# Enclosure 1

Arizona Revised Statutes §§49-104 and 49-404

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49-104. Powers and duties of the department and director A. The department shall: 1. Formulate policies, plans and programs to implement this title to protect the environment. 2. Stimulate and encourage all local, state, regional and federal governmental agencies and all private persons and enterprises that have similar and rela ted objectives and purpos es, cooperate with those agencies, persons and enterprises an d correlate department plans, programs and operations with those of the agencies, persons and enterprises.

3. Conduct research on its own initiative or at the request of the governor, the legislature or state or local agencies pertaining to any department objectives.

4. Provide information and advice on request of any local, state or fe deral agencies and private persons and business enterprises on matters within the scope of the department.

5. Consult with and make recommendations to th e governor and the legislature on all matters concerning department objectives.

6. Promote and coordinate the mana gement of air resources to assu re their protection, enhancement and balanced utilization consistent with the environmental policy of this state. 7. Promote and coordinate the prot ection and enhancement of the qua lity of water resources consistent with the environmental policy of this state. 8. Encourage industrial, commer cial, residential and communit y development that maximizes

environmental benefits and minimizes the effect s of less desirable environmental conditions. 9. Assure the preservation and enhancement of natural beauty and man-made scenic qualities. 10. Provide for the prevention and abatement of all water and air pollution including that related to particulates, gases, dust, vapors, noise, radiation, od or, nutrients and heated liq uids in accordance with article 3 of this chapter and chapters 2 and 3 of this title. 11. Promote and recommend methods for the recovery , recycling and reuse or, if recycling is not possible, the disposal of solid wastes consistent with sound health, scenic and environmental quality policies. 12. Prevent pollution through the regulation of the storage, handling and transportation of solids, liquids and gases that may cause or contribute to pollution.

13. Promote the restoratio n and reclamation of degraded or de spoiled areas and na tural resources. 14. Assist the department of health services in recr uiting and training state, local and district health department personnel. 15. Participate in the state civil defense program and develop the necessary organization and facilities to

meet wartime or other disasters. 16. Cooperate with the Arizona-Mexico commission in the governor's office and with researchers at

universities in this state to collect data and conduct projects in the United Stat es and Mexico on issues that are within the scope of the department's duties an d that relate to quality of life, trade and economic development in this state in a manner that will help the Arizona-Mexico commission to assess and enhance the economic competit iveness of this state and of the Arizona-Mexico region. B. The department, through the director, shall:
1. Contract for the services of outside advisers, co nsultants and aides reasonably necessary or desirable to enable the department to adequately perform its duties. 2. Contract and incur obligations reasonably nece ssary or desirable within the general scope of department activities and operatio ns to enable the department to adequately perform its duties. 3. Utilize any medium of communication, publicatio n and exhibition when disseminating information, advertising and publicity in any field of its purposes, obje ctives or duties. 4. Adopt procedural rules that are necessary to implement the authority granted under this title, but that are not inconsistent with other provisions of this title. Senate House Legislative Council JLBC More Agencies Bills Committees Calendars/News 

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. g ov/FormatDocument.as p ?inDoc=/ars/49/00104.ht m&Title=49&DocT yp e=ARS5. Contract with other agencies including labora tories in furthering any department program. 6. Use monies, facilities or services to provide matc hing contributions under fe deral or other programs that further the objectives an d programs of the department. 7. Accept gifts, grants, matching monies or direct payments from public or private agencies or private persons and enterprises for department services an d publications and to conduct programs that are consistent with the general purposes and objectives of this chapter. Monies received pursuant to this paragraph shall be deposited in the department fund corresponding to the service, publication or program provided. 8. Provide for the examination of any premises if the director has reasonable cause to believe that a violation of any environmental law or rule exists or is being committed on the premises. The director shall give the owner or operator th e opportunity for its representative to accompany the director on an examination of those premis es. Within forty-five days after the date of the examination, the department shall provide to the owner or operat or a copy of any report produced as a result of any examination of the premises. 9. Supervise sanitary engine ering facilities and projects in this stat e, authority for which is vested in the department, and own or lease land on which sanitary engineering facilities are located, and operate the facilities, if the director determines that owning, le asing or operating is necessa ry for the public health, safety or welfare. 10. Adopt and enforce rules relating to approving design documents for constructing, improving and operating sanitary engineering and other facilities fo r disposing of solid, liquid or gaseous deleterious

matter. 11. Define and prescribe reasonably necessary rules regarding the wa ter supply, sewage disposal and garbage collection and disposal for subdivisions. The rules shall: (a) Provide for minimum sanitary facilities to be installed in the subdivision and may require that water systems plan for future needs and be of adequate size and capacity to deliver specified minimum quantities of drinking water and to treat all sewage. (b) Provide that the design documents showing or describing the water supply, sewage disposal and garbage collection facilities be submitted with a fee to the department for review and that no lots in any subdivision be offered for sale before compliance wi th the standards and rules has been demonstrated by approval of the design documents by the department. 12. Prescribe reasonably necessary me asures to prevent pollution of water used in public or semipublic swimming pools and bathing places and to prevent dele terious conditions at such places. The rules shall prescribe minimum standards for the design of and for sanitary conditions at any public or semipublic swimming pool or bathing place and provide for abatement as public nuisances of premises and facilities that do not comply with the minimum standards. Th e rules shall be developed in cooperation with the director of the department of health services and shall be consistent with the rules adopted by the director of the department of heal th services pursuant to section 36 -136, subsection H, paragraph 10. 13. Prescribe reasonable rules regarding sewage colle ction, treatment, disposal and reclamation systems to prevent the transmission of sewage borne or insect borne diseases. The rules shall: (a) Prescribe minimum standards for the design of se wage collection systems and treatment, disposal and reclamation systems and for operating the systems. (b) Provide for inspecting the premises, systems and installations and for abating as a public nuisance any collection system, process, treatment plant, disp osal system or reclamation system that does not comply with the minimum standards. (c) Require that design documents for all sewage collection systems, sewage collection system extensions, treatment plants, processes, devices, equipment, disposal systems, on-site wastewater treatment facilities and reclamation systems be submit ted with a fee for review to the department and may require that the design documents anticipate and provide for future sewage treatment needs. (d) Require that construction, reconstruction, installa tion or initiation of any sewage collection system, sewage collection system extension, treatment plant, process, device, equipmen t, disposal system, onsite wastewater treatment facility or reclamatio n system conform with applicable requirements. 14. Prescribe reasonably necessary rules regarding excreta storage, ha ndling, treatment, transportation and disposal. The rules shall: (a) Prescribe minimum standards for human excreta st orage, handling, treatment, transportation and disposal and shall provide for inspec tion of premises, proc esses and vehicles and for abating as public nuisances any premises, processes or vehicles that do not comply with the minimum standards. (b) Provide that vehicles transporting human excret a from privies, septic ta nks, cesspools and other treatment processes shall be licensed by the depa rtment subject to compliance with the rules. 15. Perform the responsibilities of implementing and maintaining a data automation management system to support the reporting requirements of title III of the superfund amendments and reauthorization act of 1986 (P.L. 99-499) and title 26, chapter 2, article 3.
16. Approve remediation levels pursuant to article 4 of this chapter. C. The department may charge fees to cover the co sts of all permits and inspections it performs to insure compliance with rule s adopted under section 49-203, subsection A, paragraph 6, except that state agencies are exempt from paying the fees. Monies collected pursuant to this subsection shall be deposited in the water qu ality fee fund es tablished by section 49-210. D. The director may: 

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. g ov/FormatDocument.as p ?inDoc=/ars/49/00104.ht m&Title=49&DocT yp e=ARS1. If he has reasonable cause to be lieve that a violation of any environmental law or rule exists or is being committed, inspect any person or property in transit through this state and any vehicle in which the person or property is being tr ansported and detain or disinfect the person, property or vehicle as reasonably necessary to protect the environment if a violation exists. 2. Authorize in writing any qualified officer or empl oyee in the department to perform any act that the director is authorized or required to do by law.

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# Arizona State Legislature Bill Number Search:

Forty-ninth Legislature - Second Regular Session change session 

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49-404

. State implementation plan

A. The director shall maintain a state implementation plan that provides for implementation,

maintenance and enforcement of nati onal ambient air quality standards and protection of visibility as required by the clean air act. B. The director may adopt rules that describe proc edures for adoption of revisions to the state implementation plan. C. The state implementation plan and all revisions adopted before September 30, 1992 remain in effect according to their terms, except to the extent otherwise provided by the clean air act, inconsistent with any provision of the clean air act, or revised by the administrator. No control requirement in effect, or required to be adopted by an order, settlement agreement or plan in effect, before the enactment of the clean air act in any area which is a nonattainment or maintenance area for any air pollutant may be modified after enactment in any manner unless the modi fication insures equivale nt or greater emission reductions of the air pollutant. The director shall evaluate and adopt re visions to the plan in conformity with federal regulations and guidelines promulgated by the administrator for those purposes until the rules required by subsec tion B are effective.

©2007 Arizona State Legislature. privacy statment Senate House Legislative Council JLBC More Agencies Bills Committees Calendars/News 

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# Enclosure 2

State Implementation Plan Completeness Checklist

## STATE IMPLEMENTATION PLAN COMPLETENESS CHECKLIST

Submittal of

Revision to the Arizona State Implementation Plan Agricultural Best Management Practices April 2010

1. SUBMITTAL LETTER FROM GOVERNOR/DESIGNEE

Included

2. EVIDENCE OF ADOPTION

See submittal letter.

3. STATE LEGAL AUTHORITY FOR ADOPTION/IMPLEMENTATION

See Enclosure 1.

4. COMPLETE COPY OF STATUTE/REGULATION/DOCUMENT

See Enclosure 3.

5. WRITTEN SUMMARY OF RULE/RULE CHANGE

See Enclosure 3.

6. RULE CHANGES INDICATED BY UNDERLINING AND CROSS-OUTS

Not applicable.

7. EVIDENCE THAT ARIZONA ADMINISTRATIVE PROCEDURE ACT REQUIREMENTS

WERE MET FOR RULE/PLAN

See Enclosure 3.

8. EVIDENCE OF PUBLIC HEARING PER 40 CFR 51.102

See Enclosure 3.

9. PUBLIC COMMENTS AND AGENCY RESPONSE

See Enclosure 3.

10. IDENTIFICATION OF POLLUTANTS REGULATED BY RULE/PLAN

This State Implementation Plan revi sion pertains to emissions of PM 10



### .

### 11. IDENTIFICATION OF SOURCES/ATTAINMENT STATUS

See Enclosure 3.

12. RULE’S/PLAN’S EFFECT ON EMISSIONS

See Enclosure 3.

13. DEMONSTRATION THAT NAAQS, PSD INCREMENTS AND RFP ARE PROTECTED

See Enclosure 3.

14. MODELING SUPPORT

See Enclosure 3.

15. EVIDENCE THAT EMISSIONS LIMITATIONS ARE BASED ON CONTINUOUS

EMISSIONS REDUCTION TECHNOLOGY

Not applicable.

16. IDENTIFICATION OF RULE SECTIONS CONTAINING EMISSION LIMITS, WORK PRACTICE STANDARDS, AND/OR RECORD KEEPING/REPORTING REQUIREMENTS

Not applicable.

17. COMPLIANCE/ENFORCEMENT STRATEGIES

Not applicable.

18. ECONOMIC TECHNICAL JUSTIFICATION FOR DEVIATION FROM U.S. ENVIRONMENTAL PROTECTION AGENCY (EPA) POLICIES

No known deviation from EPA policy.

# Enclosure 3

Final Revision to the Arizona State Implementation Plan Maricopa County PM 10 

# Serious Nonattainment Area Agricultural Best Management Practices

# Arizona State Implementation Plan

Maricopa County PM 10 

# Serious Nonattainment Area

Agricultural Best Management Practices

Air Quality Division April 2010

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1

## TABLE OF CONTENTS

EXECUTIVE SUMMARY .............................................................................................................4

CHAPTER 1.0 INTRODUCTION ...............................................................................................6 1.1 Physical and Meteorological De scription of the Maricopa County PM 10 

## Serious

Nonattainment Area...................................................................................................6 1.2 The Maricopa County PM 10 

## Nonattainment Area History ........................................8 1.3 Maricopa Association of Governme nts (MAG) 2007 Five Percent Plan for PM 10 

## for the Maricopa County Nonattainment Area ........................................................10 1.4 Agricultural Best Manage ment Practices SIP Revision...........................................13

CHAPTER 2.0 AGRICULTURAL BEST M ANAGEMENT PRACTICES SELECTION

PROCESS ..........................................................................................................14 2.1 Actions of the Governor’s Agricultural Best Management Practices Committee...14

2.2 Senate Bill 1552 and Committee Actions................................................................15

CHAPTER 3.0 ADDITIONAL AGRICULTURAL BEST MANAGEMENT PRACTICES ...18 3.1 Best Management Practices .....................................................................................18 3.1.1 Cessation of Night Tillage on High Pollution Advisory Days ..................18 3.1.2 Green Chop ................................................................................................18 3.1.3 Integrated Pest Management......................................................................18 3.1.4 Precision Farming ......................................................................................19 3.1.5 Transgenic Crops ...................................................................................... 19 3.2 Emissions Reductions from Revisions to the BMP Program ..................................19 3.2.1 Number of BMPs Require d Per Agricultural Category.............................20 3.2.2 Cessation of Night Tilling..........................................................................20 3.2.3 Extension of the Agricultural BMP Program to the Maricopa County

Portion of Area A.......................................................................................20

3.3 Conclusion ...............................................................................................................21

CHAPTER 4.0 OUTREACH......................................................................................................22

3.1 Public Outreach Activities .......................................................................................22

CHAPTER 5.0 CONCLUSION..................................................................................................24

LIST OF FIGURES

CHAPTER 1.0 Figure 1: Maricopa County PM 10 

## Nonattainment Area..................................................................7 Figure 2: Annual 2005 PM 10 

## Emissions in the PM 10 

## Nonattainment Area ..................................12

CHAPTER 2.0 Figure 3: Map of PM 10 

## Nonattainment Area and Area A.............................................................16

2

## LIST OF APPENDICES

APPENDIX A (AgBMP Rule)

APPENDIX B (Technical Support)

APPENDIX C (Booklet and Pocket Guide)

APPENDIX D (Public Process)

3

## EXECUTIVE SUMMARY

The purpose of this State Implementation Plan (SIP ) revision is to address the contribution from agricultural practices to the Maricopa County Nonattainment area for particulate matter pollution. The Maricopa County PM 10 

## Serious Nonattainment area encompasses the Phoenix metropolitan area and the surrounding cities. The ar ea has remained in violation of the federal health standards for particulate matter of 10 microns or less (PM 10 

## ) emissions since the standard was adopted in 1987. To address the problem numerous emission control programs have been adopted. Among the many sources of PM 10 

## emissions contributing to nonattainment, agricultural activities have been required to be subject to controls. On August 4, 1997, the Environmental Protection Agency (EPA) approved in part the Plan for Attainment of the 24-hour PM 10 

## Standard – Maricopa County PM 10 

## Nonattainment Area and disapproved the demonstrations for several source categories of PM 10 

## , including agricultural sources. In order to addr ess agricultural

sources of PM 10 

## , the Arizona Legislature created the G overnor’s Agricultural Best Management Practices Committee (Committee) in 1998 to develop requirements of an agricultural general permit and alternative best management practices (BMPs) fo r controlling dust.

Arizona has made several submittals to address the Clean Air Act (CAA) requirements for

serious PM 10 

## nonattainment area plans in the Phoenix area. These include documents submitted by the Arizona Department of Environmental Qual ity (ADEQ) and the Maricopa Association of Governments (MAG). The EPA views these submittals collectively as the full serious area PM 10 

## plan for the Phoenix area, with the Revised Maricopa Association of Governments 1999 Serious Area Particulate Plan for PM-10 for the Maricopa County Nonattainment Area as the primary document (67 FR 48718). Parts of the 1999 plan were approved by EPA on July 25, 2002, and

the attainment deadline was extended to December 31, 2006. The nonattainment area was unable to reach attainment by this extended deadline, which subjec ted the area to Clean Air Act requirements stipulating that PM 10 

## emissions in the nonattainment area be reduced by five percent per year until the PM 10 

## standard is attained. To address agricultural sources of PM 10 

## emissions and contribute to the required fi ve percent reductions, the Committee adopted new agricultural BMPs to reduce PM 10 

## emissions from agricultural activities. Senate Bill (SB) 1552 also addressed agricultural sources of PM 10 

## by requiring the use of tw o BMPs per agricultural category and expanding the applicable area of BM Ps to include the Maricopa County portions of

Area A.

This document revises the Agricultural Best Management Practices, Maricopa County PM 10 

## Serious Area State Implementation Plan submitted in 2001, to reflect additional BMPs, an increase in the number of required BMPs from one to two per agricultural category, and an extended area of implementation. Chapter 1.0 contai ns a brief history of the nonattainment area. Chapter 2.0 contains a description of the review and analysis process used by the Committee and the results of this process. Descriptions of the BMPs adopted by the Committee are included in Chapter 3.0. Chapter 4.0 contains a description of the public outreac h activities that were held to inform the agricultural community of the changes to the BMP Program.

With this submittal, ADEQ requests that EPA approve this SIP Revision to the 2001 Agricultural Best Management Practices, Maricopa County PM 10 

## Serious Area State Implementation Plan.

4

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5

### 6 

## CHAPTER 1.0 INTRODUCTION

The Maricopa County Planning Area has a long hist ory of air quality challenges. Due in part to

its location in the heart of the Sonoran Desert as well as the complexity attributed to any large and still growing metropolitan area, air quality has been a ffected by numerous sources and activities, both man-made and natural. This State Implementation Plan (SIP) Revision outlines local conditions as well as the related regulato ry history for pollution from particulate matter (suspended particles 10 micrometers or smaller in diameter, also known as PM 10 

## ) for activities in the Maricopa County Planning Area related to agricultu re. Agricultural ac tivities have been regulated in the Maricopa County Planning Area since 1998; howeve r, the agricultural community continues to evaluate and commit to revise or add new practices that decrease

concentrations of PM 10 

## as demonstrated in this SIP Revision.

1.1 Physical and Meteorological Descri ption of the Maricopa County PM 10 

## Serious

Nonattainment Area

The Maricopa County PM 10 

## Serious Nonattainment Area cont ains portions of the municipal planning areas for 22 cities and towns in Maricopa County, all of the Fort McDowell, part of the Gila River, and all of the Salt River Pima-Maricopa Indian Communities, as well as unincorporated areas under the jurisdiction of Maricopa County (Figure 1). The Arizona Department of Environmental Quality (ADEQ) does not have the aut hority to require the implementation of controls in Indian Country, but the Tribes can implemen t their own controls.

The nonattainment area also contains a 36-s quare mile section of Pinal County, which encompasses a portion of the City of Apache Junction and includes unincorporated areas under the jurisdiction of Pinal County.Figure 1: Maricopa County PM10Nonattainment Area

## The area receives about 300 days of sunshine per year, while average annual rainfall is less than eight inches, with overall low hum idity. Phoeni x has two separate rainfall seasons. One season is represented by the winter months, November through March, when the Valley is subject to

storms from the Pacific Ocean. The other rainfall season, known as the “monsoon” season, occurs during summer and early fall (the Na tional Weather Service defines Arizona Monsoon dates as June 15 through September 30). This season is dominated by southeasterly winds carrying moisture from the Gulf of Mexico and thunderstorms, spawned by this moisture and

desert heat.

Two meteorological conditions have the potential to contribute to high concentrations of PM 10 

## : high winds and stagnation. Conditi ons for both of these events can occur in the nonattainment area, with high winds occurring predominantly in the spring and summer seasons, and stagnation occurring predominantly in the fall and winter seasons. High wind cond itions are either short term events (less than one hou r) generally a result of downdrafts from monsoon thunderstorms or strong pressure gradients associat ed with passage of a trough or cold front (usually 6-10 hours). Stagnation conditions are longer term events (six to 12 hours; occasionally multi-day events). During stagnation events, the air is very stable and has little vertical mixing. Temperature inversions (increasing air temp erature with height) also are common during stagnation events. An inversion traps pollutants cl ose to the ground, addi ng to any already existing concentrations of particulate matter.

1.2 The Maricopa County PM 10 

## Nonattainment Area History

In 1991, the Environmental Protection Agency (E PA) designated portions of Maricopa County and Pinal County as a moderate PM 10 

## nonattainment area under the Clean Air Act (CAA) Amendments of 1990. The Maricopa Associa tion of Governments (MAG) developed the moderate area plan, the MAG 1991 Particulate Plan for PM-10 , to ADEQ, which ADEQ adopted and submitted to EPA on November 15, 1991. In accordance with Section 188 of the CAA, the deadline for the State to demonstrate attainment of the PM 10 

## National Ambient Air Quality Standards (NAAQS) for this area was December 31, 1994; however, Arizona demonstrated to EPA that it was impracticab le for this area to attain the annual PM 10 

## NAAQS by the specified deadline. No demons tration was made for the 24-hour PM 10 

## NAAQS because at

that time an accurate assessment of the causes of the historical exceedances, which appeared to be highly localized, was not possible.

On March 4, 1992, EPA determined that the plan did not meet criteria for completeness, which began an 18-month sanctions clock and 24-mo nth clock to issue a moderate area PM 10 

## Federal Implementation Plan (FIP) [57 FR 19906; 5/8/92]. In August 1993, MAG adopted and transmitted to ADEQ the MAG 1991 Particulate Plan for PM- 10 for the Maricopa County Area

and 1993 Revisions . ADEQ adopted and submitted the plan to EPA. On September 7, 1993, EPA determined the plan to be complete.

In June 1994, the Arizona Center for Law in the P ublic Interest (ACLPI) sued to enforce the FIP obligation which became subject to enforcement action on March 4, 1994. EPA settled the case

## with an agreement to act on the moderate area PM 10 

## plan by March 1, 1995 ( Ober v. Browner

, No. CIV 94-1318 PHX, PGR, Consent Decree, March 6, 1995).

On April 10, 1995, EPA approved the Moderate Area Plan (60 FR 18010). In response to EPA’s approval, ACLPI filed suit ( Ober v. Browner ) on April 27, 1995, challenging EPA’s approval of Arizona’s 1991 moderate area partic ulate plan, due to, among other things, the plan’s failure to

address the 24-hour PM 10 

## NAAQS. The suit requested the Cour t require EPA to issue a FIP. Amidst the discussions and litiga tion concerning the approvability of the plan, EPA reclassified the Maricopa County PM 10 

## Nonattainment Area to serious effective June 10, 1996, based upon its finding that the area failed to attain the PM 10 

## NAAQS by the December 31, 1994, deadline (61 FR 21372). The action allowed Arizona 18 months to develop a new SIP providing for

attainment of the PM 10 

## NAAQS by December 31, 2001, the CAA attainment date for serious nonattainment areas (CAA § 188(c)(2)).

On May 14, 1996, the Court of Appeals for the Ni nth Circuit found that the Moderate Area Plan

failed to address the 24-hour PM 10 

## standard as required by the CAA [ Ober v. EPA , 84 F3d 304 (9th Cir. 1996)]. As a result, the Court mand ated that EPA require "the State to submit a separate demonstration of the implementation of all 'reasonably availa ble control measures’ targeting the 24-hour standard violations; attain ment and 'reasonable further progress' for the 24- hour standard." In September 1996, in response to the Court's mandate, EPA and ADEQ agreed that ADEQ would submit a "Limited" Serious Area PM 10 

## Plan to EPA by April 18, 1997 and a "Full" Serious Area Plan by December 10, 1997. The limited plan would address the 24-hour standard violations at specific monitors a nd must meet the requirements for adoption and expedited implementation of best available control measures (B ACM), all reasonably available control measures (RACM), and other measures as necessary to provide for reasonable further progress (RFP) along with expedi tious attainment at those m onitors. The full plan would represent the balance of the serious nonattainment area plan and the additional moderate area elements required by the Cour t. The full Plan titled, MAG Serious Area Committed Particulate Control Measures for PM10 and Support Technical Analysis, was submitted to EPA on December 11, 1997.

ADEQ developed the Phoenix PM 10 

## Microscale Field Study (Mic roscale Study) in 1994 to address the specific causes of and necessary controls for 24-hour exceedances, which was conducted throughout 1995 and became the basis of the limited Serious Area PM 10 

## Plan. The Microscale Study addressed exceedances of the 24-hour PM 10 

## NAAQS at four PM 10 

## monitoring locations: Salt River, Maryvale, Gilbert, and West Chandler. The 24-hour exceedances at the

Salt River site were due to fugitive dust from earth moving, industrial haul roads, unpaved parking lots, and unpaved roads. At the Maryvale site the exceedances were due to emissions

from disturbed cleared areas. Exceedances at the Gilbert site were due to emissions from agricultural field aprons and unpave d parking lots. At the Chandl er site, exceedances were due to emissions from agricultural fields, agricultura l field aprons, vacant lots , and disturbed cleared

areas. The SIP revision included a number of cont rols to address all sour ces of emissions with the exception of agriculture; as such attainment was modeled for Salt Rivers and Maryvale, but

not for Chandler and Gilbert.

9

## ADEQ developed and submitted to EPA the limited plan titled, Plan for Attainment of the 24-

hour PM 10



## Standard (24-Hour Plan), on May 7, 1997. The plan showed attainment by committing to implement reasonable available control measures (RACM) and best available control measures (BACM) for the significant sources of PM 10 

## . On August 4, 1997, EPA approved in part and disapproved in part the 24-hour Plan ( 62 FR 41856). EPA approved the

attainment demonstration at tw o monitoring locations (Salt Ri ver and Maryvale), and several county and city control measures addressing fugitive dust. EPA disapproved the RACM/BACM demonstrations for the monitoring locations at West Chandler and Gilbert for the sources categories of vacant lands, unpaved parking lots, unpaved roads, agricultural fields, and agricultural aprons.

