDOE, 1998a. “Estimates of the Costs and Benefits of the Rule to Certify Alternatives to Grass

Field Burning”, Washington State Dept of Ecology, Air Quality Program. May.

WDOE, 1998b. State of Washington Clean Air Act, 173-430-010, Agricultural Burning

Regulation. Origin Nov 1977, Modified May 1998. Washington Department of Ecology,

Website: http://www.ecy.wa.gov/biblio/wac173430.html.

WDOE, 2001. “Cereal Grain Crops Best Management Practices.” Downloaded 5/16/01 from:

http://www.ecy.wa.gov/programs/air/bmpscer.htm. Washington State Department of Ecology.

WESTAR, 1999. “Western States Agricultural Burning Survey”,. Western States Air Resources

Council, Portland, Oregon. April.

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to Produce Rice, Sacramento Valley-2001, Rice Only Rotation.” University of California

Cooperative Extension, Department of Agricultural and Resource Economics, RI-SV-01.

WRAP, 2001a. “Agricultural Burning Smoke Management Program Survey, Draft Final

Report”, Prepared for the Western Regional Air Partnership by EC/R, Durham, North Carolina.

March.

WRAP, 2001b. “Tribal Emissions Inventories and Air Quality Data Gathering and Assessment

Project, Draft”, Prepared by the Institute for Tribal Environmental Professionals, Northern

Arizona University, Flagstaff, Arizona. April.
APPENDIX A

LIST OF INFORMAL SURVEY PARTICIPANTS AND CONTACT

INFORMATION
List of Informal Survey Participants and Contact Information

State Contact Affiliation Purpose Phone Fax Email

AK Ann Lawton Dept. Env. Conservation Air Program 907.269.3066 -- ann_lawton@envircon.state.ak.us

Gerry Guay Dept. Env. Conservation General 907.269.3070 -- --

Dr. Anthony Nakazawa Univ. AK Fairbanks, Coop. Ext. Alternatives 907.474.7246 907.474.6971 fnatn@uaf.edu

Phil Kaspari Univ. AK Fairbanks, Coop. Ext. Alternatives 907.895.4215 -- fnpnk@uaf.edu

AZ Varma Sunil Dept. Env. Quality Air Program 602.207.2322 -- varma.sunil@ev.state.az.us

Shannon Reif Dept. Env. Quality Air Program 602.207.2369 -- --

Dena Kanopka Dept. Env. Quality Air Program 602.207.2378 -- --

Bill Maxwell Pima County Dept Env. Quality Implemetation 520.740.3340 -- bmaxwell@deq.co.pima.az.us

Donald Gabrielson Pinal County Dept Env. Quality Air Program 520.868.6929 520.868.6967 don.gabrielson@co.pinal.az.us

Curt Foster Yuma County Fire Dept Burn Info 520.782.4757 -- --

Rick Hado Maricopa Cnty Dpt Env. Quality Burn Info 602.506.6700 -- --

Dr. James Christenson Univ. AZ College of Agriculture Alternatives 520.621.7209 520.621.1314 jimc@ag.arizona.edu

Kevin Rogers Cotton/Alfalfa Farmer Alternatives 602.757.5779 -- --

CA Arndt Lorensen Cal/EPA Air Resources Board Air Program 916.322.6040 -- alorenze@arb.ca.gov

Patrick Gaffney Cal/EPA Air Resources Board Emissions -- pgaffney@arb.ca.gov

Karen Magliano Cal/EPA Air Resources Board Air Program 916.322.7137 -- kmaglian@arb.ca.gov

Tina Suarez-Murias Cal/EPA Air Resources Board Air Program 916.323.1495 -- tsuarezm@arb.ca.gov

Dr. W.R.Gomes Univ. California Coop. Ext. Alternatives 510.987.0060 510.451.2317 wr.gomes@ucop.edu

Jerry Maltby Broken Box Ranch, Private Alternatives 530.473.3006 530.473.5481 bbr@mako.com

CO Coleen Campbell Dept. Public Health General 303.692.3224 303.782.5493 coleen.campbell@state.co.us

Pat McLaughlin Dept. Public Health General 303.692.3256 -- --

Phyllis Woodforld Dept. Public Health Burn Info 303.692.3221 303.782.0278 phyllis.woodford@state.co.us

Dirk Wold Dept. Public Health Burn Info 303.692.3150 303.782.0278 dirk.wold@state.co,us

Milan A.Rewerts CO State Univ. Coop. Ext. Alternatives 970.491.6281 970.491.6208 mrewerts@vines.colostate.edu

Dr. Mary Gray CO State Univ. Coop. Ext. Alternatives 970.491.6281 970.491.6208 mgray@vines.colostate.edu