On August 3, 1998, EPA issued a FIP (63 FR 41326) addressing the moderate area PM 10 

## requirements for the Phoenix PM 10 

## nonattainment area. For bot h the annual and 24-hour PM 10 

## standards, EPA included a demonstration that RACM would be implemented as soon as possible, a demonstration that it is impracticable for th e area to attain the standards by the statutory attainment deadline, and a demonstration that RFP is being met. As part of the FIP, EPA also promulgated a fugitive dust rule to control PM 10 

## emissions from vacant lots, unpaved parking lots and unpaved roads, and also promulgated an enforceable commitment to ensure that RACM for agricultural sources would be proposed by September 1999, finalized by April 2000 and implemented by June 2000. The FIP included a fi nal disapproval of the RACM and attainment

demonstration for the full Moderate Area PM 10 

## Plan.

To address PM 10 

## emissions from agricultural activities, the Governor’s Agricultural Best Management Practices Committee (Committee) wa s created in 1998 by Ariz ona Revised Statute ( A.R.S. ) §49-457; the statute was modeled after the FI P requirement for agricultural sources. The Committee was charged with developing an agricultural PM 10 

## general permit and to research and adopt best management practices (BMPs) for regul ated agricultural activities. On September 4, 1998, ADEQ submitted A.R.S. §49-457 to EPA for inclusion in the Arizona State Implementation Plan (SIP) for the Maricopa County PM 10 

## nonattainment area as meeting the RACM requirements and requested that EPA a pprove the legislation to replace the FIP commitment. EPA removed the portion of th e FIP for agriculture on June 29, 1999 (64 FR 34726). ADEQ developed and submitted to EPA a SIP revision for the Maricopa County PM 10 

## Serious Area, which included the general permit and the BMPs in July 2001. The Maricopa County PM 10 

## Serious Area State Implementation Plan R evision – Agricultural Best Management

Practices , was approved by EPA as a revision to the Arizona SIP October 11, 2001, effective November 13, 2001 (66 FR 51869). AC LPI filed suit in the U.S. C ourt of Appeals for the Ninth Circuit challenging, among other things, the us e of BMPs as BACM. On May 10, 2004, the Court upheld the approval of BMPs as BACM a nd remanded to EPA for further consideration the other issues brought by the suit, Vigil v. Leavitt , 366 F.3d 1025, amended at 381 F. 3d 826 (9th Cir. 2004).

MAG transmitted and submitted to ADEQ the Revised MAG 1999 Serious Area Particulate Plan for PM-10 for the Maricopa County Nonattainment Area , which ADEQ adopted and submitted to EPA on February 16, 2000. This plan cont ained approximately seventy-seven committed control measures from the State and local agenci es. The plan demonstrated attainment of the

PM 10 

## standard by December 31, 2006. On Janua ry 8, 2002, Arizona submitted revisions

10

## addressing roadways (paved and unpaved), park ing areas, vacant lots, and industrial source

emissions.

On July 25, 2002, EPA approved the full Serious Ar ea Particulate Matter (PM-10) Plan for the Maricopa County portion of the nonattainme nt area (67 FR 48717, effective August 25, 2002). The full plan is a compilation of submittals by ADEQ 1 

## , MAG 2 

## , and a number of rules. 3 

## EPA approved the BACM and most stringent measure (M SM) demonstrations in the plan and granted the State’s request for an attainment date exte nsion for the area. Due to continued exceedances

of the PM 10 

## standard, the Maricopa County PM 10 

## Nonattainment Area was unable to meet attainment of the federal standard by the December 31, 2006 Clean Air Act deadline. EPA issued a notice regarding the fa ilure of the Maricopa County PM 10 

## Nonattainment Area to attain

the PM 10 

## NAAQS on May 25, 2007 (72 FR 31183).

1.3 Maricopa Association of Governme nts (MAG) 2007 Five Percent Plan for PM 10 

## for the Maricopa County Nonattainment Area

As a result of the failure to attain the standard , MAG began developing a Five Percent Plan for Maricopa County as required under the Clean Ai r Act Section 189(d). The Five Percent Plan requires the reduction of PM 10 

## emissions by at least five percen t per year until the standard is attained, and no violations occur at previously violating PM 10 

## monitors. To develop the plan, MAG conducted a study to de termine the sources of PM 10 

## emissions contributing to violations of

the PM 10 

## standard at monitors in the nonattainme nt area during stagna nt conditions and to characterize the deposition of PM 10 

## particles emitted by these sources. The study identified a

number of sources of PM 10 

## emissions including: trackout, dragout from unpaved or poorly maintained paved roads or parking lots, unpaved shoulders, unpaved roads, open burning, agriculture, and vehicle activity on unpaved parking areas and vacant lots. Preliminary results from the study were used to evaluate control measures and the final results were used in the modeling demonstration.

The Maricopa County Air Quality De partment conducted a periodic PM 10 

## emission inventory for the Maricopa County Nonattainment Area in 2 005. The inventory showed that agriculture

1 

### Plan for Attainment of the 24-hour PM–10 Standard—Maricopa County PM–10 Nonattainment Area, Arizona Department of Environmental Quality (ADEQ), May, 1997, submitted May 9, 1997, approved in part and disapproved in part on August 3, 1997 (62 FR 41856). Maricopa County PM–10 Serious Area State Implementation Plan Revision, Agricultural Best Management Practices (BMP), ADEQ, June 2000, submitted on June 13, 2001.

2 

### Serious Area Committed Particulate Control Measures for PM–10 for the Maricopa County Nonattainment Area and Support Technical Analysis , MAG, December 1997, subm itted December 11, 1997. Revised Maricopa Association of Governments 1999 Serious Area Particulate Plan for PM–10 for the Maricopa County

Nonattainment Area , February 2000, submitted February 16, 2000. On January 8, 2002, Arizona submitted revisions to the Maricopa County’s commitments to improve its fugitive dust rule which were in this plan.

3 

### These include the revised Maricopa County Environmen tal Services Department (MCESD) Rule 310, Fugitive Dust Sources (adopted February 16, 2000) and Rule 310. 01, Fugitive Dust from Open Areas, Vacant Lots, Unpaved Parking Lots, and Unpaved Roadways (adopted February 16, 2000), both submitted on March 2, 2000; the revised Maricopa County Residential Woodburning Restrictions Ordinance (adopted November 17, 1999) submitted on January 28, 2000; and the Agricultural BMP General Permit Rule submitted on July 11, 2000, approved October 11 2001 (66 FR 51869).



### 11

## contributes approximately thr ee percent to total annual PM 10 

## emissions in the nonattainment area (Figure 2). This regional and annual emission pr ofile does not provide any context for localized emissions that can contribute to 24-hour average PM 10 

## NAAQS exceedances. Agricultural dust represents a greater proportion of the PM 10 

## emissions that contributed to 24-hour average

exceedances at two sites in the nonattainment area.

Figure 2: Annual 2005 PM 10 

## Emissions in the PM 10 

## Nonattainment Area

stationary source point sources

industrial processes 2% fuel combustion & fires 4% 10% agriculture 7%
construction (residential)

3% construction (commercial)

construction (road) 16% other land clearing

14 % travel on unpaved parking lots

offroad recreational vehicles

Source: 2005 Periodic Emission Inventory for the Maricopa County, Arizona Nonattainment Area. Maricopa County Air Quality Department, May 2007.



## In order to reduce PM 10 

## emissions for the contribution fr om agriculture, the Committee added BMPs to those already contained in the 2001 Agricultura l Best Management Pr actices SIP. The Committee also adopted an additional requirement for two BMPs per agricultural category (for details regarding the new BMPs and additional requirements see Ch apter 2.0). Concurrently, the Arizona State Legislature passed Senate Bill (SB) 1552 (Laws 2007) to address the failure to

attain the PM 10 

## standard and other air quality issues. SB 1552 contained ch anges and additions

to A.R.S. §49-457 – Agricultural Best Management Prac tices Committee, Members, Powers, Permits, Definitions . The Committee then revised Arizona Administrative Code ( A.A.C. ) R18-2-

610 – Definitions for R18-2-611 ; and R18-2-611 – Agricultural PM 10 

## General Permit, Maricopa

PM 10 

## Nonattainment Area and Maricopa County Portion of Area A (for rule revision details see Section 2.2). 13 %

9% 3% 5% 3% 7% 1% 2% 2% leaf blowers fugitive dust

windblown vacant

windblown othe r

nonroad equipment

exhaust/tire wear/brake wear 1% paved roads (including trackout)

unpaved roads



### 12

## 1.4 Agricultural Best Manageme nt Practices SIP Revision

This document contains revisions to the Maricopa County PM 10 

## Serious Area State Implementation Plan – Agricultur al Best Management Practices , originally submitted in 2001.

These revisions include:

 

## Senate Bill 1552 requirement,

 

## New BMPs selected by the Committee,

 

## Description of BMP outreach, and

 

## Revisions to the BMP guidance booklet.

13

## CHAPTER 2.0 AGRICULTURAL BEST MA NAGEMENT PRACTICES SELECTION

PROCESS

2.1 Actions of the Governor’s Agricultural Best Management Practices Committee

The Committee met in 2006 as a proactive step to research alternatives to further reduce PM 10 

## emissions from agricultural activities. The Committee reconvened the Agricultural BMP Technical Workgroup to review and analyze similar agricultu ral management programs in California, the existing program in Maricopa County, and management practices proposed by the Maricopa Association of Governments (MAG).

The Workgroup invited representatives from San Joaquin Valley and Imperial Valley, California to present and discuss the Conservation Mana gement Practices (CMP) Programs in their respective counties. Representatives from MAG were also invited to several Committee meetings to present and discuss alternative pr actices for use as BMPs. MAG’s suggestions included calculating the emissions impacts from the elimination of plow-downs after the pink boll worm is eradicated, staggering plow-downs, cessation of tilling on high wind days, calculating the emissions impacts from the reduc tion of agricultural land once it converts to development, and the implementation of BMPs to Area A, a planning area larger than the

nonattainment area.

The Workgroup forwarded six new BMPs to the Committee for evaluation. These BMPs included: integrated pest management (IPM), precision farming, green c hop, transgenic crops, transplanting, and minimized vehicl e use to ten vehicle trips per day. In addition to reviewing these practices for feasibility, the Committee re quested that ADEQ staff conduct a comparison analysis of BMPs to determine potential emissi on reductions. The Committ ee also requested that the Workgroup review additional analysis from ADEQ regarding PM 10 

## emissions during stagnant air conditions prior to further discussion or ac tion on BMPs related to cessation of tilling (for more information on both the compar ison analysis and analysis of PM 10 

## emissions see Appendix B).

After reviewing the comparison analysis of the estimated emissions reductions for the six additional BMPs, the Committee selected practices th at were feasible and applicable for farmers in Maricopa County. Four BMPs were initially adopted: IPM, precision farming, green chop, and transgenic crops (for descriptions of the BMPs adopted by the Committee see Chapter 3.0).

The analysis of the PM 10 

## data showed that on stagnant air days, PM 10 

## concentrations start to rise after sundown, are relatively constant until ab out 4:00 a.m., and reach a maximum peak around 8:00 a.m. ADEQ staff proposed several options fo r a time frame to cease or reduce tilling: reduce tilling on weekdays (tilli ng would occur on weekends), li mit tilling on any day between 6:00 p.m. and 9:00 a.m., or limit tilling on any day between 6:00 p.m. and 7:00 a.m. In order to maintain economic feasibility of the BMP and contribute to reductions of PM 10 

## concentrations, the Committee agreed that establishing a time frame of 2:00 a.m. to 8:00 a.m. for the cessation of night tilling operations on stagnant air days was appropriate. Th e Committee adopted the cessation of night tilling from 2:00 a.m. to 8:00 a.m. during stagnant air conditions on high pollution advisory (HPA) days as a fifth additional BMP.

14

### 15 

## 2.2 Senate Bill 1552 and Committee Actions

While the T echnical Workgroup was conducting its review and analysis of BMPs, the Arizona Legislature revised Ariz ona Revised Statutes ( A.R.S .) §49-457 in Sectio n 14 of SB 1552. The Committee discussed extending the a pplication of BMPs to the Ma ricopa County portion of Area A, as originally suggested by MAG (See Figure 2) and further discussed the consideration of requiring two BMPs per category versus one BM P per category as or iginally required. Requiring two BMPs per category (t he three categories being tillage and harvest, non-cropland, and cropland) actually served to increase flex ibility. Expanding the us e of BMPs into the Maricopa County Portion of Area A captured mon itors with data showing exceedances possibly due in part to agricultural activities located on the edges of the nonattainme nt area but within the Maricopa County portion of Area A.

As signed by the Governor, SB 1552 amended th e statute to require two BMPs to be implemented per agricultural management category beginning December 31, 2007, and revised the definition of the regulated area for BMPs to include the Maricopa County portion of Area A (as defined in A.R.S §49-541). These changes, in addition to the newl y adopted BMPs, required

revisions to R18-2-610 – Definitions for R18-2-611 ; and R18-2-611 – Agricultural PM 10 

## General Permit, Maricopa PM 10 

## Nonattainment Area and Maricopa County Portion of Area A . The rule was developed as an exempt rule 4 

## to facilitate inclusion in the MAG 2007 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area , submitted by ADEQ to EPA on December 21, 2007. The now codified version of R18-2- 610 and 611 as it appears in the A.A.C. is submitted in this SIP Revision and can be found in Appendix A.

4 

### An exempt rulemaking in Arizona is not submitted to the Governor’s Regulatory Review Council but rather submitted directly to the Secretary of State for inclusion in the Code through legislative enactment. Public comments on the exempt rule were made available as pa rt of the public process for the Five Percent Plan.Figure 3: Map of PM10Nonattainment Area and Area A

## (This page intentionally left blank.)

## CHAPTER 3.0 ADDITIONAL AGRICULT URAL BEST M ANAGEMENT PRACTICES

This chapter contains descripti ons and percent emission reduction of the five BMPs that were selected by the Governor’s Agricultural Best Management Practices Committee.

3.1 Best Management Practices

3.1.1 Cessation of Night Tillage on High Pollution Advisory Days

Cessation of night tilling during high pollution a dvisory days is the stopping of agricultural tillings during the early morning hours to limit the concentration of PM 10 

## emissions while still allowing for other farming activities to occur. Notification of high pollution advisory days for

PM 10 

## [http://www.azdeq.gov/ensemble.pdf] is assisted by test messaging services provided by ADEQ [http://www.azdeq.gov/sms.html].

The Committee selected this BMP based on its pr acticality, feasibility, and efficiency regarding agricultural activit ies in Maricopa County. Based on an analysis conducted by ADEQ, the emission reduction is two percent for the Cessati on of Night Tillage on High Pollution Advisory Days BMP.

3.1.2 Green Chop

Green chopping is a harvesting practice commonly us ed with forage crops. The crop is cut and simultaneously harvested, without allowing it to dry in the field, thus reducing multiple equipment passes. Fewer equipment passes redu ce disturbance of the soil thus reducing the

amount of PM 10 

## emitted.

The Committee selected this BMP based on its pr acticality, feasibility, and efficiency regarding agricultural activ ities in Maricopa County. Based on a comparison analysis of BMPs conducted by ADEQ, the emission reduction is between 10 and 20 percent for the Green Chop BMP.

3.1.3 Integrated Pest Management

Integrated pest management (IP M) is an agricultural-management practice that uses a combination of techniques including organic, co nventional and biological farming practices to suppress pests. Implementation of IPM comm only uses a four-tiered approach: set action thresholds for an identified pest, monitor a nd identify pests, prevent pests from becoming a threat, and control the pest. The fourth step may require evaluation of the previous steps to determine if the implementation process is working or if additional control methods are required. Implementation of IPM results in fewer pests and thus reduces the need and/or number of passes for spraying pesticides and also th e need for additional tillage.

18

## The Committee selected this BMP based on its pr acticality, feasibility, and efficiency regarding agricultural activ ities in Maricopa County. Based on a comparison analysis of BMPs conducted by ADEQ, the emission reduction is between 12 and 19 percent for the IPM BMP.

3.1.4 Precision Farming

Precision farming is an agricultural practice that uses global position sy stems (GPS), sensors, satellite or aerial images, remote sensing, and geographical information systems (GIS). The use of this technology allows farmers to account for variable field conditions such as soil type, landscape characteristics, types of pests, and cr op information. This information is used to precisely evaluate optimum sowing density, estimate fertilizer a pplications, and calculate the position of agricultural equipment in the field. A primary objective for using this practice is to determine the exact location of agricultural equipmen t as it operates in a field so that a farmer can treat specific areas and redu ce overlap. Reduced overlap resu lts in fewer equipment passes

and reduces the amount of PM 10 

## emitted from disturbing the soil. This practice also allows a farmer to operate during inclement weather a nd at night since the farmer can accurately

determine their exact location in the field.

The Committee selected this BMP based on its pr acticality, feasibility, and efficiency regarding agricultural activ ities in Maricopa County. Based on a comparison analysis of BMPs conducted by ADEQ, the emission reduction is 15 percen t for the Precision Farming BMP.

3.1.5 Transgenic Crops

Transgenic crops are genetically modified orga nisms (GMOs), which are genetically engineered crops. This form of engineeri ng alters the genetic material of the organism by inserting or transferring genes from other specie s to cause the expression of modified traits. There are many reasons for using transgenic crops such as pest resistance or increased yield. In Arizona, one example of the use of a transgen ic crop is BT cotton. BT cott on is genetically modified to produce a toxin that kills caterpilla rs, particularly the pink bollw orm. The use of transgenic crops can reduce the need for ti llage, fertilizing, pesticide appl ication, or other cultivation activities and, thus, reduces soil disturbance and PM 10 

## emissions.

The Committee selected this BMP based on its pr acticality, feasibility, and efficiency regarding agricultural activ ities in Maricopa County. Based on a comparison analysis of BMPs conducted by ADEQ, the emission reduction is between two and 12 percent for the Transgenic Crops BMP.

3.2 Emissions Reductions from Re visions to the BMP Program

This section discusses the emissions reductions re sulting from the revision to the BMP Program. These are the reductions that may result fr om the additional BMPs, using two BMPs per agricultural category, and the ex pansion of the area of appl ication of the BMP Program.

Additional information on the emission reductions resulting from “Cessation of Night Tilling”

19

## BMP as a second BMP in the Tilling & Harvest category and extending the Agricultural BMP

program to the Maricopa County Portion of Area A outside of the Maricopa County PM 10 

## Nonattainment Area is also discussed.

3.2.1 Number of BMPs Required per Agricultural Category

The original BMP Program required growers to choose one BMP per agricultural land/use category: Tillage and Harv est, Non-Cropland, and Cropland. The revisions to A.R.S §49-541,

and A.A.C. R18-2-610 and 611 increased the number of BMPs required per category from one to two BMPs. With the revised program, growers are required to select one additional BMP for each of the BMP categories (total of six BMPs ). Using a second BMP per category provides greater emissions reductions th an the use of a single BMP.

3.2.2 Cessation of Night Tilling

As outlined in Section 3.1.1, “Cessation of Night Tilling” in the Tillage and Harvest category, has a relatively low annual emissions reduc tion of only two percent; however, its actual

reduction of ambient PM 10 

## concentrations is much highe r. This is because the PM 10 

## emissions from night tilling occur during the most critical time of a stagnation period, 2:00 a.m. and 8:00 a.m., when lack of vertical and horizontal mixing can allow PM 10 

## concentrations to steadily

increase.

The estimated 15 tons per year of PM 10 

## emission reductions from th is BMP was projected to occur on the nine stagnation days (annual average) that coincide on days when agricultural tilling is done in Maricopa County. Thus, the two perc ent annual total emissions reduction value can be misleading since the actual emission reductions co ver only nine days as opposed to 365 days.

The “Cessation of Night Tilling” BMP does not repl ace one of the original BMPs that is required for the Tillage & Harvest category. This BMP is in addition to the first BMP that is required for the Tillage & Harvest category. Thus, if this BMP is selected by a grower, it strengthens the Maricopa County PM 10 

## Serious Area SIP, since it provides PM 10 

## emission reductions in addition

to the first BMP’s emission reductions.

3.2.3 Extension of the Agricultural BMP Program to the Maricopa County Portion of Area A

As a result of extending the area of appli cation of the BMP Program outside of the PM 10 

## nonattainment area, it was estimated that an additional 26,004 acres of agricultural land would become subject to the Agricultur al BMP Program. This is an almost 30 percent increase in agricultural land subject to the BMP Program. The projected emissions reductions from the extension take into account appl ication of two "additional" Agricu ltural BMPs, instead of just one additional Agricultural BMP.

20

## 3.3 Conclusion

The revisio ns to the BMP Program include: fi ve additional BMPs, two BMPs required per agricultural category, and extension of the area of application of the BMP Program. All of the practices in the BMP Program are recognized as BACM and MSM and provide a reduction in

PM 10 

## emissions from agricultural activities. These revisions to the overall AgBMP Program are cumulative, and the overall impact lead s to strengthening the AgBMP SIP.

21

## CHAPTER 4.0 OUTREACH

4.1 Public Outreach Activities

After finalizing revisions to R18-2-610 – Definitions for R18-2-611; and R18-2-611 – Agricultural PM 10 

## General Permit, Maricopa PM 10 

## Nonattainment Area and Maricopa County Portion of Area A, the Committ ee discussed revisions to the Guide to Agricultural PM 10 

## Best Management Practices as well as outreach strategies to inform the agricultural community of the changes to the BMP Program. The Committee appr oved revisions to the Guide to include the five new BMPs, changes to the number of BMPs required for each category and the expansion of the application area for BMPs. The Committee also approved a pocket guide to be distributed along with the booklet; the pocket gui de replaced the previous pam phlet version of the larger

Guide. The Pocket Guide to Agricultural PM10 Best Management Practices provides a brief

overview of the BMPs that can be utilized in each agricultural category, and contains contact information for additional information regarding the BMP Program.

Once the publications were av ailable, outreach meetings we re coordinated by the Arizona Department of Agriculture (ADA) and the Arizona Farm Bureau. Two separate meetings were held during May 2008 (Estrella Mountain Community College a nd the Arizona Farm Bureau Office located in Gilbert). Continued outreach is maintained by the Agricultural Consultation and Testing (ACT) Program at the ADA. Repres entatives from the ADA also conduct on-site visits to the agricultural community in orde r to provide compliance assistance and training regarding implementation of th e BMP program. The ADA maintains a Web site for the ACT Program, http://www.azda.gov/ACT/act.htm, to provide information to the public regarding their services. ADEQ also participates in outreach for the BMP Program. If complaints are reported, a representative from ADEQ will meet with the farmer, review their chosen BMPs, and discuss options to reduce PM 10 

## emissions from the agricultural activities.

22

## (This page intentionally left blank.)

23

### 24 

## CHAPTER 5.0 CONCLUSION

The purpose of the Agricultural BMP Program is to provide farmers with alternative practices that will help reduce PM 10 

## emissions and lower concentrations of PM 10 

## in the Maricopa County Nonattainment Area. The original Program implemented in 2001 allowed farmers to pick BMPs that were both economically feasible and prac ticable. The additional BMPs will give farmers more Program flexibility and extend the BMP application area to include more farmland in the BMP Program and capture farmland on the periphery of the PM 10 

## nonattainment area boundary.

The revisions to the Agricultural BMP Program st rengthen the existing Agricultural BMP SIP. Therefore, with this submittal, ADEQ requests th at EPA approve this SIP Revision to the 2001 Agricultural Best Management Practices, Maricopa County PM 10 

## Serious Area State Implementation Plan.

# APPENDIX A

Agricultural Best Management Practices RuleSupp. 08-3 Page 68 September 30, 2008

Title 18, Ch. 2 Arizona Administrative Code

Department of Environmental Quality – Air Pollution Control

excessive amounts of particulate matter from becomi ng airborne. Reasonable precautions shall mean wetting, chemical stabilization, revegetation or such other measures as are approved by the Director.

Historical ote Section R18-2-608 renumbered from R18-2-408, new Section R18-2-408 adopted effective November 15, 19 93

(Supp. 93-4).

R18-2-609. Agricultural Practices A person shall not cause, suffer, allow, or permit the performance of agricultural practices outside the Phoenix and Yuma planning areas, as defined in 40 CFR 81.303, which is incorporated by reference in R18-2-210, including tilling of land and applicatio n of fertilizers without taking reasonable precautions to prevent ex cessive amounts of particulate matter from becoming airborne.

Historical ote
Section R18-2-609 renumbered from R18-2-409 effecti ve November 15, 1993 (Supp. 93-4). Amended by final ru lemaking at 6 A.A.R. 2009, effective May 12, 2000 (Su pp. 00-2). Amended by final rulemaking at 11 A.A.R. 221 0, effective July 18, 2005 (Supp. 05-2).

R18-2-610. Definitions for R18-2-611 The definitions in Article 1 of this Chapter and th e following definitions apply to R18-2-611: 1. “Access restriction” means restricting or elimina ting public access to noncropland with signs or physical ob struction.

2. “Aggregate cover” means gravel, concrete, recycle d road base, caliche, or other similar material applied to noncropland.

3. “Area A” means the area delineated according to A .R.S. § 49-541(1).

4. “Artificial wind barrier” means a physical barrie r to the

wind.

5. “Best management practice” means a technique veri fied by scientific research, that on a case-by-case basi s is practical, economically feasible, and effective in reducing

PM 10 emissions from a regulated agricultural activity.

6. “Chemical irrigation” means applying a fertilizer , pesticide, or other agricultural chemical to cropland th rough an irrigation system.

7. “Cessation of Night Tilling” means the discontinu ation of night tilling on high pollution advisory days durin g stagnant air conditions.

8. “Combining tractor operations” means performing t wo or more tillage, cultivation, planting, or harvesting operations with a single tractor or harvester pass.

9. “Commercial farm” means 10 or more contiguous acr es of land used for agricultural purposes within the b oundary of the Maricopa PM 10 nonattainment area and Maricopa County portion of Area A.

10. “Commercial farmer” means an individual, entity, or joint operation in general control of a commercial farm.

11. “Committee” means the Governor’s Agricultural Be st Management Practices Committee.

12. “Cover crop” means plants or a green manure crop grown for seasonal soil protection or soil improvement.

13. “Critical area planting” means using trees, shru bs, vines, grasses, or other vegetative cover on noncropland.

14. “Cropland” means land on a commercial farm that: a. Is within the time-frame of final harvest to plan t

emergence; b. Has been tilled in a prior year and is suitable f or crop production, but is currently fallow; or

c. Is a turn-row. 15. “Cross-wind ridges” means soil ridges formed by a tillage operation.

16. “Cross-wind strip-cropping” means planting strip s of alternating crops within the same field.

17. “Cross-wind vegetative strips” means herbaceous cover established in one or more strips within the same f ield.

18. “Equipment modification” means modifying agricul tural equipment to prevent or reduce particulate matter g eneration from cropland.

19. “Forage Crop” means a product grown for consumpt ion by any domestic animal.

20. “Genetically Modified” means a living organism w hose genetic material has been altered, changing one or more of its characteristics.

21. “GMO: Genetically Modified Organism” means a pla nt that has been altered by a genetic exchange with an other organism.

22. “GPS: Global Position Satellite System” means us ing a satellite navigation system on farm equipment to ca lculate position in the field.

23. “Green Chop” means the harvesting of a forage cr op without allowing it to dry in the field.

24. “High Pollution Advisory” means a public notific ation issued by the Department when the ambient concentra

tions of PM 10 may exceed the federal health standard.

25. “Integrated Pest Management” means the use of a combination of techniques including organic, conventiona l, and biological farming practices.

26. “Limited activity during a high-wind event” mean s performing no tillage or soil preparation activity whe n the measured wind speed at 6 feet in height is more tha n 25 mph at the commercial farm site.

27. “Manure application” means applying animal waste or biosolids to a soil surface.

28. “Maricopa PM 10 nonattainment area” means the Phoenix planning area as defined in 40 CFR 81.303, which is incorporated by reference in R18-2-210.

29. “Mulching” means applying plant residue or othermaterial that is not produced onsite to a soil surface.

30. “Multi-year crop” means a crop, pasture, or orch ard that is grown, or will be grown, on a continuous basis f or more than one year.

31. “Noncropland” means any commercial farm land tha t:
a. Is no longer used for agricultural production;

b. Is no longer suitable for production of crops;

c. Is subject to a restrictive easement or contract that prohibits use for the production of crops; or

d. Includes a private farm road, ditch, ditch bank, equipment yard, storage yard, or well head.

32. “Night Tilling” means preparing the land for the raising of crops between the hours of 2:00 a.m. and 8:00 a. m. 33. “Organic Farming Practices” means using biologic al or non-chemical agricultural methods.Arizona Administrative Code Title 18, Ch. 2

Department of Environmental Quality – Air Pollution Control

September 30, 2008 Page 69 Supp. 08-3 34. “Permanent cover” means a perennial vegetative c over on cropland.

35. “Planting based on soil moisture” means applying water to soil before performing planting operations.

36. “Precision Farming” means using GPS to precisely guide farm equipment in the field.

37. “Reduce vehicle speed” means operating farm vehi cles or farm equipment on unpaved private farm roads at spe eds not to exceed 20 mph.

38. “Reduced harvest activity” means reducing the nu mber of harvest passes using a mechanized method to cut and remove crops from a field.

39. “Reduced tillage system” means reducing the numb er of tillage operations used to produce a crop.

40. “Regulated agricultural activity” means a commer cial farming practice that may produce PM 10 within the Maricopa PM 10 nonattainment area and Maricopa County portion of Area A.

41. “Residue management” means managing the amount a nd distribution of crop and other plant residues on a soil surface.

42. “Sequential cropping” means growing crops in a sequence that minimizes the amount of time bare soi l is exposed on a field.

43. “Surface roughening” means manipulating a soil s urface to produce or maintain clods.

44. “Stagnant Air Conditions” means a meteorological regime where warm air aloft overlies cooler air nea r the surface and little if any vertical mixing occurs.

45. “Synthetic particulate suppressant” means a manu factured product such as lignosulfate, calcium chlorid e, magnesium chloride, an emulsion of a petroleum prod uct, an enzyme product, and polyacrylamide that is used to control particulate matter.

46. “Tillage and harvest” means any mechanical pract ice that physically disturbs cropland or crops on a commerci al

farm.

47. “Tillage based on soil moisture” means applying water to soil before or during tillage, or delaying tillage to coincide with precipitation.

48. “Timing of a tillage operation” means performing tillage operations at a time that will minimize the soil’s susceptibility to generate PM 10

. 49. “Track-out control system” means a device to rem ove mud or soil from a vehicle before the vehicle enter s a paved public road.

50. “Transgenic Crops” means the use of plants that are genetically modified.

51. “Tree, shrub, or windbreak planting” means provi ding a woody vegetative barrier to the wind.

52. “Watering” means applying water to noncropland.

Historical ote Former Section R18-2-610 renumbered to R18-2-612; new Section R18-2-610 adopted by final rulemaking a t 6 A.A.R. 2009, effective May 12, 2000 (Supp. 00-2). Amended by exempt rulemaking at 13 A.A.R. 4326, effective November 14, 2007 (Supp. 07-4). R18-2-611. Agricultural PM 10 General Permit; Maricopa

PM 10 onattainment Area and Maricopa County Portion of

Area A

A. A commercial farmer shall comply with this Section by December 31, 2007.

B. A commercial farmer, who begins a regulated agricul tural activity after December 31, 2000, shall comply with this Section within 18 months of beginning the regulated ag ricultural activity.

C. A commercial farmer shall implement at least two be st management practices from each of the following catego ries: 1. Tillage and harvest, subsection (E); 2. Noncropland, subsection (F); and 3. Cropland, subsection (G). A commercial farmer may implement more than one best management practice fo r one or more of the categories.

D. A commercial farmer shall ensure that the implement ation of all selected best management practices does not vio late any other local, state, or federal law.

E. A commercial farmer shall implement at least two ofthe following best management practices to reduce PM 10 emissions during tillage and harvest activities: 1. Chemical irrigation, 2. Combining tractor operations, 3. Equipment modification, 4. Green Chop, 5. Integrated Pest Management, 6. Limited activity during a high-wind event, 7. Multi-year crop, 8. Cessation of Night Tilling, 9. Planting based on soil moisture, 10. Precision Farming, 11. Reduced harvest activity, 12. Reduced tillage system, 13. Tillage based on soil moisture, 14. Timing of a tillage operation, or 15. Transgenic Crops.

F. A commercial farmer shall implement at least two ofthe following best management practices to reduce PM 10 emissions from noncropland: 1. Access restriction; 2. Aggregate cover; 3. Artificial wind barrier; 4. Critical area planting; 5. Manure application; 6. Reduce vehicle speed; 7. Synthetic particulate suppressant; 8. Track-out control system; 9. Tree, shrub, or windbreak planting; or 10. Watering.

G. A commercial farmer shall implement at least two ofthe following best management practices to reduce PM 10 emissions from cropland: 1. Artificial wind barrier; 2. Cover crop; 3. Cross-wind ridges; 4. Cross-wind strip-cropping; 5. Cross-wind vegetative strips; 6. Integrated Pest Management; 7. Manure application; 8. Mulching; 9. Multi-year crop; 10. Permanent cover; 11. Planting based on soil moisture; 12. Precision Farming; 13. Residue management;Supp. 08-3 Page 70 September 30, 2008

Title 18, Ch. 2 Arizona Administrative Code

Department of Environmental Quality – Air Pollution Control

14. Sequential cropping; 15. Surface roughening; or 16. Tree, shrub, or windbreak planting.

H. A person may develop different practices not contai ned in subsections (E), (F), or (G) that reduce PM 10 . A person may submit practices that are proven effective through on- farm

demonstration trials to the Committee. The Committe e may meet to review the submitted practices.

I. A commercial farmer shall maintain a record demonst rating compliance with this Section. The record shall be p rovided to the Director within two business days of notice to the commercial farmer. The record shall contain: 1. The name of the commercial farmer, 2. The mailing address or physical address of the co mmercial farm, and 3. The best management practices selected for tillag e and harvest, noncropland, and cropland.

J. The Director shall not assess a fee to a commercial farmer for coverage under the agricultural PM 10 general permit.

K. The Director shall document noncompliance with this Section before issuing a compliance order.

L. A commercial farmer who is not in compliance with t his Section is subject to the provisions in A.R.S. § 49-45 7 (I), (J), and (K).

Historical ote New Section adopted by final rulemaking at 6 A.A.R. 2009, effective May 12, 2000 (Supp. 00-2). Amended by exempt rulemaking at 13 A.A.R. 4326, effective Nove mber 14, 2007 (Supp. 07-4).

R18-2-612. Definitions for R18-2-613 1. “Access restriction” means restricting or elimina ting public access to noncropland with signs or physical ob struction. 2. “Aggregate cover” means gravel, concrete, recycle d road base, caliche, or other similar material applied to noncropland. 3. “Artificial wind barrier” means a physical barrie r to the

wind. 4. “Bed row spacing” means increasing or decreasing the size of a planting bed area to reduce the number of passes and soil disturbance by increasing plant density. 5. “Best management practice” means a technique veri fied by scientific research, that on a case-by-case basi s is practical, economically feasible, and effective in reducing

PM 10 emissions from a regulated agricultural activity. 6. “Chemical irrigation” means applying a fertilizer , pesticide, or other agricultural chemical to cropland th rough an irrigation system. 7. “Combining tractor operations” means performing t wo or more tillage, cultivation, planting, or harvesting operations with a single tractor or harvester pass. 8. “Commercial farm” means 10 or more contiguous acr es of land used for agricultural purposes within the b oundary of the Yuma PM 10 nonattainment area. 9. “Commercial farmer” means an individual, entity, or joint operation in general control of a commercial farm. 10. “Conservation irrigation” means the use of drips , sprinklers, or underground lines to conserve water, and to reduce the weed population, the need for tillage, a nd soil compaction. 11. “Conservation tillage” means types of tillage th at reduce the number of passes and the amount of soil disturb ance. 12. “Cover crop” means plants or a green manure crop grown for seasonal soil protection or soil improvement. 13. “Critical area planting” means using trees, shru bs, vines, grasses, or other vegetative cover on noncropland. 14. “Cropland” means land on a commercial farm that: a. Is within the time-frame of final harvest to plan t

emergence; b. Has been tilled in a prior year and is suitable f or crop production, but is currently fallow; or

c. Is a turn-row. 15. “Cross-wind ridges” means soil ridges formed by a tillage operation. 16. “Cross-wind strip-cropping” means planting strip s of alternating crops within the same field. 17. “Cross-wind vegetative strips” means herbaceous cover established in one or more strips within the same f ield. 18. “Equipment modification” means modifying agricul tural equipment to prevent or reduce particulate matter g eneration from cropland. 19. “Limited activity during a high-wind event” mean s performing no tillage or soil preparation activity whe n the measured wind speed at six feet in height is more t han 25 mph at the commercial farm site. 20. “Manure application” means applying animal waste or biosolids to a soil surface. 21. “Mulching” means applying plant residue or othermaterial that is not produced onsite to a soil surface. 22. “Multi-year crop” means a crop, pasture, or orch ard that is grown, or will be grown, on a continuous basis f or more than one year. 23. “Night farming” means performing regulated agric ultural activities at night when moisture levels are higher and winds are lighter. 24. “Noncropland” means any commercial farmland that : a. Is no longer used for agricultural production; b. Is no longer suitable for production of crops; c. Is subject to a restrictive easement or contract that prohibits use for the production of crops; or d. Includes a private farm road, ditch, ditch bank, equipment yard, storage yard, or well head. 25. “Permanent cover” means a perennial vegetative c over on cropland. 26. “Planting based on soil moisture” means applying water to soil before performing planting operations. 27. “Precision farming” means use of satellite navig ation to calculate position in the field, to reduce overlap during field operations, and allow operations to occur dur ing nighttime and inclement weather, thus generating le ss PM 10

. 28. “Reduce vehicle speed” means operating farm vehi cles or farm equipment on unpaved farm roads at speeds not to exceed 20 mph. 29. “Reduced harvest activity” means reducing the nu mber of harvest passes using a mechanized method to cut and remove crops from a field. 30. “Regulated agricultural activity” means a commer cial farming practice that may produce PM 10 within the Yuma

PM 10 nonattainment area. 31. “Residue management” means managing the amount a nd distribution of crop and other plant residues on a soil surface. 32. “Sequential cropping” means growing crops in a sequence that minimizes the amount of time bare soi l is exposed on a field. 33. “Surface roughening” means manipulating a soil s urface to produce or maintain clods. 34. “Synthetic particulate suppressant” means a manu factured product such as lignosulfate, calcium chlorid e,

# APPENDIX B

Technical Support Document

## i 

# AGRICULTURAL BEST MANAGEMENT PRACTICES

TECHNICAL SUPPORT DOCUMENT

Arizona Department of Environmental Quality

January 11, 2010

## ii TABLE OF CONTENTS

1.1 INTRODUCTION...............................................................................................................

.............................. 1

1.2 COMPARISON OF MARICOPA C OUNTY BMPs AND S AN JOAQUIN CMPs.......................................... 1

1.2.1 Methodology..............................................................................................................

................................ 1

1. Estimation of Crop Acres in Maricopa County PM 10 

### Nonattainment Area ........................................... 1

2. Calculation of Uncontrolled PM 10 

### Emissions in Maricopa County PM 10 

### Nonattainment Area............. 2

3. Calculation of PM 10 

### Emissions Reduction by Crop and Control Measure 

## ........................................ 3

1.2.2 Summary of Emissions Reductions ........................................................................................................... 4

1.3 AGRICULTURAL BMPS IN SENATE BILL 1552 ......................................................................................

. 10

1.3.1 Effect of One Additional Agricultural BMP in Maricopa County PM-10 Nonattainment Area.............. 10

1. Percent Emission Reduction by Agricultural BMP Category.............................................................. 10 2. Projected Crop Acreage in Maricopa County ...................................................................................

... 12 3. Rate of Change Factors......................................................................................................

.................. 13 4. Projected Agricultural Emissions in Maricopa County PM 10 

### Nonattainment Area............................. 14 5. Projected Emission Reductions in Maricopa County PM 10 

### Nonattainment Area................................ 14

1.3.2 Extending Agricultural BMP Program to Maricopa County Portion of Area A ......................................16

1. Percent Agricultural Land In Maricopa County ................................................................................

.. 16

2 Land in MC Portion of Area A.................................................................................................

............ 16 3. Agricultural Land in MC Portion of Area A ...................................................................................

..... 16 4. Agricultural Land in Maricopa County PM 10 

### Nonattainment Area..................................................... 17 5. Ratio of Agricultural Land in MC Portion of Area A to Agricultural Land in NAA ........................... 17 6. Projected Emission Reduction in MC Portion of Area A .................................................................... 17 7. Emission Reductions Due to Revised Agri cultural BMP Program in Senate Bill 1552 ...................... 19

1.3.3 Cessation of Night Tillage on High Pollution Advisory Days...............................................................

.. 20

1. Comparison of Occurrence of Stagnation Days with Tillage Days for Maricopa County................... 20 2. Uncontrolled Tillage Emissions in NAA for Year 2005 ...................................................................... 21 3. Controlled Tillage Emissions in NAA for Year 2005 .......................................................................... 21 4. Uncontrolled and Controlled Tillage Em issions in NAA for Years 2008 - 2010................................. 22 5. Uncontrolled and Controlled Tillage Emissions in MC Portion of Area A for Years 2008 - 2010...... 23 6. Uncontrolled and Controlled Tillage Emissions in Area A for Years 2008 - 2010 .............................. 23 7. Controlled Tillage Emissions in Area A by Crop for Years 2008 - 2010 ............................................. 24 8. Emission Reductions from Banning Tilling on HPAs in Area A ......................................................... 25 9. Emission Reductions from Banning Tilling from 2 AM to 8 AM on HPAs in Area A........................ 26 10. Percent Emission Reduction from Banning Tilling from 2 AM to 8 AM on HPAs in Area A ........... 26

1.3.4 Summary of Emissions Re ductions from Senate Bill 1552....................................................................

. 27

1.4 REFERENCES................................................................................................................................................ 28

ATTACHMENT #1 ..................................................................................................................

........... Attachment- 1

## iii LIST OF TABLES

Table 1 Emission Factors and Adjustment Factors ................................................................................

......... 4

Table 2 Ranking of Emission Reductions From Maricopa County BMPs and San Joaquin CMPs ............... 5

Table 3 Calculation of Percent Em ission Reductions by Ag BMP Group.................................................... 11

Table 4 Historical and Projected Crop Acreage in Maricopa County........................................................... 13

Table 5 Rate of Change Factors for Agricultural Land in Maricopa County

................................................ 13

Table 6 PM 10 

### Emissions for Maricopa County PM 10 

### Nonattainment Area................................................... 14

Table 7 Emission Reductions for Maricopa County PM 10 

### Nonattainment Area........................................... 15

Table 8 Emission Reductions for MC Portion of Area A...........................................................................

... 18

Table 9 Emission Reductions from Agricultu ral BMP Program in Senate Bill 1552 ................................... 20

Table10 Year 2005 Stagnation Days and Poten tial Tillage Days in Maricopa County ................................. 20

Table 11 Uncontrolled Tillage Emissions in NAA - Year 2005 ..................................................................... 21

Table 12 Controlled Tillage Emissions in NAA - Year 2005 .......................................................................

.. 22

Table 13 Projected Uncontrolled and Controlled Tillage Emissions (2 BMPs) in NAA ............................... 22

Table 14 Projected Uncontrolled and Controlled (2 BM Ps) Tillage Emissions in MC Portion of Area A .... 23

Table 15 Projected Uncontrolled and Controlled T illage Em issions in Area A (Maricopa County).............. 24

Table 16 Projected Controlled Tillage (2 BMP) Emissions in Area A (Maricopa County) by Crop.............. 24

Table 17 Emission Reductions from Banning Tilli ng on HP As in Area A (Maricopa County) ..................... 25

Table 18 Potential Emission Reductions from Banning Tilling from 2 AM to 8 AM on HPAs..................... 26

Table 19 Summary of Potential Emission Reductions ..............................................................................

..... 27

Table 20 Percent Emission Reductions of Agricu ltural Control Measures in Senate Bill 1552..................... 27

Table A-1 Potential PM 10 

### Emission Reductions by Control Measure and Associated Crop.......... Attachment- 1

LIST OF FIGURES

Figure 1. Ranking of Maricopa County Ag ricultural BMPs and San Joaquin CMPs................................ 9

## 1 1.0 TECHNICAL ANALYSIS OF AGRICULTURAL BMPS

1.1 INTRODUCTION This chapter presents the methodology, assumptions, and data used in selecting and assessing the effectiveness of agricultural best management practices (B MPs) that are not included in the current set of Maricopa County Agricultural PM 10 

### Best Management Practices (Governor’s Agricultural BMP Committee 2001). The chapter is divided into two sec tions. The first section (1.2) compares the current Maricopa County Agricultural BMPs with the Sa n Joaquin Valley Air Pollution Control District Conservation Management Practices (CMPs). The second section (1.3) summarizes potential PM 10 

### emission reductions from agricultural BMPs listed in Senate Bill 1552: (1) Requiring growers to use one additional BMP per Maricopa County BMP cate gory, and (2) Banning agricultural tilling on high pollution advisory days.

1.2 COMPARISON OF MARICOPA COUNTY BMPs AND SAN JOAQUIN CMPs At the request of the Agricultural Best Management Practices Workgroup (2006 – 2007), ADEQ Air Quality Division staff performed an analysis comparing potential PM 10 

### emissions reductions from implementation of San Joaquin CMPs with exis ting Maricopa County Agricultural BMPs for the Maricopa County PM 10 

### Nonattainment Area (ADEQ 2007a). This comparison was done to determine if there were San Joaquin CMPs that have the potential to reduce agricultural PM 10 

### emissions in the Maricopa County PM 10 

### Nonattainment Area. The San Joaquin CMP program was selected for this analysis based on a literature search of ot her states’ agricultural control measures.

The sources of data for the CMPs and BMPs:

 “Conservation Management Practices Program Report for 2005”, San Joaquin Valley Air Pollution Control District, January 19, 2006; and

 “Technical Support Document for Quantification of Agricultural Best Management Practices, Revised Final Draft”, ADEQ Contract No. 98-0159-BF, URS Corporation and Eastern Research Group, Inc., June 8, 2001.

1.2.1 Methodology The following steps were used to estimate potential uncontrolled PM 10 

### emissions and potential PM 10 

### emission reductions from implementation of Maric opa County Agricultural BMPs and San Joaquin

CMPs.

1. Estimation of Crop Acres in Maricopa County PM 10 

### Nonattainment Area (NAA) :

Crop Nonattainment Area 

### = Crop Maricopa County 

### * (Ag Acres Nonattainment Area 

### / Ag Acres Maricopa County 

### )

Where: Crop NAA 

### = Area of a specific crop in the Maricopa County PM 10 

### NAA (acres)

Crop Maricopa County 

### = Area of a specific crop in Maricopa County (acres) (Source: USDA, Arizona Agricultural Statistics - Year 2004)

Ag Acres NAA 

### = Total agricultural area in Maricopa County PM 10 

### NAA (acres) (Source: 2004 MAG Land Use Data)

Ag Acres Maricopa County 

### = Total agricultural area in Maricopa County (acres) (Source: USDA, Arizona Agricultural Statistics – Year 2004)

Example - Acres of Cotton in Maricopa County PM 10 NAA 

### :

## 2 Given: Crop NAA 

### = Acres of cotton in the Maricopa County PM 10 

### NAA

Crop Maricopa County 

### = 20,500 acres of cotton in Maricopa County

Ag Acres NAA 

### = 223,624 total agricultural acres in Maricopa County PM 10 

### NAA

Ag Acres Maricopa County 

### = 465,833 total agricultural acres in Maricopa County

Then: Crop NAA 

### = Crop Maricopa County 

### * (Ag Acres NAA 

### / Ag Acres Maricopa County 

### )

Cotton NAA 

### = 20,500 acres * (223,624 acres / 465,833 acres)

Cotton NAA 

### = 20,500 acres * 0.48005 = 9,841 acres

2. Calculation of Uncontrolled PM 10 

### Emissions by Crop & Agricultural Activity in Maricopa County

PM 10 

### Nonattainment Area :

E Crop Activity 

### = EF Crop Activity 

### * A

Where:

E Crop Activity 

### = Emissions for a specific crop and activity (lbs PM 10 

### / year)

EF Crop Activity 

### = Emission factor for a specific crop and activity (lbs PM 10 

### / acre / year)

A = Area of crop (acres)

Example – Land Preparation / Cultivation for Cotton:

Given:

E Crop Activity 

### = Emissions for land preparation / cultivation for cotton in Maricopa County PM 10 

### Nonattainment Area (lbs PM 10 

### / year)

EF Crop Activity 

### = 8.90 lbs PM 10 

### / acre / year for land preparation for cotton

A = 9,841 acres of cotton in Maricopa County PM 10 

### Nonattainment Area

Then:

E Crop Activity 

### = EF Crop Activity 

### * A

= 8.90 lbs PM 10 

### / acre / year * 9,841 acres

= 87,585 lbs PM 10 

### / year

## 3 3. Calculation of PM 10 

### Emissions Reduction by Crop and Control Measure:

ER = E Uncontrolled Emissions 

### * CE

Where:

ER = Emissions reduction for a specific crop and activity after application of a control measure (lbs PM 10 

### / year)

E Uncontrolled Emissions 

### = Uncontrolled emissions for a specific crop and activity (lbs PM 10 

### / year)

CE = Control effectiveness of a specific control measure (decimal reduction, e.g. 0.25 = 25% reduction)

Example – Integrated Pest Management C ontrol Measure Applied to Cotton Tilling:

Given:

ER = Emissions reduction for cotton land preparation / cultivation tilling after application of Integrated Pest Management control measure (lbs PM 10 

### / year)

E Uncontrolled Emissions 

### = Uncontrolled Emissions for cotton land preparation / cultivation (lbs

PM 10 

### / year)

CE = 19% = 0.19

Then:

ER = E Uncontrolled Emissions 

### * CE

ER = 87,585 lbs PM 10 

### / year * 0.19

ER = 16,641 lbs PM 10 

### / year

Table 1 lists the emission factors and adjustment factors that were used to estimate potential PM 10 