HI Lisa Young Dept. of Health General 808.586.4200 -- --

Janet Ashman Ag Research Center Burn Info 808.486.5307 -- jashman@HARC-HSPA.com

Susan Kihara Dept. of Health General 808.586.4200 -- --

Dr. H.Michael HarringtonUniv. HI Coop. Ext. Alternatives 970.491.6280 970.491.7396 wdal@lamar.colostate.edu

Dr. Andrew Hashimoto Univ. HI Coop. Ext. Alternatives 808.956.8234 808.956.9105 dean@avax.ctahr.hawaii.edu

Dr. Ron Mau Univ. HI Coop. Ext. Alternatives -- -- maur@ctahr.hawaii.edu

Continued

A-1
List of Informal Survey Participants and Contact Information

State Contact Affiliation Purpose Phone Fax Email

ID Diane Riley ID Dept. Env. Quality Air Program 208.373.0214 -- driley@deq.state.id.us

Dan Redline Courdelaine Regional Office Burn Info 208.769.1422 -- dredline@deq.state.id.us

Curt Thornberg Dept. Ag. Alternatives 208.322.8633 -- cthornbu@agri.state.id.us

Mike Dubois Dept. Env. Quality Emissions Info 208.373.0136 -- --

Dr. Leroy Luft/ Roger 

Veseth Univ. ID Coop. Ext. Alternatives 208.885.6639 208.885.6654 extdir@uiuc.edu

MT Bob Habeck Dep. Env. Quality Air Program 406.444.7305 -- bhabeck@state.mt.us

Dave Levinson Dep. Env. Quality Burn Info 406.329.4952 -- --

Dan Walsh Dep. Env. Quality Air Program 406.444.0285 -- dwalsh@state.mt.us

Dr. David Bryant MO State Univ. Coop. Ext. Alternatives 406.994.6647 406.994.1756 dbryant@montana.edu

ND Chuck McDonald State Health Dept. General 701.328.5188 -- cmcdonal@state.nd.us

Dr. Sharon Anderson/ 

Duane Bergland ND State Univ. Coop. Ext. Alternatives 701.231.8944 701.231.8378 ext-dir@ndsext.nodak.edu

NM Brad Musick Dept. Env. Air Qual. Air Program 505.827.0335 -- brad_musick@nmenu.stste.nm.us

Paula Garcia Private Group Cultural Pract. -- -- --

Dr. Jerry Schickedanz/ 

Denise McWilliams NM State Univ. Coop. Ext. Alternatives 505.646.3016 505.646.5975 adean@nmsu.edu

NV Colleen Cripps Div. Env. Protection Air Program 707.687.4670 -- --

Karen L. Hinton Univ. NV Coop. Ext. Alternatives 775.784.4848 775.784.4881 hinton@agnt1.ag.unr.edu

John Burton Univ. NV Coop. Ext. Alternatives 775.784.7070 775.784.7079 burtonj@unce.unr.edu

OR Brian Finneran Dep. Env. Quality Air Program 503.229.6278 -- --

John Hamblin OR Dept. Ag. Burn Info 503.986.4702 -- --

Patti Gentiluomo OR Dept. Ag. Alternatives 503.986.4793 -- --

Suzy Pettey Dept Ag Burn Info 503.986.4794 -- --

Dr. Lyla Houghlum OR State Univ. Coop. Ext. Alternatives 541.737.2713 541.737.4423 lyla.houglum@orst.edu

Kathryn BarryStelljes USDA Ag Research Service Alternatives 510.559.6069 -- --

SD Tim Rogers Dept. Env. Nat. Res. Burn Info 605.773.6706 -- tim.rogers@state.sd.us

Chris Hansen Dept. Env. Nat. Res. Air Program 605.773.3151 -- --

No Contact Waste Mgmt Program Alternatives 605.773.3153 -- --

Larry Tideman SD State Univ. Coop. Ext. Alternatives 605.688.4792 605.688.6347 tidemann.larry@ces.sdstate.edu

A-2
List of Informal Survey Participants and Contact Information

Continued

State Contact Affiliation Purpose Phone Fax Email

Tribes Sarah Kelly Inst. Tribal Environ. Prof. Tribal Info 928.523.6377 -- --

UT Francis Bernards Dept Env. Quality General 801.536.4056 -- fbernard@deq.state.ut.us

Dr. Robert Gilliland UT State Univ. Coop. Ext. Alternatives 435.797.2201 435.797.3268 bobg@ext.usu.edu

WA Grant Pfeifer Dept. Ecol. Ag Burn Burn Info 509.456.3284 -- GPFE461@ECY.Wa.Gov