### emissions by crop and agricultural activities for comp arison of Maricopa County BMPs with San Joaquin CMPs. Note: the emission factors listed in Table 1 are composite emission factors that combine data from a number of emission generating activities into one emission factor by crop and category. For example, the composite emission factor for the Land Preparation / Cultivation category for Cotton combines emission factors for the following agricultural activities: rip field, primary discing, list beds, make ditch, spray and incorporate herbicide, irrigate, close ditch, cultivate preplant, plant, uncap beds, and cultivate. (See Table A-1 in Attachment #1 for a list of individual emission factors and emission reductions by crop activity, crop, and control measure.)4Table 1 – Emission Factors and Adjustment FactorsUnpaved Road and Unpaved Vehicle / EquipmentAreas1Crop TypeLandPreparation1(lbs PM10/acre/yr)Harvest1(lbs PM10 /acre/yr)WindErosion2Cropland(lbs PM10/acre/yr)WindErosion2NonCropland(lbs PM10/acre/yr)WindErosion2UnpavedRoads(lbs PM10/acre/yr)Vehicle MilesTraveled (VMT)1(VMT/acre/yr)VMT EmissionFactor1(lbs PM10/VMT)Vehicle TravelEmissionFactor3(lbs PM10/acre/yr)Alfalfa4.000.2400.334.310.4020.80Citrus0.070.14122.241.332.881.2322.46Corn6.900.43108.051.332.880.420.8Cotton8.903.37128.843.333.600.420.8Onions6.501.68122.241.332.882.424.8Wheat4.453.4501.332.881.422.8Barley4.453.4501.332.881.422.8Lettuce12.750.23122.241.332.882.424.8Melons5.700.23122.241.332.882.424.8Vegetables9.050.23122.241.332.882.424.8Data Sources:1“Conservation Management Practices Program Report for 2005”, SanJoaquin Valley Air Pollution Control District, January 19, 2006.2“Technical Support Document For Quantification Of Agricultural BestManagement Practices, Final”, Prepared for Arizona Department ofEnvironmental Quality by URS Corporation and Eastern Research Group, Inc., June 8, 2001.3Vehicle Travel Emission Factor was calculated by multiplying Vehicle Miles Traveled by VMT Emission Factor.1.2.2 Summary of Emissions ReductionsThe methodology used in Section 1.2.1 was used to estimate and compare the potential emission reductions that would result fromapplication ofMaricopa CountyBMPs and San Joaquin CMPsin the Maricopa County PM10Nonattainment Area. Table 2 ranks the sixty-seven Maricopa County Agricultural BMPs and SanJoaquin CMPs from largest to smallest potential PM10emission reductions for the Maricopa County PM10Nonattainment Area. As can be seen from Table 2, thosecontrol measures that reduce wind erosion on cropland have the highest potential PM10emission reductions, ranging from 1,034 tons to 453 tons of PM10reducedper year. It should be noted that there were no wind erosion control measures in the San Joaquin CMPs. This is the reason that the Maricopa County BMPs hadthe most effective PM10emission reductions.The cross reference column in Table 2 refers to the corresponding control measure listed in Table A-1 of Attachment #1 (e.g.,“CO – 8” refers to the Cross WindRidges control measure with data for its eight associated croptypes). Table A-1 provides greater detail on the control measures, specific crops affected by the5control measures, emission factors, emissions, and emissions reductions of the control measures that were evaluated. Figure 1displays those Maricopa CountyAgricultural BMPs and San Joaquin CMPs that have annual PM10emission reductions of 10 tons or more.The Agricultural BMP Technical Workgroup andGovernor’s Agricultural Best Management Practices Committee reviewed the comparison of the Maricopa County BMPs’ and San Joaquin CMPs’ emissionreductions and the Committee selected six control measures based on their feasibility and potential emission reductions.Caveat: The emissions and emissions reduction data listed inthis section are for comparison purposes only to evaluate the potential effectiveness of differentagricultural control measures. These data should not be construed as an emissions inventory for agricultural operations sinceit was necessary to estimate thenumber of acres by crop in the Maricopa County PM10Nonattainment Area and make general assumptions about the application of the different control measures.Table 2 - Ranking of PM10Emission Reductions From Maricopa County Agricultural BMPs and San Joaquin CMPsOrganizationControl Measure CategoryCrossReferenceto TableA-1Control MeasurePM10EmissionReduction(Tons/Year)1Maricopa CountyBMPCropland - Other ActivitiesCO-8Cross-Wind Ridges(reduces wind erosion on cropland)1,0342Maricopa CountyBMPCropland - Other ActivitiesCO-28Surface Roughening(reduces wind erosion of cropland)8163Maricopa CountyBMPCropland - Other ActivitiesCO-30aWind Barrier – Artificial(reduces wind erosion of cropland)8164Maricopa CountyBMPCropland - Other ActivitiesCO-30bWind Barrier – Natural(reduces wind erosion of cropland)4535San Joaquin CMPCropland - Other ActivitiesCO-11Grinding / Chipping / Shredding1306San Joaquin CMPCropland - Other ActivitiesCO-26Soil Incorporation1307Maricopa CountyBMPCropland - Other ActivitiesCO-24Sequential Cropping1028Maricopa CountyBMPUnpaved Roads & NonCroplandCU-8Wind Barrier - Artificial(reduces wind erosion of unpaved roads and noncropland)879Maricopa CountyBMPCropland - Land Prep /CultivationCL-6Conservation Tillage8310Maricopa CountyBMPCropland - Land Prep /CultivationCL-21Time of Planting7311San Joaquin CMPUnpaved Roads & NonCroplandCU-3Paving7012San Joaquin CMPCropland - Other ActivitiesCO-1Alternate Tilling6613Maricopa CountyBMPCropland - Land Prep /CultivationCL-8Equipment Changes/Technological Improvements666Table 2 - Ranking of PM10Emission Reductions From Maricopa County Agricultural BMPs and San Joaquin CMPsOrganizationControl Measure CategoryCrossReferenceto TableA-1Control MeasurePM10EmissionReduction(Tons/Year)14Maricopa CountyBMPUnpaved Roads & NonCroplandCU-6Track Out Control6415San Joaquin CMPUnpaved Roads & NonCroplandCU-1dRoad Oil5416San Joaquin CMPUnpaved Roads & NonCroplandCU-1cPolymers5217Maricopa CountyBMPUnpaved Roads & NonCroplandCU-7Water Application5118Maricopa CountyBMPUnpaved Roads & NonCroplandCU-9Wind Barrier – Natural(reduces wind erosion of unpaved roads and noncropland)4919Maricopa CountyBMPCropland - Other ActivitiesCO-15Mulching4720San Joaquin CMPCropland - Other ActivitiesCO-25Soil Amendments4121San Joaquin CMPUnpaved Roads & NonCroplandCU-1fGravel3322San Joaquin CMPCropland - Land Prep /CultivationCL-17Organic Practices3223San Joaquin CMPCropland - Other ActivitiesCO-20Organic Practices3224Maricopa CountyBMPUnpaved Roads & NonCroplandCU-5a-dReducing speed on unpaved roads3025Maricopa CountyBMPCropland – HarvestCH-4Equipment Changes/Technological Improvements2626Maricopa CountyBMPCropland - Land Prep /CultivationCL-12Limited Activity During a High-Wind Event2527Maricopa CountyBMPCropland - Other ActivitiesCO-16Multi-Year Crop2428San Joaquin CMPUnpaved Roads & NonCroplandCU-1aChips/mulch2429San Joaquin CMPUnpaved Roads & NonCroplandCU-1bOrganic materials/vegetation2430San Joaquin CMPUnpaved Roads & NonCroplandCU-1eSand247Table 2 - Ranking of PM10Emission Reductions From Maricopa County Agricultural BMPs and San Joaquin CMPsOrganizationControl Measure CategoryCrossReferenceto TableA-1Control MeasurePM10EmissionReduction(Tons/Year)31San Joaquin CMPCropland – Land Prep /CultivationCL-19Precision Farming2032San Joaquin CMPCropland - Land Prep /CultivationCL-20Tillage Based on Soil Moisture2033San Joaquin CMPCropland - Other ActivitiesCO-12Integrated Pest Management1934San Joaquin CMPCropland - Other ActivitiesCO-2Application Efficiencies1935San Joaquin CMPCropland - Other ActivitiesCO-29Transgenic Crops1836San Joaquin CMPCropland - Land Prep /CultivationCL-5Conservation Irrigation1737San Joaquin CMPCropland - Other ActivitiesCO-6Conservation Irrigation1738San Joaquin CMPCropland - Land Prep /CultivationCL-2Bed/Row Size or Spacing1639Maricopa CountyBMPCropland - Land Prep /CultivationCL-14Multi-Year Crop1640San Joaquin CMPCropland - Land Prep /CultivationCL-15Night Farming1341Maricopa CountyBMPCropland – HarvestCH-2Combined Operations1342San Joaquin CMPCropland – HarvestCH-14Shuttle System / Larger Carrier1343San Joaquin CMPCropland – HarvestCH-7Green Chop1344San Joaquin CMPCropland - Land Prep /CultivationCL-13Mulching1245Maricopa CountyBMPCropland - Land Prep /CultivationCL-22Timing of Tillage Operation1246San Joaquin CMPCropland - Land Prep /CultivationCL-23Transgenic Crops1147San Joaquin CMPCropland - Land Prep /CultivationCL-11Integrated Pest Management1148Maricopa CountyBMPCropland - Land Prep /CultivationCL-4Combining land preparation operations949San Joaquin CMPCropland - Land Prep /CultivationCL-3Chemigation/Fertigation950San Joaquin CMPCropland - Other ActivitiesCO-5Chemigation/Fertigation98Table 2 - Ranking of PM10Emission Reductions From Maricopa County Agricultural BMPs and San Joaquin CMPsOrganizationControl Measure CategoryCrossReferenceto TableA-1Control MeasurePM10EmissionReduction(Tons/Year)51San Joaquin CMPCropland – HarvestCH-1Baling/Large Balers752San Joaquin CMPCropland - Other ActivitiesCO-3Baling/Large Balers753Maricopa CountyBMPCropland - Other ActivitiesCO-23Residue Management754San Joaquin CMPUnpaved Roads & NonCroplandCU-4Restricted Access755San Joaquin CMPCropland - Land Prep /CultivationCL-16Non-Tillage/Chemical Tillage656San Joaquin CMPCropland - Other ActivitiesCO-19Non-Tillage/Chemical Tillage657San Joaquin CMPCropland – HarvestCH-9Night Harvesting558Maricopa CountyBMPCropland – HarvestCH-12Reduced Harvest Activity559San Joaquin CMPCropland - Other ActivitiesCO-17Night Farming / Night Harvesting360San Joaquin CMPCropland – HarvestCH-11Pre-Harvest Soil Preparation261San Joaquin CMPCropland - Land Prep /CultivationCL-24Transplanting162San Joaquin CMPCropland – HarvestCH-8Hand Harvesting163San Joaquin CMPCropland – HarvestCH-13Shed Packing0.1464Maricopa CountyBMPCropland - Land Prep /CultivationCL-7Cover Crops0.0765San Joaquin CMPCropland - Other ActivitiesCO-7Cover Crops0.0466San Joaquin CMPCropland - Other ActivitiesCO-22Reduced Pruning0.0167Maricopa CountyBMPCropland - Land Prep /CultivationCL-18Planting Based on Soil Moisture0.019Figure 1. Ranking of Maricopa County Agricultural BMPs and San Joaquin CMPsRanking of Maricopa CountyBMPs and San Joaquin CMPsPM10 Emission Reductions (Tons/Year)0 100 200 300 400 500 600 700 800 900 1,000 1,100Cross-Wind Ridges (reduces w ind erosion on cropland):Surface Roughening (reduces w ind erosion of cropland):Wind Barrier - Artificial (reduces w ind erosion of cropland):Wind Barrier - Natural (reduces w ind erosion of cropland):Grinding / Chipping / Shredding:Soil Incorporation:Sequential Cropping:Wind Barrier - Artificial (reduces w ind erosion of unpavedConservation Tillage:Time of Planting:Paving:Alternate Tilling:Equipment Changes/Technological Improvements:Track Out Control:Road Oil:Polymers:Water Application:Wind Barrier - Natural (reduces w ind erosion of unpavedMulching:Soil Amendments:Gravel:Organic Practices:Organic Practices:Reducing speed from 25. 9 mph to 5 mph:Reducing speed from 25.9 mph to 10 mph:Reducing speed from 25.9 mph to 15 mph:Reducing speed from 25.9 to 25 mph:Equipment Changes/Technological Improvements:Limited Activity During a High-Wind Event:Multi-Year Crop:Chips/mulch:Organic materials/vegetation:Sand:Precision Farming:Tillage Based on Soil Moisture:Integrated Pest Management:Application Efficiencies:Transgenic Crops:Conservation Irrigation:Conservation Irrigation:Bed/Row Size or Spacing:Multi-Year Crop:Night Farming:Combined Operations:Shuttle System / Larger Carrier:Green Chop:Mulching:Timing of Tillage Operation:Transgenic Crops:Integrated Pest Management:

## 10 1.3 AGRICULTURAL BMPS IN SENATE BILL 1552 ADEQ Air Quality Division staff performed an analysis to estimate potential PM 10 

### emissions reductions from agricultural BMPs language contained in Senate Bill 1552 (2007 session). Specifically, the following two agricultural BMPs were evaluated: (1) Expanding the number of Best Management Practices (BMPs) that growers must apply from one to two for each of the three BMP categories and extending the applicability of the Maricopa County BMPs to the Maricopa County portion of Area A outside of the Maricopa County PM 10 

### Nonattainment Area, and (2) Implementing a ban on tillage in Area A on any day for which ADEQ has issued a High Pollution Advisory.

1.3.1 Effect of One Additional Agricultural BMP in Maricopa County PM 10 

### Nonattainment Area The following section discusses the methodology, data, and assumptions used to estimate potential PM 10 

### emissions reductions in the Maricopa County PM 10 

### Nonattainment Area (NAA) from requiring growers to apply one additional agricultural BMP per category listed in the Maricopa County Agricultural BMPs. The section is arranged by the steps used to estimate the potential PM 10 

### emission reductions.

1. Percent Emission Reduction by Agricultural BMP Category - The percent emission reductions for the following three Agricultural BMP categories - T illage & Harvest, Non-cropland (Unpaved Farm Roads), and Cropland (Windblown Agriculture) were estimated for the NAA for Year 2005 using the following methodology:

Tillage & Harvest BMPs and Non-cropl and / Unpaved Farm Roads BMPs The Maricopa County Air Quality Department’s (MCAQD) 2005 Periodic PM 10 

### Emission Inventory (PEI) lists annual uncont rolled and controlled PM 10 

### emissions from tillage and harvest operations, and travel on unpaved agricultural roads in Maricopa County. MCAQD used the BMP control efficiencies listed in Table 4-2 of the URS and ERG report: “Technical Support Document of Agricultural Best Management Practices, June 2001” to calculate controlled PM 10 

### emissions for tillage, harvest, and unpaved farm roads. However, MCAQD used a comp liance rate of 59 percent rather than the 80 percent listed in the URS and ERG report. The 59 percent compliance rate was used to ensure consistency with MCAQD’s rule effectiveness study of the agricultural BMPs that was used in the development of the MCAQD 2005 PEI.

The percent emission reduction for the Tillage & Ha rvest BMPs and the Non-cropland / Unpaved Farm

Roads BMPs were calculated as follows:

% BMP Reduction Ag Source = (Uncontrolled Emissions Ag Source - Controlled Emissions Ag Source ) / Uncontrolled Emissions Ag Source



### Where:

% BMP Reduction Ag Source = Percent reduction in PM 10 emissions from application of one agricultural BMP.

Uncontrolled Emissions Ag Source = Uncontrolled PM 10 emissions from agricultural sour ce without agricultural BMP. (Source: MCAQD 2005 PEI)

Controlled Emissions Ag Source = Controlled PM 10 emissions from agricultural source w ith one agricultural BMP. (Source: MCAQD 2005 PEI)

## 11 Example - Percent Emission Reduction from Tillage BMPs – Year 2005:

Given:

Uncontrolled Emissions Tillage = 1,556 tons PM 10 / year Note: Agricultural emissions in NAA = Ma ricopa County agricultural emissions * 48.005% ( Percent of Maricopa County agricultural land in NAA)

Controlled Emissions Tillage = 1,229 tons PM 10 / year



### Then:

% BMP Reduction Tillage = (Uncontrolled Emissions Tillage - Controlled Emissions Tillage ) / Uncontrolled

Emissions Tillage

= (1,556 tons / year - 1,229 tons / year) / 1,556 tons

= 21.0%



### The percent emission reductions for Harvest BMPs and Non-cropland BMPs were calculated in a similar fashion to the percent emission reduction for tillage. A weighted average percent emission reduction was calculated for the Tillage & Harv est BMP category based on the percent emission reductions calculated for Tillage BMPs and Harvest BMPs .

Cropland / Windblown Agriculture BMPs The percent emission reduction for the Cropland / Windblown Agriculture BMP category was derived from the Maricopa Association of Government’s (MAG) technical support document: “Technical Support Document in Support of the MAG 2007 Five Percent Plan for PM 10 

### for the Maricopa County Nonattainment Area”. MAG used the U.S. Department of Agriculture’s (USDA) wind erosion equation to calculate PM 10 

### emissions from wind erosion of agricu ltural fields in Maricopa County and in the Maricopa County PM 10 

### Nonattainment Area. Hourly wind sp eeds and annual totals of harvested acres by crop in Maricopa County were input to the USDA wind erosion equation for years 2001 through 2005 to produce estimates of annual PM 10 

### emissions. A five-year average of the annual PM 10 

### emissions due to Cropland / Windblown Agriculture was then calculated.

Table 3 lists the emissions and percent emission reductions for the three agricultural BMP categories.

Table 3 - Calculation of Percent PM 10 

### Emission Reductions by Ag BMP Group

Agricultural BMP Group Maricopa County

Year 2005 % County Ag

Land in

PM 10 

### NAA 1 

### PM-10 NAA

Year 2005

Tillage: Uncontrolled tillage emissions (tons/year) 1 

### 3,241.12 48.005% 1,555.90 Controlled tillage emissions (tons/year) 1 

### 1,228.67 Emission Reduction (tons/year) 327.23 Percent Reduction due to one Tillage BMP 21.0%

Harvest: Uncontrolled harvest emissions (tons/year) 1 

### 166.36 48.005% 79.86 Controlled harvest emissions (tons/year) 1 

### 58.99 Emission Reduction (tons/year) 20.87

Reduction due to one Harvest BMP 26.1%

## 12 Table 3 - Calculation of Percent PM 10 

### Emission Reductions by Ag BMP Group

Agricultural BMP Group Maricopa County

Year 2005 % County Ag

Land in

PM 10 

### NAA 1 

### PM-10 NAA

Year 2005

Tillage & Harvest: % Weighted reduction for one Tillage &

Harvest BMP 21.3%

Non-cropland / Unpaved Farm Roads: Uncontrolled farm road emissions (tons/year) 1 

### 2,175.39 48.005% 1,044.30 Controlled farm road emissions (tons/year) 1 

### 910.64 Emission Reduction (tons/year) 133.66 % Reduction due to one Non-Cropland BMP 12.8%

Cropland / Windblown Agriculture: Uncontrolled windblown agricultural emissions (tons/year) 2 

### 1,614

Controlled windblown agricultural emissions tons/year) 2 

### 1,128

Emission Reduction (tons/year) 486 % Reduction due to one Cropland BMP 3 

### 30.1%

Data Sources:

1 

### “2005 Periodic PM 10 

### Emission Inventory”



### , MCAQD, May 2007.

2 

### "Technical Support Document in Support of the MAG 2007 Five Percent Plan for PM 10 

### for the Maricopa County Nonattainment Area", Maricopa Associa tion of Governments, December 2007. (Windblown agricultural emissions were derived from data in the MAG 2007 TSD's Appendix II, Exhibit 3: "Windblown

Dust Emission Calculations for PM 10 

### Nonattainment Are for the Years 2001 - 2005".)

3 

### Derived from Table 4-2 of the "Technical Support Document for Quantification of Agricultural Best Management Practices, Revised Final Draft", ADE Q Contract No. 98-0159-BF. URS Corporation and Eastern Research Group, Inc., June 8, 2001. Note: The compliance rate of 0.80 listed in the TSD for Quantification of Ag BMPs was converted to 0.59 by MCAQD in the development of their 2005 PEI.



### 2. Projected Crop Acreage in Maricopa County The Arizona Agricultural Statistics Bulletins for years 2000 through 2004 were reviewed to determine trends in crop acreages in Maricopa Count y. Based on these crop acreage data, the trend for harvested acres of field crops is a 4.6 percent d ecline per year and the trend for harvested acres of all crops (includes grapes and citrus) is a 4.9 pe rcent decline per year. These annual trends were used to project years 2007 through 2010 crop acreage for field crops (-4.6% per year) and all crops (- 4.9% per year) as follows:

Example – Field Crop Acreage – Year 2006:

Projected Crop Acres = Year 2005 Crop Acres x Annual Decrease

Projected Crop Acres Field Crops = 172,340 Harvested Acres Field Crops x (1 - 0.046)

= 164,412 Harvested Acres Field Crops in 2006

## 13 Table 4 lists historical and projected crop acreage for Maricopa County. Table 4 - Historical and Projected Crop Acreage in Maricopa County (acres / year)

2003 2004 2005 2006 2007 2008 2009 2010

Harvested

Acres of

Field Crops 1 

### 169,750 180,650 172,340 164,412 156,849 149,634 142,751 136,184

Harvested

Acres of

All Crops 2 

### 179,050 189,950 180,642 171,791 163,373 155,368 147,755 140,515

Data Sources:

1 

### Based on data from 2000-2004 Arizona Agricultural Statistics Bulletins; excludes grapes & citrus. Average annual acreage decrease between 2000 and 2004 = -4.6%.

2 

### Based on data from 2000-2004 Arizona Agricultural Statistics Bulletins; includes grapes & citrus; average annual acreage decrease between 2000 and 2004 = -4.9%.



### 3. Rate of Change Factors The years 2007 through 2010 projected crop acreage for harvested acres of field crops and harvested acres of all crops (Table 4) were divided by year 2005 crop acreage to produce rate of change factors for years 2006 through 2010 for harvested acres of field crops and harvested acres of all crops as

follows:

Example – Rate of Change for Field Crops – Year 2006:

Rate of Change Factor = Year 2006 Crop Acres / Year 2005 Crop Acres

Rate of Change Factor Field Crops = 164,412 Harvested Acres Field Crops / 172,340 Harvested Acres Field Crops

= 0.954 for 2006



### Table 5 lists rate of change factors for years 2006 through 2010. Table 5 - Rate of Change Factors for Agricultural Land in Maricopa County

2006 2007 2008 2009 2010

Harvested Acres of Field Crops

● Used to estimate future emission reductions from 2nd additional Tillage & Harvest BMP.

● Year 2005 is base year for calculation. 

### 0.954 0.910 0.868 0.828 0.790

Harvested Acres of All Crops

● Used to estimate future emission reductions from 2nd additional Noncropland / Unpaved

Farm Roads BMP



### .

● Year 2005 is base year for calculation. 

### 0.951 0.904 0.860 0.818 0.778

Harvested Acres of Field Crops

● Used to estimate future emission reductions from 2nd additional Cropland / Windblown Ag

BMP.

● Year 2003 is base year for calculation. 

### 0.969 0.924 0.881 0.841 0.802

## 14 4. Projected Agricultural Emissions in Maricopa County PM 10 

### Nonattainment Area The year 2005 uncontrolled emissions and contro lled emissions (Table 3, based on MCAQD 2005 PEI) were multiplied by the rate of change factor s (Table 5) to produce projected uncontrolled and controlled emission reductions, by agricultural BMP category, for years 2006 through 2007. The following rate of change factors were used to estimate projected and controlled emissions: (1) “Harvested Acres of Field Crops” rate of change factor was used for the Tillage & Harvest BMPs, (2) “Harvested Acres of All Crops” rate of change f actor was used for the Non-cropland / Unpaved Farm Roads BMPs, and (3) “Harvested Acres of Field Crops (base year 2003),” rate of change factor was used for the Cropland / Windblown Agriculture BMPs . These emissions are listed in Table 6 and the following example shows the calculation of projected emissions.

Example – Uncontrolled Tillage & Harvest Emissions – Year 2006:

Projected Emissions = Year 2005 Emissions x Rate of Change Factor

Projected Emissions Tillage & Harvests = 1,636 tons / year Uncontrolled Tillage & Harvest x 0.954

= 1,561 tons / year Uncontrolled Tillage & Harvest



### Table 6 - PM 10 

### Emissions for Maricopa County PM 10 

### Nonattainment Area (tons / year) BMP Category 2005 2006 2007 2008 2009 2010 Tillage & Harvest:



##  Uncontrolled 1,636 1,561 1,489 1,420 1,355 1,292



##  Controlled (21.3% reduction) 1,288 1,229 1,172 1,118 1,066 1,018
Non-cropland / Unpaved Farm Roads:



##  Uncontrolled 1,044 993 944 898 854 812



##  Controlled (12.8% reduction) 911 866 824 783 745 709
Cropland / Windblown Agriculture:



##  Uncontrolled 1,614 1,564 1,491 1,422 1,357 1,294



##  Controlled (30.1% reduction) 1,128 1,093 1,042 994 949 905

5. Projected Agricultural Emission Reductions in Maricopa County PM 10 

### Nonattainment Area

 One Agricultural BMP- The uncontrolled agricultural emissions (Table 6) for years 2006 through 2010 were multiplied by the percent emission reductions for the three agricultural BMP categories (Table 1: Tillage & Harvest = 21. 3%, Non-cropland / Unpaved Farm Roads = 12.8%, Cropland / Windblown Agriculture = 30.1%) The resulting emission reductions represent the application of one agricultural BMP per BMP cat egory. These emission reductions are listed in Table 7 and the following example shows the calculation of the emission reductions.

Example – Tillage & Harvest Emissions Reduction – Year 2006:

Emission Reductions = Annual Emissions x % BMP Emission Reduction

Emissions Reduction Tillage & Harvest = 1,561 tons / year Uncontrolled Tillage & Harvest x 0.213

= 332 tons / year

## 15  Second Additional Agricultural BMP – Years 2006 through 2010 controlled agricultural emissions (Table 6) were multiplied by the per cent emission reductions for the three agricultural BMP categories (Table 3). The resulting emission reductions represent the application of a second additional agricultural BMP per BMP cate gory. These emission reductions are listed in

Table 7.

It was assumed that the control effectiveness of the second additional agricultural BMP per BMP category would be at least as effective as the first set of agricultural BMPs. It should be noted that the percent emission reductions for the sec ond additional BMP were applied to controlled agricultural emissions to account for the emi ssion reductions that had already occurred from application of the first set of agricultural BMPs to the uncontrolled agricultural emissions.

 Total Agricultural Emission Reductions – The above emission reductions resulting from application of the first agricultural BMP and the second additional agricultural BMP for each of the three agricultural BMP categories (Tillage & Harvest, Non-cropland / Unpaved Farm Roads, Cropland / Windblown Agriculture) were summed to give total agricultural emission reductions for years 2006 through 2010, by BMP category, for the Maricopa County PM 10 

### Nonattainment

Area. These emission reductions are listed in Table 7.

Table 7 - Emission Reductions for Maricopa County PM 10 

### Nonattainment Area (tons/year) BMP Category 2005 2006 2007 2008 2009 2010 Tillage & Harvest:



##  First BMP Applied 348 332 317 303 289 275



##  Second BMP Applied 274 262 250 238 227 217



##  Total 622 594 567 541 516 492
Non-cropland / Unpaved Farm Roads:



##  First BMP Applied 134 127 121 115 109 104



##  Second BMP Applied 117 111 105 100 95 91



##  Total 251 238 226 215 204 195
Cropland / Windblown Agriculture:



##  First BMP Applied 486 471 449 428 408 389



##  Second BMP Applied 340 329 314 299 286 272



##  Total 826 800 763 727 694 661

Notes:

1. PM 10 

### Emission Reduction from 1st Ag BMP = % Emission Reduction * Uncontrolled Emissions (e.g., Year 2005 Tillage & Harvest: 1,636 tons PM 10 

### / Year 2005 * 21.3% = 348 tons PM 10 

### reduced / Year 2005).

2 . It was assumed that the control effectiveness of re quiring that a second BMP be implemented for each of the three BMP categories - Tillage & Harvest, Cropland, and Noncropland - would be at least as effective in reducing

PM 10 

### emissions as implementing the first set of BMPs for each of the three BMP categories.

3. PM 10 

### Emission Reduction from 2nd Ag BMP = % Emission Reduction * Controlled Emissions after 1st Ag BMP has been implemented (e.g., Year 2007 Tillage & Harvest: 1,172 tons PM 10 

### / year * 21.3% = 250 tons PM 10 

### reduced / year).

## 16 1.3.2 Extending Agricultural BMP Program to Ma ricopa County Portion of Area A outside the Maricopa County PM 10 

### Nonattainment Area

The following section discusses the methodology, data, and assumptions used to estimate potential PM 10 

### emission reductions for the Maricopa County portion of Area A outside of the Maricopa County PM 10 

### Nonattainment Area (hereafter referred to as “MC Por tion of Area A”) of requiring growers to apply two agricultural BMPs per category. The rationale for evaluating the effect of two agricultural BMPs per category for the MC Portion of Area A is that this ar ea had previously not been subject to the Agricultural BMP Program (only the Maricopa County PM 10 

### Nonattainment Area had been subject to the Agricultural BMP Program). The section is arranged by the steps used to estimate the potential PM 10 

### emission reductions and will build on the agricultural emission re duction data that were calculated in the previous section for the Maricopa County PM 10 

### Nonattainment Area.

1. Percent Agricultural Land In Maricopa County - The percent agricultural land in Maricopa County was calculated by dividing the total acres of agricu ltural land in Maricopa County, listed in the 2004 Arizona Agriculture Statistics Bulletin for Maricopa County, by the total acres of land in Maricopa County as follows:

Example – Percent Agricultural Land:

Percent Ag Land in County = Total Ag Acres in County / Total Acres in County

= 189,950 acres / 5,889,941 acres

= 3.225%



### 2. Land in MC Portion of Area A - Spatial analysis, using GIS, was used to determine the number of acres in the MC Portion of Area A and the percentage of the MC Portion of Area A in Maricopa County. The results of the GIS analysis were th at there are 806,333 acres in the MC Portion of Area A and the percentage of the MC Portion of Area A that is in Maricopa County is 13.69% (based on spatial analysis by ADEQ GIS staff).

3. Agricultural Land in MC Portion of Area A – Was calculated by multiplying “Percent Agricultural Land in Maricopa County” (Step #1) by “Land in MC Portion of Area” (Step #2) as follows:

Example – Agricultural Land in MC Portion of Area A:

Ag Land in MC Portion of Area A = Percent Ag Land in County x Land in MC Portion of Area A

= 3.225% x 806,333 acres

= 26,004 acres

## 17 4. Agricultural Land in Maricopa County PM 10 

### Nonattainment Area - Was calculated by multiplying the “Percent County Agricultural Land in Maricopa County PM 10 

### Nonattainment Area” (MCAQD, 2007) by total agricultural acres in Maricopa County (USDA, 2005) as follows:

Example – Agricultural Land in Maricopa County PM 10 

### Nonattainment Area:

Ag Land in PM 10 Nonattainment Area = Percent County Ag Land in NAA x Ag Land in Maricopa County

= 48.005% x 189,950 acres

= 91,185 acres



### 5. Ratio of Agricultural Land in MC Portion of Area A to Agricultural Land in Maricopa County

PM 10 

### Nonattainment Area – Was calculated by dividing acres of “Agricultural Land in MC Portion of Area A” (Step #3) by acres of “A gricultural Land in Maricopa County PM 10 

### Nonattainment Area” (Step #4) as follows:

Example – Ratio of Agricultural Land:

Ratio of Ag Land = Ag Land in MC Portion of Area A / Ag Land in PM 10 Nonattainment Area

= 26,004 acres / 91,185 acres

= 0.285



### 6. Projected Emission Reductions in MC Portion of Area A – The agricultural emission reductions resulting from application of the first BMP and the second additional BMP, by agricultural BMP category, in the Maricopa County PM 10 

### Nonattainment Area for years 2008 through 2010 (totals shown in Table 7) were multiplied by the ratio of agricultural land (Step #5) to produce projected agricultural emission reductions for the MC Portion of Area A for years 2008 through 2010. It

should be noted that the MC Portion of Area A w as not previously subject to the Maricopa County Agricultural BMP program. That is the reason th at both the first agricultural BMP and the second additional agricultural BMP, per BMP category, we re applied to the MC Portion of Area A to

estimate emission reductions.

The projected emission reductions for the MC Portion of Area A were calculated as follows:

MC Portion Area A ER Ag Source 

### = Nonattainment Area ER Ag Source 

### x Ratio of Ag Land

## 18 Where:

MC Portion Area A ER Ag Source = Emission reduction, by agricultural source (Tillage & Harvest, Noncropland / Unpaved Farm Roads, Cropl and / Windblown Agriculture), in the
Maricopa County Portion of Area A Outside of the Maricopa County PM 10 Nonattainment Area.

Nonattainment Area ER Ag Source = Emission reduction, by agricultural source (Tillage & Harvest, Noncropland / Unpaved Farm Roads, Cropl and / Windblown Agriculture), in the
Maricopa County PM 10 Nonattainment Area. Note: These are total emission reductions due to application of original one agricultural BMP per category and application of second additional agricultural BMP category (Second agricultural BMP required by Senate Bill 1552).

Ratio of Ag Land = Ag Land in MC Portion of Area A / Ag Land in PM 10 Nonattainment Area.



### Example - Emission Reduction from Tillage & Harvest BMP for Year 2008:

Given:

Nonattainment Area ER Tillage & Harvest = 541 tons / year

Ratio of Ag Land = 0.285



### Then:

MC Portion Area A ER Tillage & Harvest = Nonattainment Area ER Tillage & Harvest x Ratio of Ag Land

= 541 tons / year x 0.285

= 154 tons / year



### Table 8 lists the emission reductions for the MC Portion of Area A, by BMP category, for the years 2008 through 2010.

Table 8 - Emission Reductions for MC Portion of Area A (tons/year)

2008 2009 2010

Ag BMP Category (1 st 

### and 2 nd 

### BMPs) Nonattainmen

t

Area Area A

Outside

NAA Nonattainment

Area Area A

Outside

NAA Nonattainmen

t

Area Area A

Outside

NAA

Tillage & Harvest 541 154 516 147 492 140

Non-cropland / Unpaved Farm Roads 215 61 204 58 195 56

Cropland / Windblown Agriculture 727 207 694 198 661 188



### Notes:

1. It was assumed that the crop mix is homogeneous throughout Maricopa County.

2 . Emission reduction in MC Portion of Area A = NAA Emission Reduction * (Ag land in MC Portion of Area A / Ag land in NAA).

3. Emission reductions in Nonattainment Area (for this table) = Emission Reduction from First BMP + Emission Reduction from Second BMP (see totals for each BMP category in Table 7). This assumption was used in calculating

the MC Portion of Area A emissions b ecause the MC Portion of Area A had not previously been subject to the Agricultural BMP program (only the Maricopa County PM 10 

### Nonattainment Area had the Ag BMP Program), thus its projected emission reductions are due to two "additional" Ag BMPs, instead of just one additional Ag BMP, when extending the Agricultural BMP program to the MC Portion of Area A.

## 19 7. Emission Reductions Due to Revised Agricultural BMP Program in Senate Bill 1552 - The Senate Bill 1552 revisions to the Agricultural BMP Program included: (a) Second additional Agricultural BMP in the Maricopa County PM 10 

### Nonattainment Area, and (b) Extending the Agricultural BMP Program to the Maricopa County Portion of Area A Outside of the Maricopa County PM 10 

### Nonattainment Area (two new agricultural BMPs). To determine the total projected emission reductions from the revised Agricultural BMP Progr am, the projected emission reductions for the MC Portion of Area A (see “Area A Outside NAA” colu mns in Table 8) were added to the projected emission reductions for the Maricopa County PM 10 

### Nonattainment Area (see “Second BMP Applied” rows in Table 7). The total PM 10 

### emission reductions due to the revised agricultural BMP program in

Senate Bill 1552 were calculated as follows:

Example – Emission Reductions from Tillage & Harvest BMP for Year 2008:

ER Tillage & Harvest 

### = MC Portion of Area A ER Tillage & Harvest 

### + Nonattainment Area ER Tillage & Harvest



### = 154 tons/year + 238 tons/year

= 392 tons/year

Table 9 lists the total projected emission reductions from the revised agricultural BMP program in Senate Bill 1552: (1) Second additional agricultural BMP in the Maricopa County PM 10 

### Nonattainment Area, and (2) Extending the Agricultural BMP program from the Maricopa County PM 10 

### Nonattainment Area to the Maricopa County portion of Area A outside of the Maricopa County PM 10 

### Nonattainment Area.

Table 9 – Emission Reductions from Agricultur al BMP Program in Senate Bill 1552 (tons/year) Ag BMP Category 2008 2009 2010 Tillage & Harvest BMP (21.3% Reduction) 392 374 357

Non-cropland / Unpaved Farm Roads BMP (12.8% Reduction) 161 153 147

Cropland / Windblown Agriculture BMP (30.1% Reduction) 506 484 460

Total Emission Reductions: 1. Maricopa County PM 10 

### Nonattainment Area (one new BMP for this area). 2. MC Portion of Area A (two new BMPs for this area). 1,059 1,011 964

Emission Reductions from 2nd BMP in Maricopa County PM 10 

### NAA 637 608 580

Emission Reductions from 1st BMP and 2nd BMP in MC Portion of Area A 422 403 384

Notes: Revised Agricultural BMP Program in Senate Bill 1552 included:

 Maricopa County PM 10 

### NAA - Second additional Ag BMP per category.

 Extending Agricultural BMP program from Maricopa County PM 10 

### Nonattainment Area to MC Portion of Area A (i.e., require two new BMPs per category in MC Portion of Area A).

Projected Emission Reductions = (Emission Reductions for MC Portion of Area A) + (Emission Reductions for Maricopa County PM 10 

### Nonattainment Area).

## 20 Caveats : 1. Crop Data - The actual number of acres for specific crops in the Maricopa County PM 10 

### Nonattainment Area and Area A is not available. These data were estimated from the Maricopa County crop acre data listed in the USDA, “Ari zona Agricultural Statistics – 2004”. The crop mix was assumed to be homogeneous in the Maricopa County PM 10 

### Nonattainment Area and MC

Portion of Area A.

2. Selection of Agricultural BMPs – The actual BMPs that have been selected by growers in the Maricopa County PM 10 

### Area are not known since growers are not required to submit these data to government agencies. Thus, MCAQD assumed an average PM 10 

### emission reduction for each BMP category during the development of the MCAQD 2005 Periodic PM 10 

### Emissions Inventory.

1.3.3 Cessation of Night Tillage on High Pollution Advisory Days This control measure bans agricultural tilling from 2 AM to 8 AM on High Pollution Advisory Days (HPAs) forecast by ADEQ that are air stagnation days. The following section discusses the methodology, data, and assumptions used to estimate potential PM 10 

### emission reductions from implementation of this control measure in the Maricopa County portion of Area A [hereafter referred to as “Area A (Maricopa County)”]. The section is arranged by the steps used to estimate the potential PM 10 

### emission reductions and will build on the agricultural emissions and emi ssion reduction data that were calculated in the previous sections for the Maricopa County PM 10 

### Nonattainment Area and MC Portion of Area A.

1. Comparison of Occurrence of Stagnation Days with Tillage Days for Maricopa County - The crop calendar of agricultural practices in Maricopa County, listed in the in the Salt River PM 10 

### Technical Support Document (ADEQ, 2005), was compared with the Year 2005 – 2006 ADEQ summary report

of PM 10 

### exceedances and associated weather conditions (ADEQ, 2007b) to determine which crops were being tilled during months with stagnation days. The comparison showed that cotton, corn, and vegetables were being tilled during the months of Ja nuary and February which have stagnation days. Table 10 lists data on the months when tillage and stagnation days occur and the percent of stagnation days that occur during tillage days by crop.

Table 10 - Year 2005 Stagnation Days and Pote ntial Tillage Days in Maricopa County
Crop Tillage

Months 1 

### Potential Tillage Days Stagnation Days 2 

### Stagnation Days / Tillage Days

(percent)

Cotton January, February, March 59 9 15%
Corn January, February 59 9 15% Vegetable

s February 28 5 18%

Data Sources:

1 

### Crop Calendar in ADEQ Salt River PM10 TSD (ADEQ. 2005. Revised PM10 State Implementation Plan for the Salt River Area, Technical Support Document. Air Qua lity Division, Arizona Department of Environmental Quality. September 2005. http://azdeq. gov/environ/air/plan/ download/sr-tsd.pdf).

2 

### ADEQ analysis of the occurrence of Stagnation Days in Year 2005: 4 days in January, 5 days in February , 0 days in March (ADEQ. 2007b. 2005-2006 Forecast Season PM10 Exceedan ce Report for Maricopa County. Air Quality Division, Arizona Depa rtment of Environmen tal Quality. January 2007 ).

Notes:

1. Potential Tillage Days : There were no stagnation days listed for March in ADEQ's analysis (only in January and February), that is why 59 instead of 90 "Potential Tillage Days" were considered for cotton tillage emissions. 2. Stagnation Days : Total stagnation days were based on January and February stagnation days since ADEQ's analysis did not list any stagnation days for March.

## 21 2. Uncontrolled Tillage Emissions in NAA for Year 2005 - Were calculated by multiplying the annual uncontrolled tillage emissions for cotton, corn, and vegetables, listed in the PEI, by the percent county agricultural land in the NAA as follows:

Example – Uncontrolled Cotton Tillage Emissions – Year 2005:

Uncontrolled Tillage Emissions = Uncontrolled County Tillage Emissions x % County Ag Land in NAA

Uncontrolled Tillage Emissions Cotton = 1,140.09 tons/year x 48.005%

= 547 tons/year



### Table 11 lists the uncontrolled tillage emissions by crop and percent of the total tillage emissions by crop in the NAA for Year 2005.

Table 11 - Uncontrolled Tillage Emissions in NAA - Year 2005

Crop Maricopa County

Uncontrolled

Emissions 1


### (tons/year) Percent County Ag Land

in NAA 1 

### NAA

Uncontrolled

Emissions (tons/year) NAA

Uncontrolled Emissions (percent)

Cotton 1,140.09 48.005% 547 68%

Corn 333.90 160 20% Vegetables 201.87 97 12%
Total 1,675.86 804 100%

Data Source:

1 

### MCAQD 2005 Periodic PM 10 

### Emissions Inventory.

Notes:
MCAQD 2005 Periodic PM 10 Emission Inventory lists the following vegetables as having tillage emissions: Dry Onions (23.66 tons/year), Carrots (73.93 tons/year), and Broccoli (104.28 tons/y ear). These three crops' tillage emissions were added togethe r to produce uncontrolled emissions of 201. 87 tons / year for "Vegetables".



### 3. Controlled Tillage Emissions in NAA for Year 2005 - Were calculated by multiplying the annual uncontrolled tillage emissions for cotton, corn, and ve getables in the NAA (Step #2) by the result of 1 - Tillage BMP Percent Control Reduction (see Table 3) as follows:

Example – Controlled Cotton T illage Emissions – Year 2005:

Controlled Tillage Emissions = Uncontrolled NAA Tillage Emissions x % BMP Control Reduction

Controlled Tillage Emissions Cotton = 547 tons/year x (1 – 0.21)

= 432 tons/year



### Table 12 lists the controlled tillage emissions by crop in the NAA and percent of total emissions, after application of the first and second tillage BM Ps from the Tillage & Harvest BMP category, for

the Year 2005.

## 22 Table 12 - Controlled Tillage Emissions in NAA - Year 2005

Controlled Emissions (tons/year) 

### Crop Uncontrolled

Emissions 1


### (tons/year) BMP Control

Reduction 2



### (percent) 1 st 

### BMP 2 nd 

### BMP Controlled Emissions

2nd BMP (percent)

Cotton 547 21% 432 341 68%

Corn 160 126 100 20% Vegetables 97 77 61 12%

Total 804 635 502 100%

Data Sources:

1 

### MCAQD 2005 Periodic PM 10 

### Emissions Inventory.

2 

### Table 3 of this report.

Notes:

Controlled Emissions from 2nd Tillage BMP = Controlled Emissions from 1st Tillage BMP x (1 - 0.21).



### 4. Projected Uncontrolled and Controlled Tillage Emissions in NAA for Years 2008 - 2010 - Were calculated by multiplying the Year 2005 totals for uncontrolled and controlled tillage emissions in the NAA (Step #3) by the rate of change factors th at were developed in Sec tion 1.3.1 of this report (see Table 5) as follows:

Example – Projected Controlled Tillage Emissions – Year 2010:

Projected Controlled Tillage Emissions = Controlled NAA Tillage Emissions 2005 x Rate of Change Factor Year

Projected Controlled Tillage Emissions 2010 = 502 tons/year x 0.790

= 397 tons/year



### Table 13 lists the projected uncontrolled and contro lled tillage emissions in the NAA for Years 2008 -

2010.

Table 13 - Projected Uncontrolled and Cont rolled Tillage Emissions (2 BMPs) in NAA

Year 2008 Rate of Change 1 

### Year 2009 Rate of Change 1 

### Year 2010 Rate of Change 1



### 0.868 0.828 0.790

Year 2008

Uncontrolled Emissions (tons/yr) Year 2009

Uncontrolled Emissions (tons/yr) Year 2010

Uncontrolled Emissions (tons/yr)

698 666 635

Year 2008

Controlled 2


### Emissions (tons/yr) Year 2009

Controlled 2


### Emissions (tons/yr) Year 2010

Controlled 2


### Emissions (tons/yr)

436 416 397

Data Sources:

1 

### Table 5 of this report.

2 

### Controlled Emissions from applicati on of 1st original tillage BMP (21% emissions reduction) and second additional tillage BMP from Tillage & Harvest BMP category (21% emissions reduction applied to controlled emissions from 1st tillage BMP). Note: Does not incl ude emission reduction from “Cessation of Night Tillage during High Pollution Advisory Days” BMP.

## 23 5. Projected Uncontrolled and Controlled Tillage Emissions in MC Portion of Area A for Years 2008

- 2010 - Were calculated by multiplying the projected uncontrolled and controlled tillage emissions in the NAA (Step #4) by the ratio of agricultural land in the MC Portion of Area A to agricultural land in the NAA (see Section 1.3.2, Step #5) as follows:

Example – Projected Controlled Tillage Emissions – Year 2010:

Projected Controlled Tillage Emissions = Controlled NAA Tillage Emissions x Ratio of Ag Land

Projected Controlled Tillage Emissions 2010 = 397 tons/year x 0.285

= 113 tons/year



### Table 14 lists the projected uncontrolled and controlle d tillage emissions in the MC Portion of Area A.

Table 14 - Projected Uncontrolled a nd Controlled (2 BMPs) Tillage Emissions in MC Portion of Area A

Year 2008

Uncontrolled Emissions (tons/yr) Year 2009

Uncontrolled Emissions (tons/yr) Year 2010

Uncontrolled Emissions (tons/yr) Ratio of Ag Land:

MC Portion of Area A /

Nonattainment Area 1



### 199 190 181 0.285

Year 2008

Controlled Emissions (tons/yr) Year 2009

Controlled Emissions (tons/yr) Year 2010

Controlled Emissions (tons/yr)

124 119 113

Data Source:

1 

### Section 1.3.2, Step #5 of this report.

Notes:

1. "MC Portion of Area A" is the portion of Area A in Maricopa County that is outside of the Maricopa County

PM 10 

### Nonattainment Area (i.e., does not include portion of Area A that is in Pinal County).

2. Controlled Emissions are from application of 2 Tillage BM Ps from Tillage & Harvest BMP category. It does not include emission reduction from "Cessation of Night Tillage during High Pollution Advisory Days" BMP.



### 6. Projected Uncontrolled and Controlled Tillage Emissions in Area A (Maricopa County) for Years

2008 - 2010 - Were calculated by adding the uncontrolle d and controlled tillage emissions for the NAA (step #4) with the uncontrolled and controlled tillage emissions from the MC Portion of Area A (step #5) for Years 2008 – 2010 as follows:

Example – Projected Controlled Tillage Emissions – Year 2010:

Projected Controlled Tillage Emissions = NAA Controlled Tillage Emissions + MC Portion of Area A Controlled Tillage Emissions

Projected Controlled Tillage Emissions 2010 = 397 tons/year + 113 tons/year

= 510 tons/year



### Table 15 lists the projected uncontrolled and c ontrolled tillage emissions in Area A (Maricopa County) for Years 2008 – 2010.

## 24 Table 15 - Projected Uncontrolled a nd Controlled Tillage (2 BMPs) Emissi ons in Area A (Maricopa County)

Year 2008

Uncontrolled Emissions (tons/yr) Year 2009

Uncontrolled Emissions (tons/yr) Year 2010

Uncontrolled Emissions (tons/yr)

897 856 816

Year 2008

Controlled Emissions (tons/yr) Year 2009

Controlled Emissions (tons/yr) Year 2010

Controlled Emissions (tons/yr)

560 535 510

Notes:

1. "Area A (Maricopa County)" does not include Pinal County portion of Area A. Area A (Maricopa County) is comprised of Maricopa County PM 10 

### Nonattainment Area and MC Portion of Area A (portion of Area A in Maricopa County that is outside of the nonattainment area).

2. Controlled Tillage Emissions in Area A (Maricopa County) = Controlle d Emissions in NAA (from 1st and 2nd Tillage BMPs) + Controlled Emissions in MC Portion of Area A (from 1st and 2nd Tillage BMPs).



### 7. Projected Controlled Tillage Emissions in Area A (Maricopa County) by Crop for Years 2008 -

2010 - Were calculated by multiplying the uncontro lled and controlled tillage emissions in Area A (Maricopa County) from Step #6 by the percent tillage emissions by crop (see “Controlled Emissions, 2nd BMP” column of Table 12) as follows:

Example – Projected Controlled Tillage Emissions – Cotton in Year 2010:

Projected Controlled Tillage Emissions Crop = Controlled NAA Tillage Emissions x % Tillage Emissions Crop

Projected Controlled Tillage Emissions Cotton = 510 tons/year x 68%

= 347 tons/year



### Table 16 lists the projected uncontrolled and c ontrolled tillage emissions, by crop, in Area A (Maricopa County) for Years 2008 – 2010.

Table 16 - Projected Controlled Tillage (2 BMPs) Em issions in Area A (Maricopa County) by Crop
Crop Year 2008 Year 2009 Year 2010

Emissions 1 

### Emissions 1 

### Emissions 1



### (tons/yr) (tons/yr) (tons/yr)

Cotton 381 364 347

Corn 112 107 102 Vegetables 67 64 61

Total 560 535 510

Notes:

1 

### Tillage Emissions by Crop = (Tillage Emissions in Area A, Maricopa County) x (P ercent Tillage Emissions by crop).

## 25 8. Emission Reductions from Banning Tilling on HPAs in Area A (Maricopa County) for Years 2008

– 2010 - Were calculated by multiplying controlled tilla ge emissions, by crop, in Area A (Maricopa County) from Step #7 by the ratio of stagnation da ys to tillage days (see “Stagnation Days / Tillage Days” column of Table 10) as follows:

Example – Emissions Reduction from Banning Tilling during HPAs – Corn in Year 2010:

Emissions Reduction Crop = Controlled Tillage Emissions Crop x Stagnation Days / Tillage Days Crop

Emissions Reduction Corn = 102 tons/year x 15%

= 15 tons/year



### Table 17 lists the potential emission reductions from banning tilling on HPAs (stagnation days) in Area A (Maricopa County) for Years 2008 -2010.

Table 17 - Potential Emission Reductions from Ba nning Tilling on HPAs in Area A (Maricopa County
Crop Year 2008

Emission Reductions (tons/year) Year 2009

Emission Reductions (tons/year) Year 2010

Emission Reductions (tons/year)

Cotton 38 36 34

Corn 17 16 15 Vegetables 12 12 11

Total 67 64 60

Notes:

1. It has been observed that dust can remain suspended in the air for extended periods on a stagnation day. An assumption was made that dust resulting from agricultu ral tilling will remain suspended twice as long on a stagnation day as on a "non-st agnation day" and this will have an e ffect on air quality / emissions which is equivalent to an additional agricultural tilling day. Thus, banning tilling on a HPA, that is a stagnation day, was assumed to reduce one day's equivalent of agricultural tilling emissions.

2. Tilling Emission Reductions from Banning Tilling on HPAs = (Controlled Emissions from application of 2 Tillage BMPS from Tillage & Harvest BMP category) x (Stagnation Days / Potential Tillage Days).

3. Cotton Emission Reductions: ADEQ's analysis of PM 10 

### exceedance and stagnation days indicated that stagnation days do not typically occur in March. Thus, the March tillage emissions for cotton were not included in the Ban Tilling on HPAs emissions reduction calculation for cotton. A ratio of 59 days / 90 days, or 0.66, was used to adjust the 3-month total of January, February, and March cotton tillage emissions to a 2-month total of January and February cotton tillage emissions . Example: Year 2010 cotton tilla ge emission reduc tions from Banning Tilling on HPAs = 347 tons/year x 15% x 0.66 = 34 tons/year.

## 26 9. Emission Reductions from Banning Tilling from 2 AM to 8 AM on HPAs in Area A (Maricopa County) for Years 2008 – 2010 - Were calculated by multiplying emission reductions, by crop, in Area A (Maricopa County) from Step #8 by the ratio of 6 hours / 24 hours as follows:

Example – Emissions Reduction from Banning Tilling from 2 AM to 8 AM during HPAs – Cotton -

Year 2010:

Emissions Reduction Crop = Emissions Reduction Crop x Ratio of Tilling Ban Hours per Day

Emissions Reduction Cotton = 34 tons/year x 6 hours / 24 hours

= 9 tons/year



### Table 18 lists the potential emission reductions from banning tilling from 2 AM to 8 AM on HPAs (stagnation days) in Area A (Maricopa County) for Years 2008 – 2010.

Table 18 - Potential Emission Reductions from Banning Tilling from 2 AM to 8 AM on HPAs
Crop Year 2008

Emission Reductions (tons/year) Year 2009

Emission Reductions (tons/year) Year 2010

Emission Reductions (tons/year) Percent HPA Day

2 AM to 8 AM (6 hours / 24 hours)

Cotton 10 9 9 25%

Corn 4 4 4 Vegetables 3 3 3

Total 17 16 16

Notes:

1. It was assumed that agricultural tilling does not va ry by hour on an agricultural tilling day (based on conversations with growers on Governor's Ag BMP Committee w ho said that they often have two or three shifts of workers operating farm machinery per day. These growers recommended 2 AM to 8 AM ban on tilling on HPAs).

2. Emission Reductions from Banning Tilling from 2 AM to 8 AM on HPAs = (Emission Reductions on HPAs) x Percent HPA Day.

3. This control measure is referred to as "Cessation of Night Tillage on High Pollution Advisory Days" in Agricultural Best Management Practices SIP.



### 10. Percent Emission Reduction from Banning Tilling from 2 AM to 8 AM on HPAs in Area A (Maricopa County) for Year 2010 - Was calculated by dividing the Year 2010 tillage emission reduction for Area A (Maricopa County) from St ep #9 by the Year 2010 uncontrolled tillage emissions (see Table 15) as follows:

Example – Percent Emission Reduction from Banning T illing from 2 AM to 8 AM during HPAs – Year

2010:

Percent Emission Reduction = Emissions Reduction / Uncontrolled Tillage Emissions

= (16 tons/year / 816 tons/year) x 100%

= 2.0%

## 27 1.3.4 Summary of Agricultural Emission Reductions from Senate Bill 1552 Table 19 lists the potential emission reductions from implementation of the two agricultural control measure packages listed in Senate Bill 1552.

Table 19 - Summary of Potential PM 10 

### Emission Reductions from Agricultural Control Measures in Senate Bill 1552 (tons / year) Control Measure Category 2008 2009 2010 Require One Additional BMP Per Category and Extend Agricultural BMP Program to Maricopa County Portion of Area A Outside of the

PM 10 

### Nonattainment Area:

 Tillage and Harvest BMP 392 374 357

 Non-Cropland / Unpaved Farm Roads BMP 161 153 147

 Cropland / Windblown Agriculture BMP 506 484 461
Total 1,059 1,011 965

Ban Agricultural Tilling from 2 AM to 8 AM on HPAs (Cessation of Night Tillage on High Pollution Advisory Days) 17 16 16

Total Agricultural Emission Reducti ons From Senate Bill 1552 1,076 1,027 981



### Table 20 lists the percent emission reductions by agricultural control measure in Senate Bill 1552.

Table 20 - Percent Emission Reductions of Agri cultural Control Measures in Senate Bill 1552

Agricultural Control Measure Emission Reduction (percent)

Revised Agricultural BMP Program:

● Tillage and Harvest BMPs 21.3%

● Noncropland / Farm Roads BMPs 12.8%

● Cropland / Windblown Agriculture BMPs 30.1%

Ban Agricultural Tilling from 2 AM to 8 AM on HPAs 1


### (Cessation of Night Tillage on High Pollution Advisory Days) 2.0%

Notes:

1 

### Emission Reduction Percent for Year 2010.

## 28 1.4 REFERENCES

ADEQ. 2005. Revised PM 10 

### State Implementation Plan for the Salt River Area, Technical Support

Document . Air Quality Division, Arizona Department of Environmental Quality. September 2005. http://azdeq.gov/environ/air/plan/download/sr-tsd.pdf

ADEQ. 2007a. Comparison Of Potential PM 10 

### Emissions Reductions From Implementation Of Maricopa County Agricultural BMPs and San Joaquin Conservation Measure Practices . Air Quality Division, Arizona Department of Environmen tal Quality. January 22, 2007. http://www.azda.gov/ACT/Emissions%20Comparison%20Report.pdf

ADEQ. 2007b. 2005-2006 Forecast Season PM 10 

### Exceedance Report for Maricopa County. Air Quality Division, Arizona Department of Environmental Quality. January 2007.