Dr. Michael Tate WA State Univ. Coop. Ext. Alternatives 509.335.2933 509.335.2926 mtate@wsu.edu

Mark Wagoner Alfalfa Seed Farmer Alternatives 509.394.2970 509.394.0479 wagoner@wwics.com

WY Darla Potter Dept. Env. Quality Burn Info 307.777.7346 307.777.5616 dpotte@state.wy.us

Dr. Glen Whipple Univ. WY Coop Ext. Alternatives 307.766.5124 307.766.3998 glen@uwyo.edu

Grant Stumbough Dept. Ag. Nat Resources Alternatives 307.777.7321 307.777.6593 --

End

A-3
APPENDIX B

PROJECT CASE STUDY:

ALASKA AGRICULTURE PROJECT, DELTA JUNCTION
B-1

Alaska Agriculture Project, Delta Junction

Objective:

To present realistic information on the successes and challenges currently seen or encountered in

developing and implementing non-burning alternatives in the West.

Geographic Location (i.e. State, County, Region, Tribe, etc.):

Delta Junction, Alaska (64° latitude, 146° longitude)

This community is rather remote, but still on a road system. It is a three-hour drive to Fairbanks

(in good weather with good road conditions), which is its nearest large community.

Description:

The Alaska Agriculture Project was initially started in Palmer, Alaska, in approx.1940. The

objective was to populate the Alaska territory so that it could become a state. Because the Palmer

Project was a success, the Delta Project (approx. 1970s) was implemented and designed to

improve the state’s resource base. As land was cleared to provide open spaces for agriculture,

large piles of woody debris were deposited along the edges of cropland (Figures 8-1 through 8-3).

Agriculture in Alaska is difficult at best, but it can provide produce (potatoes, kole crops), meat

(cattle, swine, some elk, reindeer, buffalo), feed (dryland hay and grain primarily) and milk at a

price that is cheaper than shipping it from Lower 48 markets. However, a sustained, reliable

supply is not always achievable. Proceeds from crops only during the past ten years were

variable, from $1.9 million to $5 million, largely depending on weather.

The Delta Projects are in danger of “going away” primarily because weather conditions are

severe, which limits a sustained supply, which limits the market. Politics are also a limiting

factor here, partially because a state-funded program must exist in order to sustain agriculture

through low-market prices, small infrastructure, and other limitations to farming. Hope springs

eternal, however, particularly among Alaskan farmers. They are a tough breed. They call

themselves “The Frozen Chosen.”
B-2

This case study has more to do with proper timing and coordination of agricultural burning than

it does with non-burning alternatives. Timing is an important smoke management tool.

Figure B-1: Close up View of piles woody

debris from land clearing (Delta Junction,

Alaska).

Figure B-2: Close up view of piled woody

debris and vehicle for scale, land clearing

(Delta Junction, Alaska).

Figure B-3: Aerial “Birds Eye” view of long

rows of piled woody debris from land clearing

(Delta Junction, Alaska).
B-3

Figure B-4: Post burn view of prior woody

debris pile from land clearing (Delta Junction,

Alaska).

Case Study Successes or Positive Benefits

The success of this case study comes in the manner that the challenge was overcome. They still

burn, but in a more coordinated and environmentally-safe fashion (Figure B-4).

Practical considerations outweighed political and social considerations in the end.

Environmental and statutory considerations were satisfied.

The Delta Projects were allowed to continue burning to remove debris (which is the cheapest and

most practical alternative for this situation), and the community keeps its farming resource which

is desperately needed due to the closure of nearby Fort Greely, one of its major sources of

income.

Challenges or Limits

When the land was cleared in the 1970s, the idea was to either use the piles as windrows or burn

them in place. The clearing method that was used intentionally incorporated dirt into the piles

because the “proper” burning technique at the time involved a “kiln-effect” where the debris

smoldered within the pile and the dirt and snow prevented smoke from escaping. This technique

didn’t work.
B-4

Because the piles were not clean, burning did not occur, or when it did it was a dismal failure.

Not only did the piles smolder for many days, the debris often didn’t completely burn, which left

large debris without fine material to get it lit and keep it burning.

Alaska legislature recently passed a “Right to Farm” bill limiting civil suits against farmers for

odors or smoke. This was done in direct response to the open burning practices done by the

farmers prior to Alaska Dept. of Environmental Conservation (DEC) coordination. The bill does

not limit DEC enforcement.

Prior to the Right to Farm bill and DEC coordination with farmers, smoke from open burning of

land clearing debris was so bad, you literally could not see the road. It caused a school bus to

run off the road. No one was injured, but it led to a series of events that caused friction between

Alaska Division of Forestry, Division of Agriculture, DEC, the farmers, the local residents, and

the Governor’s office.

Recommendations to Overcome Challenges or Limits

Communication and flexibility among all stakeholders, including regulatory agency. Due to the

controversial nature of the smoke problem, we established a “Task Force” which brought all

interested parties to the table to work out a resolution. If nothing else, this method defused the

situation and brought about a more thorough understanding of all parties’ grievances. Angry

words were said, but ultimately solutions were achieved.

Anecdotal incident: Prior to the formation of the Task Force, DEC had tried several techniques

of enforcement. All of these techniques failed, primarily because DEC did not fully understand

the cultural, logistical and societal elements of the problem.

At the Governor’s request, DEC held a public meeting in Delta which was attended primarily by

the farmers who thought DEC would inflict more unreasonable regulations on them. Needless to

say, the tone of the meeting was tense at best.

I presented the DEC’s case to the farmers at this meeting, and was well aware of the negative

reaction I was receiving. Alaskans are notorious for their dislike of government intrusion, and

this is particularly the case in remote Alaska. Arms folded, frowns, and grunts were the primary
B-5

responses to my statements. When I asked how I could fix the problem, how we all could fix the

problem, they asked me if I could stay another day to take “The Tour.” I readily agreed.

The next day, seven of us piled into a Suburban and began driving. It should be noted that it was

late October and bitter cold with a lot of snow on the ground. We drove for nearly an hour,

asphalt road became gravel, gravel became dirt, yet we kept driving. I had no idea where I was.

I was also new to Alaska and understood that remote areas can be deadly without proper respect

for the environment. It appeared we were deep in the “Cold As I’ve Ever Been Middle of

Nowhere.”

At last we stopped, and the driver got out. I nervously asked (with humor), “Is this where I get

out?” The driver said, “Oh no! You could still get back from here!”

*********** Case Study Participant Additional Comments*********

The Tour ended up being an excellent experience. For me, it was a tremendous opportunity to

understand the full extent of the problem, to get to know the people, and some of the things they

believe are more important than unreasonable state regulations. In return, they began to

understand that there are better ways to burn. We achieved a workable compromise, which

makes it a 100% success.

I also attended some Farm Symposiums (statewide conference) and gave a presentation at the

Farm Forum (a yearly gathering in Delta). Now, I’m fairly well-known by the community, the

local Cooperative, the Agricultural Extension staff, and the Division of Agriculture. They know

that if there’s a problem, we’ll all figure out a way to fix it.

Magnitude of Potential Impact

The debris does not easily decompose primarily due to extreme weather. It’s been there for 10 to

30 years and has only gotten spongy and regrown trees and weeds. It’s now much more difficult

to burn than it was 30 years ago. In addition, they usually need to be burned twice (burning

piles, replying into round piles, burning again).

Alternatively, it is also an extreme wildfire hazard at times, partially due to high winds and dry

conditions in the summer. The debris is also a target for arsonists, which makes it a double-
B-6

hazard. Most residents in the area cannot afford fire insurance. In addition, when the piles ARE

burned, wildfire escapement is a very real danger.

Alaska Division of Forestry recommended moving residents out of areas for short period of time

while they conducted controlled burns to remove hazard. Proposal estimate at $2 million in

1995. Project denied due to high cost. Approximate cost to state for wildfire suppression and

smoke past ten years = approx. $7 million.

One wildfire destroyed thousands of acres of farmland and nearly destroyed the entire town of

Delta in mid-80s in which arson was a prime cause (arson was denied by the community and it

was blamed on rouge lightening). Those farmers with completely cleared land are thriving and

consist of the largest acreage and largest financial income at this time.

Most often heard: “It’s a serious liability for the farmer to do it, might burn down the area,

including houses. It was the state’s idea to do it this way, let the state come up with the money

to clean it up.”

Average percentage of farmers with debris piles on their land = 75%; average size = 40 ft. wide x

10 ft. high with majority being longer than 1,000 ft in length without breaks; average total length

on land = 6 miles; 0-100 ft. from standing trees.

Statistics indicate that the debris piles comprise about 20% of the fields. The piles harbor pests

and weeds, interfere with drainage and water access (snow accumulates on one side which limits

water on the far side and water does not flow evenly), and interfere with efficient cultivation

(requiring extra passes with equipment, blockages in turning equipment, etc.).

Protecting Alaska produce from diseases is important because currently Alaska is able to sell

“organic” produce and seed stock due to the lack of common disease organisms. Very little

pesticide, if any, is needed here.