Governor’s Agricultural BMP Committee. 2001. Guide to Agricultural PM 10 

### Best Management Practices, Maricopa County PM 10 

### Nonattainment Area

. http://www.azda.gov/ACT/bmpguide.pdf

MAG. 2004. MAG 2004 Existing Land Use Data . Maricopa Association of Governments.

MAG. 2007. MAG 2007 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area; Appendices Volume 3 and 4; Technical Document in Support of the MAG 2007 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area . Maricopa Association of Governments.

December 2007. http://magwww.mag.maricopa.gov/detail.cms?item=8072

MCAQD. 2007. 2005 Periodic Emissions Inventory for PM 10 

### for the Maricopa County, Arizona,

Nonattainment Area . Maricopa County Air Quality Department. May 2007. http://www.maricopa.gov/aq/divisions/planning_ana ly sis/emissions_inventory/reports/Default.aspx

San Joaquin Valley APCD. 2006. Conservation Management Prac tices Program Report for 2005 . San Joaquin Valley Air Pollution Control District. January 19, 2006. http://www.valleyair.org/farmpermits/updates/cmp_program_report_for_2005.pdf

URS. 2001. Technical Support Document for Quantification of Agricultural Best Management Practices, Revised Final Draft . ADEQ Contract No. 98-0159-BF. URS Corporation and Eastern Research Group, Inc. June 8, 2001. http://www.azda.gov/ACT/AgBMP_SIP_TSD-URSrpt6-01.pdf

USDA. 2002. The Census of Agriculture – Year 2002 . United States Department of Agriculture, National Agricultural Statistics Service. http://www.agcensus.usda.gov/Publicati ons/2002/Census_by _Sta te/Arizona/index.asp

USDA. 2005. Arizona Agricultural Statistics – Year 2004 . United States Department of Agriculture, National Agricultural Statistics Service. September 2005. http://www.nass.usda.gov/Statisti cs_by _State/Arizona/index.aspAttachment - 1ATTACHMENT #1Table A-1 provides detailed data on the individual control measures, specific crops affected by the control measures, emissionfactors,emissions, control efficiencies, and potential emissions reductionsfrom the Maricopa County BMPs and San Joaquin CMPs that were evaluated.Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)CL CROPLAND – LANDPREPARATION /CULTIVATIONCL2Bed/Row Size orSpacing:(EF - LandPrep)32,696Citrus4,464 0.07 312 0% 9% 0 28Corn6,241 6.90 43,063 0% 12% 0 5168Cotton9,841 8.90 87,585 0% 9% 0 7883Onions336 6.50 2,184 0% 12% 0 262Wheat18,200 4.45 80,990 0% 16% 0 12958Barley7,537 4.45 33,540 0% 16% 0 5366Lettuce96 12.75 1,224 0% 6% 0 73Melons6,529 5.70 37,215 0% 2% 0 744Vegetables 2,352 9.05 21,286 0% 1% 0 213CL3Chemigation/Fertigation:(EF - LandPrep)No data atthis time17,555Alfalfa36,004 4.00 144,016 0% 2% 0 2880Citrus4,464 0.07 312 0% 9% 0 28Corn6,241 6.90 43,063 0% 1% 0 431Cotton9,841 8.90 87,585 0% 9% 0 7883Onions336 6.50 2,184 0% 6% 0 131Attachment-2Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)Wheat8,737 4.45 38,880 0% 8% 0 3110Barley7,537 4.45 33,540 0% 8% 0 2683Lettuce96 12.75 1,224 0% 3% 0 37Melons6,529 5.70 37,215 0% 1% 0 372CL4Combined Operations:18,621Combining landpreparation operations(EF - LandPrep)Cotton9,841 8.9 87,585 8% 0% 7007 0Wheat8,737 4.45 38,880 8% 0% 3110 0Barley7,537 4.45 33,540 8% 0% 2683 0Corn6,241 6.9 43,063 8% 0% 3445 0Vegetables2,352 9.05 21,286 11% 0% 2341 0Citrus4,464 0.07 312 11% 0% 34 0CL5ConservationIrrigation:(EF - LandPrep)34,599Alfalfa36,004 4.00 144,016 0% 6% 0 8641Citrus4,464 0.07 312 0% 9% 0 28Corn6,241 6.90 43,063 0% 12% 0 5168Cotton9,841 8.90 87,585 0% 9% 0 7883Onions336 6.50 2,184 0% 12% 0 262Wheat8,737 4.45 38,880 0% 16% 0 6221Barley7,537 4.45 33,540 0% 16% 0 5366Lettuce96 12.75 1,224 0% 6% 0 73Melons6,529 5.70 37,215 0% 2% 0 744Vegetables2,352 9.05 21,286 0% 1% 0 213Attachment-3Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)CL6Conservation Tillage:(EF - LandPrep)(25% -100%ReducedTillage)166,935 60,270Corn6,241 6.90 43,063 63% 35% 27,130 15072Cotton9,841 8.90 87,585 63% 28% 55178 24524Onions336 6.50 2,184 63% 4% 1376 87Wheat8,737 4.45 38,880 63% 16% 24494 6221Barley7,537 4.45 33,540 63% 16% 21130 5366Lettuce96 12.75 1,224 63% 5% 771 61Melons6,529 5.70 37,215 63% 4% 23446 1489Vegetables2,352 9.05 21,286 63% 35% 13410 7450CL7Cover Crops:(EF - LandPrep)134Citrus4,464 0.07 312 43% 27% 134 84CL8EquipmentChanges/TechnologicalImprovements:(EF - LandPrep)50% 50%132,644 132,644Citrus 4,464 0.07 312 50% 50% 156 156Corn 6,241 6.90 43,063 50% 50% 21531 21531Cotton 9,841 8.90 87,585 50% 50% 43792 43792Onions 336 6.50 2,184 50% 50% 1092 1092Wheat 8,737 4.45 38,880 50% 50% 19440 19440Barley 7,537 4.45 33,540 50% 50% 16770 16770Lettuce 96 12.75 1,224 50% 50% 612 612Melons 6,529 5.70 37,215 50% 50% 18608 18608Vegetables 2,352 9.05 21,286 50% 50% 10643 10643Attachment-4Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)CL11Integrated PestManagement:(EF - LandPrep)21,809Corn6,241 6.90 43,063 0% 12% 0 5168Cotton9,841 8.90 87,585 0% 19% 0 16641CL12Limited ActivityDuring a High-WindEvent:(EF - LandPrep)49,887Cotton9,841 8.9 87,585 9% 0% 7883 0Wheat8,737 4.45 38,880 9% 0% 3499 0barley7,537 4.45 33,540 9% 0% 3019 0Corn6,241 6.9 43,063 9% 0% 3876 0Alfalfa36,004 4 144,016 20% 0% 28803 0Vegetables2,352 9.05 21,286 13% 0% 2767 0Citrus4,464 0.07 312 13% 0% 41 0CL13Mulching:(EF - LandPrep)23,930Corn6,241 6.9 43,063 0% 12% 0 5,168Onions336 6.5 2,184 0% 18% 0 393Wheat8,737 4.45 38,880 0% 0.80% 0 311Barley7,537 4.45 33,540 0% 8% 0 2683Lettuce96 12.75 1,224 0% 9% 0 110Melons6,529 5.7 37,215 0% 21% 0 7815Vegetables2,352 9.05 21,286 0% 35% 0 7450CL14Multi-Year Crop:(EF - LandPrep)32,491Attachment-5Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)Cotton9,841 8.9 87,585 16% 0% 14014 0Wheat8,737 4.45 38,880 16% 0% 6221 0Barley7,537 4.45 33,540 16% 0% 5366 0Corn6,241 6.9 43,063 16% 0% 6890 0CL15Night Farming:(EF - LandPrep)26,529Citrus 4,464 0.07 312 0% 10% 0 31Corn 6,241 6.90 43,063 0% 10% 0 4306Cotton 9,841 8.90 87,585 0% 10% 0 8758Onions 336 6.50 2,184 0% 10% 0 218Wheat 8,737 4.45 38,880 0% 10% 0 3888Barley 7,537 4.45 33,540 0% 10% 0 3354Lettuce 96 12.75 1,224 0% 10% 0 122Melons 6,529 5.70 37,215 0% 10% 0 3722Vegetables 2,352 9.05 21,286 0% 10% 0 2129CL16Non-Tillage/ChemicalTillage:(EF - LandPrep)11,615Alfalfa36,004 4 144,016 0% 8% 0 11521Citrus4,464 0.07 312 0% 30% 0 94CL17Organic Practices:(EF - LandPrep)63,398Alfalfa36,004 4.00 144,016 0% 9% 0 12961Citrus4,464 0.07 312 0% 14% 0 44Corn6,241 6.90 43,063 0% 17% 0 7321Cotton9,841 8.90 87,585 0% 18%015765Attachment-6Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)Onions336 6.50 2,184 0% 18% 0 393Wheat8,737 4.45 38,880 0% 16% 0 6221Barley7,537 4.45 33,540 0% 16% 0 5366Lettuce96 12.75 1,224 0% 5% 0 61Melons6,529 5.70 37,215 0% 21% 0 7815Vegetables2,352 9.05 21,286 0% 35% 0 7450CL18Planting Based on SoilMoisture:(EF - LandPrep)30%19Citrus4,464 0.07 312 6% 0% 19 0Corn6,241 6.90 43,063 0% 0% 00Cotton9,841 8.90 87,585 0% 0% 00Onions336 6.50 2,184 0% 0% 00Wheat8,737 4.45 38,880 0% 0% 00Barley7,537 4.45 33,540 0% 0% 00Lettuce96 12.75 1,224 0% 0% 00Melons6,529 5.70 37,215 0% 0% 00Vegetables2,352 9.05 21,286 0% 0% 00CL19Precision Farming:(EF - LandPrep)39,793Citrus4,464 0.07 312 0% 15% 0 47Corn6,241 6.90 43,063 0% 15% 0 6459Cotton9,841 8.90 87,585 0% 15% 0 13138Onions336 6.50 2,184 0% 15% 0 328Wheat8,737 4.45 38,880 0% 15% 0 5832Barley7,537 4.45 33,540 0% 15% 0 5031Lettuce96 12.75 1,224 0% 15% 0 184Melons6,529 5.70 37,215 0% 15% 0 5582Vegetables 2,352 9.05 21,286 0% 15%03193Attachment-7Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)CL20Tillage Based on SoilMoisture:(EF - LandPrep)39,793Citrus4,464 0.07 312 0% 15% 0 47Corn6,241 6.90 43,063 0% 15% 0 6459Cotton9,841 8.90 87,585 0% 15% 0 13138Onions336 6.50 2,184 0% 15% 0 328Wheat8,737 4.45 38,880 0% 15% 0 5832Barley7,537 4.45 33,540 0% 15% 0 5031Lettuce96 12.75 1,224 0% 15% 0 184Melons6,529 5.70 37,215 0% 15% 0 5582Vegetables2,352 9.05 21,286 0% 15% 0 3193CL21Time of Planting:(EF - LandPrep)(50 % -60%Timing ofTillageOperation)No data atthis time145,737Corn 6,241 6.90 43,063 55% 0% 23685 0Cotton 9,841 8.90 87,585 55% 0% 48172 0Onions 336 6.50 2,184 55% 0% 1201 0Wheat 8,737 4.45 38,880 55% 0% 21384 0Barley 7,537 4.45 33,540 55% 0% 18447 0Lettuce 96 12.75 1,224 55% 0% 673 0Melons 6,529 5.70 37,215 55% 0% 20468 0Vegetables 2,352 9.05 21,286 55% 0% 11707 0CL22Timing of TillageOperation:(EF - LandPrep)23,928Cotton9,841 8.9 87,585 10% 0%87580Attachment-8Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)Wheat8,737 4.45 38,880 15% 0% 5832 0Barley7,537 4.45 33,540 15% 0% 5031 0Corn6,241 6.9 43,063 10% 0% 4306 0CL23Transgenic Crops:(EF – LandPrep)21,823Alfalfa36,004 4 144,016 0% 2% 0 2880Corn6,241 6.90 43,063 0% 12% 0 5168Cotton9,841 8.90 87,585 0% 9% 0 7883Onions336 6.50 2,184 0% 12% 0 262Wheat8,737 4.45 38,880 0% 4% 0 1555Barley7,537 4.45 33,540 0% 4% 0 1342Lettuce96 12.75 1,224 0% 6% 0 73Melons6,529 5.70 37,215 0% 2% 0 744Vegetables2,352 9.05 21,286 0% 9% 0 1916CL24Transplanting:(EF – LandPrep)2,996Onions336 6.5 2,184 0% 12% 0 262Lettuce96 12.75 1,224 0% 6% 0 73Melons6,529 5.7 37,215 0% 2% 0 744Vegetables2,352 9.05 21,286 0% 9% 0 1916CH CROPLAND –HARVESTCH1Baling/Large Balers:(EF -Harvest)14,987Attachment-9Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)Alfalfa36,004 0.24 8,641 0% 11% 0 951Wheat8,737 3.45 30,143 0% 25% 0 7536Barley7,537 3.45 26,003 0% 25% 0 6501CH2Combined Operations:(EF -Harvest)26,036Cotton9,841 3.37 33,164 17% 0% 5638 0Wheat8,737 3.45 30,143 34% 0% 10249 0Barley7,537 3.45 26,003 34% 0% 8841 0Corn6,241 0.43 2,684 34% 0% 912 0Vegetables2,352 0.23 541 34% 0% 184 0Citrus4,464 0.14 625 34% 0% 212 0CH4EquipmentChanges/TechnologicalImprovements:(EF -Harvest)51,674 51,674Alfalfa36,004 0.24 8,641 50% 50% 4320 4320Citrus4,464 0.14 625 50% 50% 312 312Corn6,241 0.43 2,684 50% 50% 1342 1342Cotton9,841 3.37 33,164 50% 50% 16582 16582Onions336 1.68 564 50% 50% 282 282Wheat8,737 3.45 30,143 50% 50% 15071 15071Barley7,537 3.45 26,003 50% 50% 13001 13001Lettuce96 0.23 22 50% 50% 11 11Melons6,529 0.23 1,502 50% 50% 751 751CH7Green Chop:(EF -Harvest)25,025Alfalfa36,004 0.24 8,641 0% 10% 0 864Corn Grain and Silage 13,000 0.43 5,590 0% 17%0922Attachment-10Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)Dry Beans, CerealGrains, Safflower,Wheat, and Barley33,900 3.45 116,955 0% 20% 0 23239CH8Hand Harvesting:(EF -Harvest)1,959Citrus4,464 0.14 625 0% 33% 0 206Corn6,241 0.43 2,684 0% 33% 0 886Onions336 1.68 564 0% 33% 0 186Lettuce96 0.23 22 0% 33% 07Melons6,529 0.23 1,502 0% 33% 0 496Vegetables2,352 0.23 541 0% 33% 0 179CH9Night Harvesting:(EF -Harvest)10,335Alfalfa36,004 0.24 8,641 0% 10% 0 864Citrus4,464 0.14 625 0% 10% 0 62Corn6,241 0.43 2,684 0% 10% 0 268Cotton9,841 3.37 33,164 0% 10% 0 3316Onions336 1.68 564 0% 10% 0 56Wheat8,737 3.45 30,143 0% 10% 0 3014Barley7,537 3.45 26,003 0% 10% 0 2600Lettuce96 0.23 22 0% 10% 02Melons6,529 0.23 1,502 0% 10% 0 150CH11Pre-Harvest SoilPreparation:(EF -Harvest)4,919Alfalfa36,004 0.24 8,641 0% 7% 0 605Citrus4,464 0.14 625 0% 10% 0 62Corn6,241 0.43 2,684 0% 5%0134Attachment-11Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)Cotton9,841 3.37 33,164 0% 12% 0 3980Onions336 1.68 564 0% 10% 0 56Wheat8,737 3.45 30,143 0% 0% 00Barley7,537 3.45 26,003 0% 0% 00Lettuce96 0.23 22 0% 0% 00Melons6,529 0.23 1,502 0% 0% 00Vegetables2,352 0.23 541 0% 15% 0 81CH12Reduced HarvestActivity:(EF -Harvest)10,089Cotton9,841 3.37 33,164 20% 0% 6633 0Alfalfa36,004 0.24 8,641 40% 0% 3456 0CH13Shed Packing:(EF -Harvest)274Onions336 1.68 564 0% 12% 0 68Lettuce96 0.23 22 0% 7% 02Melons6,529 0.23 1,502 0% 10% 0 150Vegetables2,352 0.23 541 0% 10% 0 54CH14Shuttle System /Larger Carrier:(EF -Harvest)25,289Alfalfa36,004 0.24 8,641 0% 17% 0 1469Citrus4,464 0.14 625 0% 17% 0 106Corn6,241 0.43 2,684 0% 17% 0 456Cotton9,841 3.37 33,164 0% 40% 0 13266Onions336 1.68 564 0% 17% 0 96Wheat8,737 3.45 30,143 0% 17% 0 5124Barley7,537 3.45 26,003 0% 17% 0 4420Lettuce960.23220% 17%04Attachment-12Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)Melons6,529 0.23 1,502 0% 17% 0 255Vegetables2,352 0.23 541 0% 17% 0 92CO CROPLANDACTIVITIES -OTHERCO1Alternate Tilling:(EF - LandPrep)132,922Alfalfa 36,004 4 144,016 0% 32.50% 0 46805Corn6,241 6.90 43,063 0% 32.50% 0 13995Cotton9,841 8.90 87,585 0% 32.50% 0 28465Onions336 6.50 2,184 0% 32.50% 0 710Wheat8,737 4.45 38,880 0% 32.50% 0 12636Barley7,537 4.45 33,540 0% 32.50% 0 10900Lettuce96 12.75 1,224 0% 32.50% 0 398Melons6,529 5.70 37,215 0% 32.50% 0 12095Vegetables2,352 9.05 21,286 0% 32.50% 0 6918CO2ApplicationEfficiencies:(EF - LandPrep)37,451Alfalfa 36,004 4 144,016 0% 8% 0 11521Corn 6,241 6.90 43,063 0% 12% 0 5168Cotton 9,841 8.90 87,585 0% 9% 0 7883Onions 336 6.50 2,184 0% 12% 0 262Wheat 8,737 4.45 38,880 0% 16% 0 6221Barley 7,537 4.45 33,540 0% 16% 0 5366Lettuce 96 12.75 1,224 0% 6% 0 73Melons 6,529 5.70 37,215 0% 2% 0 744Vegetables 2,352 9.05 21,286 0% 1% 0 213Attachment-13Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)CO3Baling/Large Balers:(EF -Harvest)14,987Alfalfa 36,004 0.24 8,641 0% 11% 0 951Wheat8,737 3.45 30,143 0% 25% 0 7536Barley7,537 3.45 26,003 0% 25% 0 6501CO5Chemigation/Fertigation:(EF - LandPrep)17,555Alfalfa 36,004 4.00 144,016 0% 2% 0 2880Citrus 4,464 0.07 312 0% 9% 0 28Corn 6,241 6.90 43,063 0% 1% 0 431Cotton 9,841 8.90 87,585 0% 9% 0 7883Onions 336 6.50 2,184 0% 6% 0 131Wheat 8,737 4.45 38,880 0% 8% 0 3110Barley 7,537 4.45 33,540 0% 8% 0 2683Lettuce 96 12.75 1,224 0% 3% 0 37Melons 6,529 5.70 37,215 0% 1% 0 372Vegetables 2,352 9.05 21,286 0% 0% 0 0CO6ConservationIrrigation:(EF - LandPrep)34,599Alfalfa 36,004 4.00 144,016 0% 6% 0 8641Citrus 4,464 0.07 312 0% 9% 0 28Corn 6,241 6.90 43,063 0% 12% 0 5168Cotton 9,841 8.90 87,585 0% 9% 0 7883Onions 336 6.50 2,184 0% 12% 0 262Wheat 8,737 4.45 38,880 0% 16% 0 6221Barley 7,537 4.45 33,540 0% 16% 0 5366Lettuce 96 12.75 1,224 0% 6% 0 73Melons 6,529 5.70 37,215 0% 2% 0 744Vegetables 2,352 9.05 21,286 0% 1%0213Attachment-14Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)CO7Cover Crops:(EF - LandPrep)(20% -66%)84Citrus 4,464 0.07 312 43% 27% 134 84CO8Cross-Wind Ridges(reduces wind erosionon cropland):(EF - WindErosionCropland)20% - 93% 2,067,022Citrus 4,464 122.24 545,679 57% 0% 311037 0Corn 6,241 108.05 674,340 57% 0% 384374 0Cotton 9,841 128.84 1,267,914 57% 0% 722711 0Onions 336 122.24 41,073 57% 0% 23411 0Wheat 8,737 0 0 57% 0% 0 0Barley 7,537 0 0 57% 0% 0 0Lettuce 96 122.24 11,735 57% 0% 6689 0Melons 6,529 122.24 798,105 57% 0% 454920 0Vegetables 2,352 122.24 287,508 57% 0% 163880 0CO11Grinding / Chipping /Shredding:(EF - LandPrep)260,109Citrus4,464 0.07 312 0% 90% 0 283Cotton9,841 8.9 87,585 0% 90% 0 79221Alfalfa (under soilincorporation)36,004 4 144,016 0% 97% 0 139033Corn (under soilincorporation)6,241 6.9 43,063 0% 97% 0 41573CO12Integrated PestManagement:(EF - LandPrep)37,479Alfalfa 36,004 4.00 144,016 0% 8% 0 11521Citrus 4,464 0.07 312 0% 9% 0 28Corn 6,241 6.90 43,063 0% 12%05168Attachment-15Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)Cotton 9,841 8.90 87,585 0% 9% 0 7883Onions 336 6.50 2,184 0% 12% 0 262Wheat 8,737 4.45 38,880 0% 16% 0 6221Barley 7,537 4.45 33,540 0% 16% 0 5366Lettuce 96 12.75 1,224 0% 6% 0 73Melons 6,529 5.70 37,215 0% 2% 0 744Vegetables 2,352 9.05 21,286 0% 1% 0 213CO15Mulching:(EF - LandPrep)(50% -55%)94,017 57,652Corn 6,241 6.9 43,063 53% 32.50% 22823 13995Onions 336 6.5 2,184 53% 32.50% 1158 710Wheat 8,737 4.45 38,880 53% 32.50% 20606 12636Barley 7,537 4.45 33,540 53% 32.50% 17776 10900Lettuce 96 12.75 1,224 53% 32.50% 649 398Melons 6,529 5.7 37,215 53% 32.50% 19724 12095Vegetables 2,352 9.05 21,286 53% 32.50% 11281 6918CO16Multi-Year Crop:(EF - LandPrep)48,736Cotton9,841 8.9 87,585 24% 0% 21020 0Wheat8,737 4.45 38,880 24% 0% 9331 0Barley7,537 4.45 33,540 24% 0% 8050 0Corn6,241 6.9 43,063 24% 0% 10335 0CO17Night Farming / NightHarvesting:(EF -Harvest)5,194Alfalfa36,004 0.24 8,641 0% 5% 0 432Citrus4,464 0.14 625 0% 5% 0 31Corn6,241 0.43 2,684 0% 5%0134Attachment-16Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)Cotton9,841 3.37 33,164 0% 5% 0 1658Onions336 1.68 564 0% 5% 0 28Wheat8,737 3.45 30,143 0% 5% 0 1507Barley7,537 3.45 26,003 0% 5% 0 1300Lettuce96 0.23 22 0% 5% 01Melons6,529 0.23 1,502 0% 5% 0 75Vegetables2,352 0.23 541 0% 5% 0 27CO19Non-Tillage/ChemicalTillage:(EF - LandPrep)11,615Alfalfa36,004 4 144,016 0% 8% 0 11521Citrus4,464 0.07 312 0% 30% 0 94CO20Organic Practices:(EF - LandPrep)63,398Alfalfa36,004 4.00 144,016 0% 9% 0 12961Citrus4,464 0.07 312 0% 14% 0 44Corn6,241 6.90 43,063 0% 17% 0 7321Cotton9,841 8.90 87,585 0% 18% 0 15765Onions336 6.50 2,184 0% 18% 0 393Wheat8,737 4.45 38,880 0% 16% 0 6221Barley7,537 4.45 33,540 0% 16% 0 5366Lettuce96 12.75 1,224 0% 5% 0 61Melons6,529 5.70 37,215 0% 21% 0 7815Vegetables2,352 9.05 21,286 0% 35% 0 7450CO22Reduced Pruning:(EF - LandPrep)28Citrus4,464 0.07 312 0% 9% 0 28Attachment-17Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)CO23Residue Management:(EF -Harvest)14,408Cotton9,841 3.37 33,164 12% 0% 3980 0Wheat8,737 3.45 30,143 18% 0% 5426 0Barley7,537 3.45 26,003 18% 0% 4680 0Corn6,241 0.43 2,684 12% 0% 322 0CO24Sequential Cropping:(EF - LandPrep)204,652Alfalfa 36,004 4.00 144,016 50% 0% 72008 0Citrus 4,464 0.07 312 50% 0% 156 0Corn 6,241 6.90 43,063 50% 0% 21531 0Cotton 9,841 8.90 87,585 50% 0% 43792 0Onions 336 6.50 2,184 50% 0% 1092 0Wheat 8,737 4.45 38,880 50% 0% 19440 0Barley 7,537 4.45 33,540 50% 0% 16770 0Lettuce 96 12.75 1,224 50% 0% 612 0Melons 6,529 5.70 37,215 50% 0% 18608 0Vegetables 2,352 9.05 21,286 50% 0% 10643 0CO25Soil Amendments:(EF - LandPrep)81,861Alfalfa 36,004 4.00 144,016 0% 20% 0 28803Citrus 4,464 0.07 312 0% 20% 0 62Corn 6,241 6.90 43,063 0% 20% 0 8613Cotton 9,841 8.90 87,585 0% 20% 0 17517Onions 336 6.50 2,184 0% 20% 0 437Wheat 8,737 4.45 38,880 0% 20% 0 7776Barley 7,537 4.45 33,540 0% 20% 0 6708Lettuce 96 12.75 1,224 0% 20%0245Attachment-18Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)Melons 6,529 5.70 37,215 0% 20% 0 7443Vegetables 2,352 9.05 21,286 0% 20% 0 4257CO26Soil Incorporation:(EF - LandPrep)260,109Citrus4,464 0.07 312 0% 90% 0 283Cotton9,841 8.9 87,585 0% 90% 0 79221Alfalfa (under soilincorporation)36,004 4 144,016 0% 97% 0 139033Corn (under soilincorporation)6,241 6.9 43,063 0% 97% 0 41573CO28Surface Roughening(reduces wind erosionof cropland):(EF - WindErosionCropland)(15% -75%)1,631,860 2,320,867Alfalfa 36,004 0 0 45% 64% 0 0Citrus 4,464 122.24 545,679 45% 64% 245556 349235Corn 6,241 108.05 674,340 45% 64% 303453 431578Cotton 9,841 128.84 1,267,914 45% 64% 570561 811465Onions 336 122.24 41,073 45% 64% 18483 26286Wheat 8,737 0 0 45% 64% 0 0Barley 7,537 0 0 45% 64% 0 0Lettuce 96 122.24 11,735 45% 64% 5281 7510Melons 6,529 122.24 798,105 45% 64% 359147 510787Vegetables 2,352 122.24 287,508 45% 64% 129379 184005CO29Transgenic Crops:(EF - LandPrep)36,159Alfalfa36,004 4 144,016 0% 8% 0 11521Corn6,241 6.9 43,063 0% 12% 0 5168Cotton9,841 8.9 87,585 0% 9%07883Attachment-19Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)Wheat8,737 4.45 38,880 0% 16% 0 6221Barley7,537 4.45 33,540 0% 16% 0 5366CO30aWind Barrier -Artificial (reduceswind erosion ofcropland):(EF - WindErosionCropland)(0% - 90%ArtificialWindBarrier)30%1,631,860 1,087,906Alfalfa 36,004 0 0 45% 30% 0 0Citrus 4,464 122.24 545,679 45% 30% 245556 163704Corn 6,241 108.05 674,340 45% 30% 303453 202302Cotton 9,841 128.84 1,267,914 45% 30% 570561 380374Onions 336 122.24 41,073 45% 30% 18483 12322Wheat 8,737 0 0 45% 30% 0 0Barley 7,537 0 0 45% 30% 0 0Lettuce 96 122.24 11,735 45% 30% 5281 3521Melons 6,529 122.24 798,105 45% 30% 359147 239431Vegetables 2,352 122.24 287,508 45% 30% 129379 86253CO30bWind Barrier -Natural (reduces winderosion of cropland):(EF - WindErosionCropland)(Tree,Shrub, orWindbreakPlanting)25%906,589 1,087,906Alfalfa 36,004 0 0 25% 30% 0 0Citrus 4,464 122.24 545,679 25% 30% 136420 163704Corn 6,241 108.05 674,340 25% 30% 168585 202302Cotton 9,841 128.84 1,267,914 25% 30% 316979 380374Onions 336 122.24 41,073 25% 30% 10268 12322Wheat 8,737 0 0 25% 30% 0 0Barley 7,537 0 0 25% 30% 0 0Lettuce 96 122.24 11,735 25% 30%29343521Attachment-20Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)Melons 6,529 122.24 798,105 25% 30% 199526 239431Vegetables 2,352 122.24 287,508 25% 30% 71877 86253CU CROPLAND –UNPAVED ROADSand UNPAVEDVEHICLEEQUIPMENT AREACU1Dust Suppressants:CU1aChips/mulch:(EF -VehicleTraffic)47,164Alfalfa36,004 0.8 28,803 0% 33% 0 9,505Citrus4,464 2.46 10,981 0% 33% 0 3,624Corn6,241 0.8 4,993 0% 33% 0 1,648Cotton9,841 0.8 7,873 0% 33% 0 2,598Onions336 4.8 1,613 0% 33% 0 532Wheat8,737 2.8 24,464 0% 33% 0 8,073Barley7,537 2.8 21,104 0% 33% 0 6,964Lettuce96 4.8 461 0% 33% 0 152Melons6,529 4.8 31,339 0% 33% 0 10,342Vegetables2,352 4.8 11,290 0% 33% 0 3,726CU1bOrganicmaterials/vegetation:(EF -VehicleTraffic)047,164Alfalfa36,004 0.8 28,803 0% 33% 0 9,505Citrus4,464 2.46 10,981 0% 33% 0 3,624Corn6,241 0.8 4,993 0% 33% 0 1,648Cotton9,841 0.8 7,873 0% 33%02,598Attachment-21Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)Onions336 4.8 1,613 0% 33% 0 532Wheat8,737 2.8 24,464 0% 33% 0 8,073Barley7,537 2.8 21,104 0% 33% 0 6,964Lettuce96 4.8 461 0% 33% 0 152Melons6,529 4.8 31,339 0% 33% 0 10,342Vegetables2,352 4.8 11,290 0% 33% 0 3,726CU1cPolymers:(EF -VehicleTraffic)(47% -99%)104,331 114,336Alfalfa36,004 0.8 28,803 73% 80% 21,026 23,043Citrus4,464 2.46 10,981 73% 80% 8,016 8,785Corn6,241 0.8 4,993 73% 80% 3,645 3,994Cotton9,841 0.8 7,873 73% 80% 5,747 6,298Onions336 4.8 1,613 73% 80% 1,177 1,290Wheat8,737 2.8 24,464 73% 80% 17,858 19,571Barley7,537 2.8 21,104 73% 80% 15,406 16,883Lettuce96 4.8 461 73% 80% 336 369Melons6,529 4.8 31,339 73% 80% 22,878 25,071Vegetables2,352 4.8 11,290 73% 80% 8,241 9,032CU1dRoad Oil:(EF -VehicleTraffic)108,619Alfalfa36,004 0.8 28,803 0% 76% 0 21,890Citrus4,464 2.46 10,981 0% 76% 0 8,346Corn6,241 0.8 4,993 0% 76% 0 3,795Cotton9,841 0.8 7,873 0% 76% 0 5,983Onions3364.8 1,613 0% 76%01,226Attachment-22Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)Wheat8,737 2.8 24,464 0% 76% 0 18,592Barley7,537 2.8 21,104 0% 76% 0 16,039Lettuce96 4.8 461 0% 76% 0 350Melons6,529 4.8 31,339 0% 76% 0 23,818Vegetables2,352 4.8 11,290 0% 76% 0 8,580CU1eSand:(EF -VehicleTraffic)33%47,164Alfalfa36,004 0.8 28,803 0% 33% 0 9,505Citrus4,464 2.46 10,981 0% 33% 0 3,624Corn6,241 0.8 4,993 0% 33% 0 1,648Cotton9,841 0.8 7,873 0% 33% 0 2,598Onions336 4.8 1,613 0% 33% 0 532Wheat8,737 2.8 24,464 0% 33% 0 8,073Barley7,537 2.8 21,104 0% 33% 0 6,964Lettuce96 4.8 461 0% 33% 0 152Melons6,529 4.8 31,339 0% 33% 0 10,342Vegetables2,352 4.8 11,290 0% 33% 0 3,726CU1fGravel:(EF -VehicleTraffic)65,743Alfalfa36,004 0.8 28,803 0% 46% 0 13,249Citrus4,464 2.46 10,981 0% 46% 0 5,051Corn6,241 0.8 4,993 0% 46% 0 2,297Cotton9,841 0.8 7,873 0% 46% 0 3,621Onions336 4.8 1,613 0% 46% 0 742Wheat8,737 2.8 24,464 0% 46%011,253Attachment-23Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)Barley7,537 2.8 21,104 0% 46% 0 9,708Lettuce96 4.8 461 0% 46% 0 212Melons6,529 4.8 31,339 0% 46% 0 14,416Vegetables2,352 4.8 11,290 0% 46% 0 5,193CU3Paving:(EF -VehicleTraffic)0140,061Alfalfa36,004 0.8 28,803 0% 98% 0 28,227Citrus4,464 2.46 10,981 0% 98% 0 10,762Corn6,241 0.8 4,993 0% 98% 0 4,893Cotton9,841 0.8 7,873 0% 98% 0 7,715Onions336 4.8 1,613 0% 98% 0 1,581Wheat8,737 2.8 24,464 0% 98% 0 23,974Barley7,537 2.8 21,104 0% 98% 0 20,682Lettuce96 4.8 461 0% 98% 0 452Melons6,529 4.8 31,339 0% 98% 0 30,712Vegetables2,352 4.8 11,290 0% 98% 0 11,064CU4Restricted Access:(EF -VehicleTraffic)2,858 14,292Alfalfa36,004 0.8 28,803 2% 10% 576 2,880Citrus4,464 2.46 10,981 2% 10% 220 1,098Corn6,241 0.8 4,993 2% 10% 100 499Cotton9,841 0.8 7,873 2% 10% 157 787Onions336 4.8 1,613 2% 10% 32 161Wheat8,737 2.8 24,464 2% 10% 489 2,446Barley7,537 2.8 21,104 2% 10%4222,110Attachment-24Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)Lettuce96 4.8 461 2% 10% 9 46Melons6,529 4.8 31,339 2% 10% 627 3,134Vegetables2,352 4.8 11,290 2% 10% 226 1,129CU5Speed Limits:CU5aReducing speed from25. 9 mph to 5 mph:(EF -VehicleTraffic)60,026 115,765Alfalfa36,004 0.8 28,803 -- 81% 12,097 23,331Citrus4,464 2.46 10,981 -- 81% 4,612 8,895Corn6,241 0.8 4,993 -- 81% 2,097 4,044Cotton9,841 0.8 7,873 -- 81% 3,307 6,377Onions336 4.8 1,613 -- 81% 677 1,306Wheat8,737 2.8 24,464 -- 81% 10,275 19,816Barley7,537 2.8 21,104 -- 81% 8,864 17,094Lettuce96 4.8 461 -- 81% 194 373Melons6,529 4.8 31,339 -- 81% 13,162 25,385Vegetables2,352 4.8 11,290 -- 81% 4,742 9,145CU5bReducing speed from25.9 mph to 10 mph:(EF -VehicleTraffic)58%60,026 82,894Alfalfa36,004 0.8 28,803 -- 58% 12,097 16,706Citrus4,464 2.46 10,981 -- 58% 4,612 6,369Corn6,241 0.8 4,993 -- 58% 2,097 2,896Cotton9,841 0.8 7,873 -- 58% 3,307 4,566Onions336 4.8 1,613 -- 58% 677 935Wheat8,737 2.8 24,464 -- 58% 10,275 14,189Barley7,537 2.8 21,104 -- 58% 8,864 12,240Lettuce964.8461-- 58%194267Attachment-25Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)Melons6,529 4.8 31,339 -- 58% 13,162 18,177Vegetables2,352 4.8 11,290 -- 58% 4,742 6,548CU5cReducing speed from25.9 mph to 15 mph:(EF -VehicleTraffic)60,026 82,894Alfalfa36,004 0.8 28,803 42% 42% 12,097 12,097Citrus4,464 2.46 10,981 42% 42% 4,612 4,612Corn6,241 0.8 4,993 42% 42% 2,097 2,097Cotton9,841 0.8 7,873 42% 42% 3,307 3,307Onions336 4.8 1,613 42% 42% 677 677Wheat8,737 2.8 24,464 42% 42% 10,275 10,275Barley7,537 2.8 21,104 42% 42% 8,864 8,864Lettuce96 4.8 461 42% 42% 194 194Melons6,529 4.8 31,339 42% 42% 13,162 13,162Vegetables2,352 4.8 11,290 42% 42% 4,742 4,742CU5dReducing speed from25.9 to 25 mph:(EF -VehicleTraffic)60,026 4,288Alfalfa36,004 0.8 28,803 -- 3% 12,097 864Citrus4,464 2.46 10,981 -- 3% 4,612 329Corn6,241 0.8 4,993 -- 3% 2,097 150Cotton9,841 0.8 7,873 -- 3% 3,307 236Onions336 4.8 1,613 -- 3% 677 48Wheat8,737 2.8 24,464 -- 3% 10,275 734Barley7,537 2.8 21,104 -- 3% 8,864 633Lettuce96 4.8 461 -- 3% 194 14Melons6,529 4.8 31,339 -- 3%13,162940Attachment-26Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)Vegetables2,352 4.8 11,290 -- 3% 4,742 339CU6Track Out Control:(EF -VehicleTraffic)(85% -95%)(No data atthis time)128,628Alfalfa36,004 0.8 28,803 90% 0% 25,923 0Citrus4,464 2.46 10,981 90% 0% 9,883 0Corn6,241 0.8 4,993 90% 0% 4,494 0Cotton9,841 0.8 7,873 90% 0% 7,086 0Onions336 4.8 1,613 90% 0% 1,452 0Wheat8,737 2.8 24,464 90% 0% 22,017 0Barley7,537 2.8 21,104 90% 0% 18,993 0Lettuce96 4.8 461 90% 0% 415 0Melons6,529 4.8 31,339 90% 0% 28,205 0Vegetables2,352 4.8 11,290 90% 10,161 0CU7Water Application:(EF -VehicleTraffic)(50% -93%)102,902 100,044Alfalfa36,004 0.8 28,803 72% 70% 20,738 20,162Citrus4,464 2.46 10,981 72% 70% 7,907 7,687Corn6,241 0.8 4,993 72% 70% 3,595 3,495Cotton9,841 0.8 7,873 72% 70% 5,668 5,511Onions336 4.8 1,613 72% 70% 1,161 1,129Wheat8,737 2.8 24,464 72% 70% 17,614 17,125Barley7,537 2.8 21,104 72% 70% 15,195 14,773Lettuce96 4.8 461 72% 70% 332 323Melons6,529 4.8 31,339 72% 70% 22,564 21,937Vegetables 2,352 4.8 11,290 72% 70%8,1297,903Attachment-27Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)CU8Wind Barrier -Artificial (reduceswind erosion ofunpaved roads andnon cropland):(EF - WindErosion ofUnpavedRoads & NonCropland)(0% - 90%ArtificialWindBarrier)30%174,621 116,414Alfalfa 36,004 4.64 167,059 45% 30% 75,176 50,118Citrus 4,464 4.21 18,793 45% 30% 8,457 5,638Corn 6,241 4.21 26,275 45% 30% 11,824 7,882Cotton 9,841 6.93 68,198 45% 30% 30,689 20,459Onions 336 4.21 1,415 45% 30% 637 424Wheat 8,737 4.21 36,783 45% 30% 16,552 11,035Barley 7,537 4.21 31,731 45% 30% 14,279 9,519Lettuce 96 4.21 404 45% 30% 182 121Melons 6,529 4.21 27,487 45% 30% 12,369 8,246Vegetables 2,352 4.21 9,902 45% 30% 4,456 2,971CU9Wind Barrier -Natural (reduces winderosion of unpavedroads and noncropland):(EF - WindErosion ofUnpavedRoads &NonCropland)Tree,Shrub, orWindbreakPlanting)25%97,012 116,414Alfalfa36,004 4.64 167,059 25% 30% 41,765 50,118Citrus4,464 4.21 18,793 25% 30% 4,698 5,638Corn6,241 4.21 26,275 25% 30% 6,569 7,882Cotton9,841 6.93 68,198 25% 30% 17,050 20,459Onions336 4.21 1,415 25% 30% 354 424Wheat8,737 4.21 36,783 25% 30% 9,196 11,035Barley7,537 4.21 31,731 25% 30% 7,933 9,519Lettuce96 4.21 404 25% 30% 101 121Melons6,529 4.21 27,487 25% 30%6,8728,246Attachment-28Table A-1 – Potential PM10Emission Reductions by Control Measure and Associated CropIDControl Measure byAssociated CropAcres byCrop / LandUse(MaricopaCounty PM10NonattainmentArea)PM10EmissionFactor(lbs / acre/yr)UncontrolledPM10Emissions(lbs/yr)MaricopaBMPControlEfficiency(%)San JoaquinCMPControlEfficiency(%)PM10EmissionReductionFromMaricopaBMPs(lbs/yr)PM10EmissionReductionFrom SanJoaquinCMPs(lbs/yr)Vegetables2,352 4.21 9,902 25% 30% 2,475 2,971

# APPENDIX C

Agricultural Best Manageme nt Practices Guidance

Booklet and Pocket Guide

# Guide to Agricultural PM10 Best Management Practices

“Agriculture Improving Air Quality”

Governor’s Agricultural Best Management Practices Committee

Second Edition, 2008

### The Governor’s Agricultural BMP Committee gratefully recognizes, thanks and appreciates the input, review suggestions, and overall support of many individuals and groups involved in this process.

Governor’s Agricultural BMP Committee:

Dan Thelander (Committee Chair), Grain Producer, Chandler Arizona
Wade Accomazzo, Alfalfa Producer, Tolleson, Arizona Don Butler, Director, Arizona Department of Agriculture, Phoenix, Arizona (Designee Brett Cameron, Assistant Director, Agricultural Consultation and Training, Arizona Dept. of Agriculture, Phoenix, Arizona) Alfred Lopez, Citrus Producer, Sun City, Arizona Kevin G. Rogers, Cotton Producer, Mesa, Arizona Will Rousseau, Vegetable Producer, Litchfield Park, Arizona Eugene G. Sander, Vice Provost and Dean, College of Agriculture and Life Sciences, University of Arizona, Tucson, Arizona (Designee Colin Kaltenbach, Director of Agricultural Experiment Stations, University of Arizona, Tucson, Arizona) Stephen A. Owens, Director, Arizona Department of Environmental Quality, Phoenix, Arizona (Designee Nancy Wrona, Director, Air Quality Division, Arizona Department of Environmental Quality, Phoenix, Arizona) Dave McKay, State Conservationist, Natural Resource Conservation Service, Phoenix, Arizona James L. Walworth, Soil Scientist, College of Agriculture and Life Sciences, University of Arizona, Tucson, Arizona



### Ag BMP Technical Work Group:

Rick Ladra (Co-Chair) Cotton Producer, Buckeye, Arizona Kevin G. Rogers (Co-Chair) Cotton Producer, Mesa, Arizona Brett Cameron, Arizona Department of Agriculture, Phoenix, Arizona Kristin Graham-Chavez, Natural Resource Conservation Service, Phoenix, Arizona Pat Clay, Field Market Development Specialist, Maricopa, Arizona Jeannette Fish, Maricopa County Farm Bureau, Phoenix, Arizona Cheryl Goar, Arizona Nursery Association, Phoenix, Arizona Jim Klinker, Arizona Farm Bureau Federation, Higley, Arizona
Rick Lavis, Arizona Cotton Grower’s Association, Phoenix, Arizona Andrea Martin, Arizona Department of Agriculture, Phoenix, Arizona Russell Van Leuven, Arizona Department of Agriculture, Phoenix, Arizona Steven Peplau, Arizona Department of Environmental Quality, Phoenix, Arizona Randy Sedlacek, Arizona Department of Environmental Quality, Phoenix, Arizona Robert L. Shuler, Attorney, Ryley, Carlock & Applewhite, for Western Growers Association Joe Sigg, Arizona Farm Bureau Federation, Higley, Arizona Wienke Tax, EPA Region 9, Tucson, Arizona James L. Walworth, Soil Scientist, University of Arizona, Tucson, Arizona



### Staff assigned to Governor’s Ag BMP Committee:

Deborrah “Corky” Martinkovic, Planning Unit Supervisor Lisa Tomczak, Environmental Program Specialist Air Quality Division, Arizona Department of Environmental Quality, Phoenix, Arizona



### Funding support for printing of this guide was provided by a US Environmental Protection Agency 105 Air Quality Grant to the Arizona Department of Agriculture, Agricultural Consultation and Training Program through the Arizona Department of Environmental Quality, Air Quality Division. 

# Governor’s Agricultural BMP Acknowledments

First Edition 2001

Second Edition 2008

### Where can I learn more?

.............................................................................................................................................................. 4

Introduction

................................................................................................................................................................................. 5
Why is this Guide to Agricultural PM10 Best Management Practices needed?

.......................................................................... 5
Why was the agricultural PM10 general permit created?

............................................................................................................ 5
Who must comply with the agricultural PM10 general permit?

.................................................................................................. 6

What does the farmer have to do?

................................................................................................................................................ 6
When must the agricultural PM10 general permit be implemented?

.......................................................................................... 6
What will happen if I do not comply with the agricultural PM10 general permit?

..................................................................... 6
Where does the agricultural PM10 general permit apply?

........................................................................................................... 6

Soils, PM10, and Air Quality

..................................................................................................................................................... 7

Best Management Practices

....................................................................................................................................................... 8
Category I: Tillage and Harvest

................................................................................................................................................ 9
Cessation of Night Tillage

........................................................................................................................................................... 9
Chemical Irrigation

...................................................................................................................................................................... 9
Combining Tractor Operations

................................................................................................................................................... 10
Equipment Modification

............................................................................................................................................................. 10
Green Chop

................................................................................................................................................................................. 10
Integrated Pest Management

....................................................................................................................................................... 11
Limited Activity during a High-Wind Event

.............................................................................................................................. 11
Multi-Year Crop

.......................................................................................................................................................................... 12
Planting Based on Soil Moisture

................................................................................................................................................. 12
Precision Farming

....................................................................................................................................................................... 13
Reduced Harvest Activity

........................................................................................................................................................... 13
Reduced Tillage System

.............................................................................................................................................................. 13
Tillage Based on Soil Moisture

................................................................................................................................................... 14
Timing of a Tillage Operation

..................................................................................................................................................... 14
Transgenic Crops

........................................................................................................................................................................ 14

Category II: Non-cropland

........................................................................................................................................................ 15

Access Restriction

....................................................................................................................................................................... 15
Aggregate Cover

......................................................................................................................................................................... 15

Artificial Wind Barrier

................................................................................................................................................................ 16
Critical Area Planting

.................................................................................................................................................................. 16
Manure Application

.................................................................................................................................................................... 16
Reduce Vehicle Speed

................................................................................................................................................................. 17
Synthetic Particulate Suppressant

............................................................................................................................................... 17
Track-out Control System

........................................................................................................................................................... 18
Tree, Shrub or Windbreak Planting

............................................................................................................................................. 19
Watering

...................................................................................................................................................................................... 19 

## Guide to Agricultural PM10 Best Management Practices 

## Table of Contents

### Category III: Cropland

............................................................................................................................................................. 20

Artificial Wind Barrier

................................................................................................................................................................ 20
Cover Crop

.................................................................................................................................................................................. 21
Cross-Wind Ridges

..................................................................................................................................................................... 21
Cross-Wind Strip-Cropping

........................................................................................................................................................ 22
Cross-Wind Vegetative Strips

..................................................................................................................................................... 22
Integrated Pest Management

....................................................................................................................................................... 23
Manure Application

.................................................................................................................................................................... 23
Mulching

..................................................................................................................................................................................... 24
Multi-Year Crop

.......................................................................................................................................................................... 24

Permanent Cover

......................................................................................................................................................................... 25
Planting Based on Soil Moisture

................................................................................................................................................. 25
Residue Management

.................................................................................................................................................................. 26
Sequential Cropping

.................................................................................................................................................................... 26
Surface Roughening

.................................................................................................................................................................... 27
Transgenic Crops

........................................................................................................................................................................ 27
Tree, Shrub or Windbreak Planting

............................................................................................................................................. 28
Sample Agricultural BMP General Permit Record

................................................................................................................ 29

PM10 Nonattainment Area & Area A Map

....................................................................................................................... Insert 

## Guide to Agricultural PM10 Best Management Practices 

## Table of Contents

### -- 

## If you do not know whether your agricultural operation resides within the PM10 Nonattainment Area, or if you have questions regarding compliance or specific components of the agricultural PM10 general permit, contact:

Arizona Department of Agriculture Agricultural Consultation & Training

1688 W. Adams St.
Phoenix, AZ 85007

602-5 4 2-3 4 8 4

800-29 4 -0308 www.azda.gov/ACT/AirQuality.htm

Agua-Fria New River NRCD

16251 W. Glendale Ave. Litchfield Park, AZ 853 4 0

602-771- 4 162 www.nrcd.org/aguafria/

Arizona Cotton Growers Association

4 139 E. Broadway Rd.
Phoenix, AZ 85040

602- 4 37-13 44



## a cga1@aol.com

Arizona Nursery Association 1430 W. Broadway Rd.

Suite#110 Tempe, AZ 85282

4 80-966-1610

www.azna.org

Buckeye Valley NRCD

220 N. 4 th 

### St. Buckeye, AZ 85326

602-386-7350 www.nrcd.org/buckeyevalley/ Arizona Department of Environmental Quality Air Quality Division 1110 W. Washington St.
Phoenix, AZ 85007

602-771-2300

800-23 4 -5677 www.azdeq.gov/environ/air/index.html

East Maricopa NRCD

18256 E. Williams Field Rd.

Suite #1 Higley, AZ 86236

4 80-988-1078 www.nrcd.org/eastmaricopa/

FSA Service Center Office Maricopa County Farm Service Agency

12 4 09 W. Indian School Rd. Building B Ste. 201
Avondale, AZ 85323

623-535-5055 ext 2 www.fsa.usda.gov/az/

Maricopa County Cooperative Extension 4341 E. Broadway Rd.
Phoenix, AZ 85040

602- 4 70-8086 

## www.cals.arizona.edu/maricopa/

Maricopa County Farm Bureau 4001 E. Broadway Rd.

Suite #B9
Phoenix, AZ 85040

602- 4 37-1330 MCFB@qwestoffice.net 

## Where can I learn more?

### 5 

## Why is the Guide to Agricultural PM10

Best Management Practices needed?

The Federal Clean Air Act requires that emissions from all significant sources in areas not meeting the national ambient air quality standards be controlled through effective programs. Through a study conducted by the Arizona Department of Environmental Quality (ADEQ) in 1995, agricultural activities were identified as a source that contributes to the production of particulate matter
(PM).

PM10 is particulate matter that is 10 micrometers or less in diameter (as compared to a human hair that is about 70 micrometers). These particles are very small

and can invade the natural defense mechanism of the human respiratory tract, penetrating deep into the lungs. Consequently, PM10 can cause a wide variety of harmful health effects, especially for children, the elderly, and people with pre-existing respiratory or cardiovascular

disease.

With this threat to human health, coupled with repeated
violations of the federal health standard for PM10, public agencies and industry groups in the Phoenix metropolitan area have developed and are implementing programs to help the area meet the federal clean air

standards for PM10.

The intent of this guide is to:

• Provide agricultural operators with information and guidance on how to effectively implement individual best management practices (BMPs).

• Inform the general public about the efforts Maricopa County farmers are implementing to improve air quality.

• Provide Natural Resource Conservation Districts (NRCD) and other farm organizations with background information regarding the agricultural PM10 general permit.

Provide regulators with information and guidance on how to determine compliance with the agricultural PM10 general permit. • Why was the agricultural PM10 general permit created?

The Phoenix metropolitan area has not met the Federal

Clean Air Act Standards for PM10 since the Clean Air Act was revised in 1990. On June 10, 1996, the U.S. Environmental Protection Agency (EPA) redesignated
the Moderate PM10 Nonattainment Area to Serious, resulting in the need for emission reduction programs for previously unregulated sources, such as unpaved roads, unpaved parking lots, vacant lots and agriculture. On August 3, 1998, EPA issued a federal implementation plan (FIP) addressing these unregulated sources. The FIP included requirements to develop and enforce control measures for these source categories.