In 1997, the Delta Project had approximately 18,300 acres in cropland (of potential 90,000 acres

total for livestock and crop land), which was almost 60% of the state total for that year. Harvest

of crops in the Delta Project was $2,830,000 which was 29% of the state total. Crops and
B-7

livestock production for the Delta area was $4.7 million which accounted for 32% of the state

totals.

Removing all piles, assuming they presently comprise 20% of crop land, might increase proceeds

to greater than 20% due to: greater efficiency, higher acreage in production (important in small

business/small infrastructure), larger amount of feed for livestock in area, greater water

capacity/drainage, etc.

When viewed from the bigger perspective, it is in the best interest of all concerned to make sure

the hazards and obstacles are removed as much as possible. This includes obstacles in the form

of government regulations. This can be accomplished without compromising public health if

done properly.

The ultimate solution required flexibility from DEC, a streamlined permitting process, and more

oversight and guidance from the local Alaska Division of Forestry. Forestry conducts an

inspection for each site. They are on heightened alert during burning, which generally occurs

during the spring and fall. Fall is best because they wait for a low front to come in carrying

snow three days after the piles have been ignited. The snow covers the embers which after three

days are beginning to smolder. The wood under the snow continues to burn down for a month or

more. Only one or two land owner is allowed to burn at a time, and they still incur all liability

for burning. But the process is safer, smoke complaints have been reduced 99%, and the

community appears quite happy with the compromise.

Contact Information

Name: Ann Lawton Phone: 907-269-3066

Title: Open Burning, Environmental

Specialist

Fax: 907-269-7508

Affiliation: Alaska Department of

Environmental Conservation

Email: ann_lawton@envircon.state.ak.us

Address: 555 Cordova Street, Anchorage,

AK 99501

Website:
APPENDIX C

RELEVANT VOLUME I TABLES
 C-1

Table 3-5. Summary of Agricultural Residues Burned within the Western States for Various Ye

AZ CA CO HI ID MT ND NM NV2 OR S

Fuel/Residue 2000/01 1996/97/99 Avg 1996 1996 1996 Avg 1996/Avg 1998 1996 A

Grains and HayBarley 889 167,943 21,429 14Corn, for Grain 1,680 36,380 Corn, Unspecified 5,112Hay, Alfalfa 7,213 Hay, All Other 361 Oats 3,944 7,902 Rice 764,293Rye 124Wheat, All 15,352 224,709 376,010 5,055 410,145 6,560 244,755 Wheat, Spring 2,000 Wheat, Winter All 84Grasses and SeedsBermuda 9,400 49,224Grasses, Propaning 3,204Grasses, StackBurning

 38,205

Seeds, Other 1,604 Seeds, Alfalfa 6,701 Seeds, Grasses (FieldBurning), Unspecified

3,014 569,616 

Seeds, KBG

100,000

Sudan 5,770OrchardAlmond 310,836Apple 74 8,071 Apricot 6,603Avocado 1,371Cherry 7,511 Citrus 548 15,458Fig 12,097Grape 78,860 Nectarine 6,951Olive 8,042Pruning, Unspecified 2 5,570 Pruning, Other 2,454
Table 3-5. Continued

C-2

AZ CA CO HI ID MT ND NM NV2 OR S

Fuel/Residue 2000/01 1996/97/99 Avg 1996 1996 1996 Avg 1996/Avg 1998 1996 A

Removal, Unspecified 84,359 Peach 22,940 Pear 17,748 Pecan 7 3,186Pistachio 17 24,136Plum, Prune, Pluot 25,152 Walnut 113,223OtherAsparagus 8,819 Beans 300 4,430 Other 3,561 352 Peas 1 Safflower 6,686Sugarcane 4 420,000Agricultural Related FuelsCRP Ditches, Ditch Banks 1,225 25,552 160,013 Total3 31,619 1,898,134 2,000 420,000 811,018 5,055 410,145 6,560 20,952 890,223 98

1AK does not conduct agricultural burning as defined under this project; thus only 14 states are shown. Values on this table represent tons of agricultu

state or developed with gap-filling/averaging techniques. As such, values for states should not be compared to each other.

2NV reports 20,952 acres burned; since specific crops are not indicated, residue (tons) cannot be estimated (Sergent, 2002).3Sum of individual crops may not be equal total due to rounding.

Seeds, Other = All seeds not including alfalfa and Kentucky bluegrass (KBG).Pruning, Other = Bushberry, kiwi, date, persimmon, pomegranate, quinceOther, Other = Other fruits and vegetables, unspecified, sorghum, peanuts, mint, jojoba beans, canola, hopsWheat, All = All wheat not including spring and winter, all