To address agriculture’s contribution to PM10, the Governor’s Agricultural Best Management Practices Committee was created by law in 1998 (Arizona Revised Statutes (A.R.S.) § 4 9- 4 57). The Committee’s charge was to develop an agricultural PM10 general permit that would include controls on agricultural operations. The Committee was to identify BMPs that focused on feasible, effective and common sense practices that minimized negative impacts on local agriculture. In the original program, the agricultural PM10 general permit required that at least one BMP be implemented to control PM10 for each of the following three categories: tillage and harvest, non-cropland and cropland. In 2007, the Arizona State Legislature passed Senate Bill 1552, changing the number of BMPs required from one to

two BMPs per category. The Committee is composed of five local farmers, the Director of ADEQ, the Director of Arizona’s Department of Agriculture, the State

Conservationist for the Natural Resources Conservation Service (NRCS), the Dean of the University of Arizona College of Agriculture and Life Sciences, and a soil taxonomist from the University of Arizona. After A.R.S. § 4 9- 4 57 was developed and adopted, EPA removed the portion of the Federal Implementation Plan for agriculture on June 29, 1999 [6 4 Federal Register p.
34726]. 

## Introduction

### - - 

## Who must comply with the agricultural PM10 general permit?

Any farmer who farms more than 10 contiguous acres of land located within the Maricopa PM10 Nonattainment Area and Maricopa County Portion of Area A (reference map insert) must comply with the agricultural PM10 general permit.

What does the farmer have to do?

• Implement and maintain at least two approved BMPs (described later in this document) for eachof the three categories: tillage and harvest, noncropland and cropland.

• Keep records detailing the BMPs selected for each category. The commercial farmer may document the practice on the sample BMP agricultural PM10 permit record or develop a record that includes the information required by the agricultural PM10 general permit. The commercial farmer must make
available the record to the ADEQ director within two business days of notice to the farmer.

• The Committee recommends additional record keeping if implementation of the BMPs is not easily visible. Examples of additional record keeping include, but are not limited to, photographs, purchase records, receipts, job sheets, contractor invoices, employee timesheets, logs, narrative statements, individual farm policies, statements of understanding signed by employees or contractors, and training records.

• No fee is associated with the agricultural PM10 general permit.

When must the agricultural PM10

general permit be implemented?

A farmer engaged in agricultural activities before June 10, 2000 must comply with the agricultural PM10 general permit by December 31, 2001. A commercial farmer who engages in agricultural activities after December 31, 2000, has 18 months to comply with the agricultural PM10 general permit.

Legislation enacted in 2007 requires that all farmers engaged in agricultural activities must comply with the agricultural PM10 program by December 31, 2007, as revised by the Governor’s Agricultural BMP

Committee. What would happen if I do not comply with the agricultural PM10 general permit?

If the ADEQ director determined that a commercial farmer is not in compliance with the agricultural PM10 general permit, the following three-stage process would

occur: If the farmer has not previously been subject to an agricultural general permit related compliance order, the farmer would be required to submit a plan to the local NRCD. The plan must specify the BMPs that the farmer would use to comply with the general permit.

If the farmer has previously been subject to an agricultural PM10 general permit related compliance order, the farmer would be required to submit a plan to ADEQ that specifies the BMPs that the farmer would use to comply with the general permit.

If the farmer failed to comply with the plan submitted to NRCD and ADEQ, the director of ADEQ may revoke the agricultural PM10 general permit and require the farmer to obtain an individual fee based permit.

At each stage, the farmer would have the opportunity

for a hearing.

Where does the agricultural PM10 general permit apply?

Any agricultural operation greater than 10 contiguous acres within the Maricopa PM10 Nonattainment Area and Maricopa County Portion of Area A (reference map insert), except on tribal lands, must comply with the agricultural PM10 general permit. 1.

2.

3.

### - - 

## Soils consist of various particles including mineral matter, organic matter, air, and water. These particles vary in shape and size, ranging from large drops of liquid to microscopic dust particles. The mineral particles in soil are classified as sand, silt, or clay. Soils containing high amounts of clay coupled with large silt particles have a greater likelihood of generating PM10.

When the natural soil structure is manipulated or disturbed by tillage, animals, weather, or vehicular traffic, the structure can be broken apart from larger pieces, or clods, into smaller pieces. This process significantly increases the potential for soil particles to become suspended in the air. Further manipulation of the soil increases the chance for smaller particles to become

PM10.

Air quality problems occur when the amount of particles released into the air increase in concentration. Large concentrations of PM10 could potentially violate one of the federal air quality standards, or National Ambient Air Quality Standards (NAAQS), set for various air pollutants. The current NAAQS standard for PM10 is 150 micrograms/cubic meter averaged over 24 hours. This standard is a concentration by weight measure. PM10 emissions can also cause visibility impairment (e.g., Brown Cloud) as well as health impacts. The small particles can pass through nostril hairs and enter the lungs, penetrating deep into the lung tissue where it is lodged and not easily, if ever, expelled.

Two meteorological events have the potential to increase the impacts from high concentrations of PM10: high winds and stagnation. Conditions for both of these events can occur in the Phoenix area, one occurring predominantly in the warmer season, the other in the cooler season. Warm season high wind events are generally short (less than one hour) and are the result of the downdrafts from monsoon thunderstorms. The cool season events are longer (six to 12 hours) and are the result of strong pressure gradients associated with a trough or a cold front. An inversion is a region in the atmosphere where the temperature increases with height. The presence of an inversion creates a very stable atmosphere and leads to very little mixing of the air, trapping pollutants close to the ground. An inversion is also produced whenever radiation from the surface exceeds the amount of radiation from the sun – commonly at night or in the winter when the angle of the sun is very low in the sky . Some of the best management practices

outlined in this booklet address how to lower PM10 so these events do not increase PM10 concentrations.

Disturbed soil that is broken down into smaller particles can also become a soil conservation problem. Many of the best management practices outlined in this booklet are already used to prevent soil erosion. Other best management practices address ways of limiting PM10 from associated farming activities such as adjoining dirt roads 

## Soils, PM10 and Air Quality

### - - 

## or road shoulders on farmland. The manipulation or disturbance of soil is inherent to the practice of farming. Best management practices are not designed to eliminate particle emissions 100 percent, but they are designed to reduce

the activities that can lead to the increased concentration of PM10.

As a result of discussions between the EPA, Arizona Department of Environmental Quality, and the Arizona Department of Agriculture, the Arizona State Legislature in 1999 enacted legislation with the full support of the Arizona agriculture community to create and implement a Best Management Practice Program. The Agricultural Best Management Practice Program allows growers a wide range of choices to reduce PM10 emissions within the established Maricopa PM10 Nonattainment Area and Maricopa County Portion of Area A (reference map insert).

The Arizona Legislature has defined a BMP for the Maricopa PM10 Nonattainment Area and Maricopa County Portion of Area A (reference map insert) as a technique verified by scientific research that is practical, economically feasible and effective in reducing PM10 on a case by case basis from a regulated agricultural activity. The following section summarizes the BMPs approved by the Governor’s Agricultural Best Management Practices Committee to reduce PM10 for each of the three agricultural categories: tillage and harvest, non-cropland and cropland. A wide range of variation in soils and cropping systems exists within the Maricopa PM10 Nonattainment Area and Maricopa County Portion of Area A (reference map insert), which can only be addressed by a wide range of flexible and adaptable management practices. Most methods for controlling PM10 emissions parallel the controls for wind erosion. These methods are based on principles that contain or slow soil movement from fields. Not all of the BMPs will work equally well on every farm because of variations in wind, soils, cropping systems, moisture conditions and, in some cases, the management approaches of individual growers. Such factors should be considered by the individual farmer to ensure he or she implements effective BMPs. This guide represents steps in helping farmers reduce PM10 emissions from farmlands located within the Maricopa PM10 Nonattainment Area and Maricopa County Portion of Area A (reference map insert). 

## Best Management Practices

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## Any mechanical practice that physically disturbs cropland or crops on a commercial farm.

Best management practices for use during tillage and harvest

Cessation of Night Tillage Chemical Irrigation Combining Tractor Operations Equipment Modification Green Chop Integrated Pest Management Limited Activity during a High-Wind Event Multi-Year Crop Planting Based on Soil Moisture Precision Farming Reduced Harvest Activity Reduced Tillage System Tillage Based on Soil Moisture Timing of a Tillage Operation Transgenic Crops



## Cessation of Night Tillage

Rule Definition

“Cessation of Night Tilling” means the discontinuance of night tilling on high pollution advisory ( hpa ) days during stagnant air conditions. See night tilling rule definition.

Purpose

Cessation of night tillage between 2:00 a.m. and 8:00 a.m. to decrease the concentrations of PM emissions at night when stagnant air conditions with little if any vertical mixing of the air occurs and a high pollution advisory has been given.

Suggestions for Implementation

An individual farm policy should be developed to ensure that no tillage activities occur during stagnant air conditions on HPA days. Notification of HPAs are broadcast by noon of the day prior to the HPA in the media, by e-mail, and by text message. Employees should receive training in implementing the farm policy.



## Chemical Irrigation

Rule Definition

“Chemical Irrigation” means applying fertilizer, pesticide, or other agricultural chemicals to cropland through an irrigation system.

Purpose

Chemical irrigation reduces the number of passes across a field with tractors, sprayers, fertilizer applicators and machinery. Reducing the number of field operations reduces the emissions associated with those activities.

Suggestions for Implementation

All prod uct application recommendations should be followed to ensure proper im plementation. The field operations eliminated should be documented to demonstrate the implementation of the practice. •

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## Category 1: Tillage and Harvest

### -10- 

## Combining Tractor Operations

Rule Definition

“Combining Tractor Operations” means performing two or more tillage, cultivation, planting, or harvesting operations with a single tractor or harvester pass.

Purpose

Combining tractor operations reduces the number of passes or trips that a tractor, implement, harvester or other farming support vehicle makes across a field or unpaved surface, thereby reducing the amount of soil disturbed.

Suggestions for Implementation

C ombining tractor operations is most effective if implem ented during the time of year when PM10 is most likely to be produced. Applying fertilizer and herbicide in a single pass. Cultivating and fertilizing in a single pass. Using specialized machinery to bury stalks make new furrows in a single pass. Combining multiple heavy tillage operations in a single pass, for example, pulling a ring roller behind a disc.



## Equipment Modification

Rule Definition

“Equipment Modification” means modifying agricultural equipment to prevent or reduce particulate matter generation from cropland.

Purpose

Modifying and maintaining an existing piece of agricultural equipment or purchasing new equipment to prevent PM10 from becoming airborne during tillage and harvest operations, which helps reduce PM10 and soil erosion.

Examples of Equipment Modification

Shields or deflec tors that redirect fan or vehicle exhaust sideways or upward. This can prevent PM10 from becoming airborne because exhaust is not blowing downward on the soil surface. Dust shrouds around tillage implements and harvesters. Spray bars that emit a mist to knock down PM10.



## Green Chop

Rule Definition

“Green Chop” means the harvesting of a forage crop without allowing it to dry in the field.

Purpose

Green chop reduces multiple equipment passes in-field as well as reduces soil disturbance and soil compaction.

Examples of Green Chop

• Alfalfa

• Winter forage

• Silage corn •

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## Integrated Pest Management

Rule Definition “Integrated Pest Management” means the use of a combination of techniques including organic, conventional and biological farming practices.

Purpose Integrated pest management creates beneficial insect habitat that reduces the use of herbicides/ pesticides, thereby reducing the number of passes for spraying. It also reduces soil compaction and the need for additional tillage.

Examples of Integrated Pest Management

Monitoring crop for pests to accurately and effectively apply control measures

. Incorporate biological practices into farming operation to reduce need for spraying.



## Limited Activity during a High-Wind Event

Rule Definition

“Limited activity during a High-Wind Event” means performing no tillage or soil preparation activity when the measured wind speed at 6 feet in height is more than 25 mph at the commercial farm site.

Purpose

Because this BMP falls within the tillage and harvest category, it also applies during harvest time. Wind speed, temperature and relative humidity affect the distance that PM10 travels and the ability for PM10 to be suspended in the air. Limiting activity during a high-wind event will reduce the transport of PM10. Reducing farm operations during a high wind event, as well as when the wind speed is less than 25 mph, can significantly help reduce PM10

emissions.

Suggestions for Implementation A device to measure wind speed should be available at the commercial farm site. An individual farm policy should be developed to ensure that no tillage or soil preparation activities occur when the wind speed reaches 25 mph. Employees and family members should receive training in implementing the farm policy. Subscribe to the Dust Action Forecast issued by ADEQ. Notification of Dust Action Forecasts are broadcast by

mi d­ -morning of the day prior to the high-wind event. •

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## Multi-Year Crop

Rule Definition

“Multi-Year Crop” means a crop, pasture, or orchard that is grown, or will be grown, on a continuous basis for more than one year.

Purpose

Surface covers, such as crops, pasture and orchards that are grown and maintained for a long duration, protect the soil surface from erosive winds. The longer a crop or cover is protecting the soil surface, the less time the surface is susceptible to wind erosion.

Examples of Multi-Year Crops include

Alfalfa

Citrus

Roses Livestock pastures
Nuts (Pecans)

Sod



## Planting Based on Soil Moisture

Rule Definition

“Planting Based on Soil Moisture” means applying water to soil before performing planting operations.

Purpose

Planting based on soil moisture reduces PM10 during the planting operation and is effective from the time of planting until crop establishment. Planting based on soil moisture is one of the most efficient practices to reduce PM10 between planting and crop emergence. Moisture causes soil to crust and therefore PM10 is not easily transported into the air.

Suggestions for Implementation

Care should be taken to avoid over compaction of the soil, which could result in additional tillage operations. Irrigation should be applied as soon after soil preparation for planting as possible. After watering, a thin crust develops on the soil surface, which stabilizes it until planting. The time between bed lifting, irrigation and planting should be minimized as much as possible. Use the soil moisture “feel method” to determine adequate soil moisture. See the Natural Resource Conservation Service Publication #1619 “Estimating Soil Moisture by Feel and Appearance.” This publication is available at

all NRCD offices. •

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## Precision Farming

Rule Definition “Precision Farming” means using GPS to precisely guide farm equipment in the

field. Purpose Precision farming reduces overlap and allows operations to occur during inclement weather conditions and at night thereby generating less PM. Examples of Precision Farming Install overlap reduction technology

Pass markers Variable rate application technology



## Reduced H arvest Activi ty

Rule Definitio n
“Reduced Harvest Activity” means reducing the number of harvest passes using a mechanized method to cut and remove crops from a field.

Purpose

Any time an operation takes place in a field, the soil structure can be modified and some PM10 could be released into the air. Reducing the number of harvest activities can keep the soil structure intact and reduce

PM10.

Suggestions for Implementation

An example of reduced harvest activity is the elimination of a harvest or rood pass from a cotton harvest. More PM10 is emitted during a normal cotton harvest season because the process requires several harvest passes to remove most of the crop from the plant. The rood process produces a significant amount of PM10 because of the nature of the operation.



## Reduced Tillage System

Rule Definition

“Reduced Tillage System” means reducing the number of tillage operations used to produce a crop.

Purpose

Any tillage operation in a field can modify the soil structure and possibly release PM10 into the air . Reducing the number of tillage activities can maintain the soil structure and help reduce PM10.

Suggestions for Implementation Minimum tillage system* Mulch tillage system* Reduced tillage system*

*Consult NRCS Standard and Specifications, 329 and 3 44 , Residue Management. This document is available at all

NRCD offices. •

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### -1 4

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## Tillage Based on Soil Moisture

Rule Definition

“Tillage Based on Soil Moisture” means applying water to soil before or during tillage, or delaying tillage to coincide with precipitation.

Purpose

Moisture binds soil particles and helps reduce the amount of PM10 released into the air. Fine dry soil can easily erode with increased wind speeds. Sufficient moisture levels can be achieved by irrigating before tillage or tilling after rain. Moisture can also allow large soil clods to form, after tillage, which reduces wind erosion.

Suggestions for Implementation Fields should be irrigated to the depth of proposed cut prior to soil disruption, or tillage should be conducted to coincide with precipitation. The application of moisture or the date of tillage that coincided with precipitation should be documented. The soil moisture “feel method” should be used as a way to determine adequate soil moisture. See the Natural Resource Conservation Service publication #1619 “Estimating Soil Moisture by Feel and Appearance”. This publication is available at all NRCD offices.



## Timing of a Tillage Operation

Rule Definition

“Timing of a Tillage Operation” means performing tillage operations at a time that will minimize the soil’s susceptibility to generate PM10.

Purpose

Adjusting the time of tillage operations can minimize the amount of time the soil surface is susceptible to wind erosion and generation of PM10. When a field’s surface is smooth, dry, and consists of finer grained soil particles, the field is most susceptible to wind erosion, resulting in PM10.

Some examples of timing of tillage operations to reduce PM10 generation include:

Reducing time between leveling (land planing) and bedding, which is when the beds act as miniature windbreaks. For example, a cotton production system where fields are tilled in the fall, land planed, and then bedded, would be less susceptible to wind erosion and PM10. Leaving the field surface with large soil clods for as long as possible prior to preparation of seed beds.



## Transgenic Crops

Rule Definition

“Transgenic Crops” means the use of plants that are genetically modified.

Purpose

Transgenic crops reduce need for tillage or cultivation operations, as well as reduces soil disturbance. Can also reduce the number of chemical applications.

Examples of Transgenic Crops

Genetically altered seed

Nematode resistant rootstock •

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## Any commercial farm land that:

• Is no longer used for agricultural production,

• Is no longer suitable for production of crops,

• Is subject to a restrictive easement or contract that prohibits use for the production of crops, or includes a private farm road, ditch, ditch bank, equipment yard, storage yard or well head.

Best management practices for use on non-cropland

Access Restriction Aggregate Cover

Artificial Wind Barrier Critical Area Planting Manure Application Reduce Vehicle Speed Synthetic Particulate Suppressant Track-out Control System Tree, Shrub or Windbreak Planting
Watering



## Access Restriction

Rule Definition

“Access Restriction” means restricting or eliminating public access to non-cropland with signs or physical

obstruction. Purpose Reducing the number of trips driven on agricultural aprons and access roads can reduce that area’s susceptibility to PM10.

Examples of methods to restrict access include, but are not limited to:

• Installing physical barriers such as gates, fencing, posts, signs, shrubs, trees or other physical obstructions to prevent or control access to the area.

• Installing “no trespassing” or “limited use area” signs.



## Aggregate Cover

Rule Definition

“Aggregate Cover” means gravel, concrete, recycled road base, caliche or other similar material applied to noncropland.

Purpose

Applying an aggregate cover to unpaved farm roads, parking areas and canal banks helps reduce the amount of soil particles exposed to the surface, thus helping to reduce the generation of PM10. Aggregate cover acts as a surface

barrier to erosive forces like wind or vehicle traffic.

Suggestions for Implementation
The aggregate s hould be one inch or larger in diameter. The aggregate should be applied a minimum of four inches deep. The aggregate material should be clean, hard and durable. •

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• CATEGORY II: Non-Cropland

### -16- 

## Artificial Wind Barrier

Rule Definition

“Artificial Wind Barrier” means a physical barrier to the wind.

Purpose

Artificial wind barriers disrupt the erosive flow of wind over unprotected areas thus helping to reduce PM10.

Suggestions for Implementation Continuous board fences, burlap fences, crate walls, bales of hay and similar material can be used to control air currents and blowing soil. Barriers should be aligned across the prevailing wind direction. While 90 degrees or perpendicular is preferred, benefits can still be realized when barriers are aligned as close to perpendicular as possible. The distance of 10 times the barrier height is considered the protected area downwind of the barrier.



## Critical Area Planting

Rule Definition

“Critical Area Planting” means using trees, shrubs, vines, grasses, or other vegetative cover on non-cropland.

Purpose

Critical area planting helps control soil movement and protect the soil surface when adequate cover does not exist. Ground covers reduce dust and wind erosion by shielding the soil with vegetation and anchoring the soil with roots. This practice applies to field aprons, equipment parking areas, turn rows, canal banks, canal excavation spoil piles and bare areas where vegetation is difficult to establish by usual planting methods.

Suggestions for Implementation

Critical area planting consists of any vegetative cover that maintains more than 60 percent ground cover.



## Manure Application

Rule Definition

“Manure Application” means applying animal waste or biosolids to a soil surface.

Purpose

Applying manure to maintain or improve chemical and biological condition of the soil can help reduce wind erosion

and PM10.

Suggestions for Implementation

If the application or storage of manure is near a water source, precautions should be taken to prevent accidental leakage, spillage or runoff that will result in undesirable effects on soil, water and plants. Caution should be used when applying manure to ensure that state and local regulations are not violated. Caution should be used when certain manures are applied as they can volatilize and contribute to odor and

ammonia emissions. Manures should be incorporated as quickly as possible to reduce odor and ammonia emissions, and to preserve nutrient value if the area is to be cropped in the future. •

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## Reduce Vehicle Speed

Rule Definition

“Reduce Vehicle Speed” means operating farm vehicles or farm equipment on unpaved private farm roads at speeds not to exceed 20 mph.

Purpose

Reduced speeds can decrease the amount of PM10 generated by vehicles or equipment on unpaved farm roads.

Examples of methods to reduce vehicle speed include, but are not limited to:

• Posting speed limit signs.

• Informing all employees, contractors and sub-contractors of speed limits.

• Placing signs in all farm vehicles stating the speed limits on farm roads.

• Installing speed bumps.



## Synthetic Particulate Suppressant

Rule Definition

“Synthetic Particulate Suppressant” means a manufactured product such as lignosulfate, calcium chloride, magnesium chloride, an emulsion of a petroleum product, an enzyme product, and polyacrylamide that is used to control particulate matter.

Purpose

Synthetic particulate suppressants provide a surface barrier or bind soil particles together to retard PM10 on unprotected areas, such as unpaved roads, rights-of-way and abandoned fields.

Examples of synthetic particulate suppressant include, but are not limited to:

• Calcium chloride (CaCl)

• Soybean feedstock (SBF) processing byproducts

• Calcium lignosulfonate (lignin)

• Polyvinyl acrylic polymer emulsion (PVA)

• Polyacrymide (PAM)

• Emulsified petroleum resin

Differences in traffic type and volume, soil types, roadway surface characteristics and topography between sites requiring dust control can cause product performance to vary . Consult the NRCD office or a dust control contractor for specific recommendations. All products should be applied strictly in accordance with manufacturers’ specifications.

### -18- 

## Track-out Control System

Rule Definition

“Track-out Control System” means a device to remove mud or soil from a vehicle before the vehicle enters a paved public road.

Purpose

Using a track-out control system helps remove mud and soil from the tires of farm equipment and vehicles before they enter a paved public road, where the mud or soil can be crushed into fine particles and easily suspended in the air by passing vehicles.

Suggestions for Implementation

Some examples of track-out control systems are: Grizzly - a device similar to a cattle guard, which is used to dislodge mud, dirt or debris from the tires and undercarriage of equipment and vehicles prior to leaving a farm. Gravel pad - a pad of crushed stone, coarse gravel or recycled road base located at the point of intersection of a paved public roadway and a farm entrance.

It is recommended that:

a) The stone or gravel is one inch or larger in diameter. b) The gravel pad is applied a minimum of four inches deep. c) The gravel pad is the full width of the farm entrance. d) The gravel pad is a minimum of 50 feet long.

Pave ment – an area of asphalt, concrete or similar material applied to a farm road at the intersection of a paved public roadway and a farm entrance.

It is recommended that:

a) The pavement is the width of the farm road. b) The pavement is a minimum of 100 feet long from the point of intersection with a paved public roadway.

The farm entrance should be maintained in a condition that will prevent tracking of mud and soil onto paved public roads. The farmer should conduct periodic inspections, maintenance, re-application of gravel and cleaning of paved access road surfaces to accomplish track-out control. •

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## Tree, Shrub, or Windbreak Planting

Rule Definition

“Tree, Shrub, or Windbreak Planting” means providing a woody vegetative barrier to the wind.

Purpose Barriers placed perpendicular to the wind direction can reduce wind speeds by changing the pattern of airflow over the land surface, which helps reduce wind erosion and PM10.

Suggestions for Implementation

• The distance of 10 times the barrier height is considered the protected

area downwind of the barrier.

• Single row plantings are most popular in field windbreaks because they use less water and occupy the least amount of land area for the amount of protection derived.

• Recommended species for planting can be obtained at all NRCD

offices.

• The planting should be done at a time and manner to ensure survival and growth of selected species.

• Moisture conservation or supplemental watering should be provided for plant establishment and growth, as well as the use of drought tolerant species.

• Windbreaks should be aligned across the prevailing wind direction. While 90 degrees or perpendicular is preferred, benefits can still be realized when windbreaks are aligned as close to perpendicular as possible.

• The interval between windbreaks should be determined using current approved wind erosion technology

, available at all NRCD offices.



## Watering

Rule Definition

“Watering” means applying water to non-cropland.

Purpose

Applying water from a truck, tractor or other portable spray system to bare soil surfaces, such as unpaved roadways and equipment yards where high traffic areas exist, can help reduce PM10. W atering the soil surface tends to compact the soil so that it is not dispersed into the air.

Suggestions for Implementation

Watering is effective during peak usage times, such as silage harvest time.

• Apply water so that the surface is visibly moist.

### -20- 

## Land on a commercial farm that:

•	 Is within the timeframe of final harvest to plant emergence,

• Has been tilled in a prior year and is suitable for crop production, but is currently fallow, or

• Is a turn-row.



## Best management practices for use on cropland

Artificial Wind Barrier
Cover Crop
Cross-Wind Ridges
Cross-Wind Strip-Cropping
Cross-Wind Vegetative Strips
Integrated Pest Management
Manure Application
Mulching
Multi-Year Crop

Permanent Cover
Planting Based on Soil Moisture
Residue Management
Sequential Cropping
Surface Roughening
Transgenic Crops
Tree, Shrub, or Windbreak planting



## Artificial Wind Barrier

Rule Definition

“Artificial Wind Barrier” means a physical barrier to the wind.

Purpose

Artificial wind barriers disrupt the erosive flow of wind over unprotected cropland fields thus helping to reduce

PM10.

Suggestions for Implementation

Continuous board fences, burlap fences, cr ate walls, bales of hay and similar material can be used to control air currents and blowing soil. Barriers should be aligned across the prevailing wind direction. While 90 degrees or perpendicular is preferred, benefits can still be realized when barriers are aligned as close to perpendicular as possible. The distance of 10 times the barrier height is considered the protected area downwind of the barrier. •

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## CATEGORY III: Cropland

### -21- 

## Cover Crop

Rule Definition

“Cover Crop” means plants or a green manure crop grown for seasonal soil protection or soil improvement.

Purpose

Cover crops help control soil movement and protect the soil surface between crops. Cover crop reduces wind erosion by shielding the soil with vegetation and anchoring the soil with roots.

Suggestions for Implementation

It is recommended that: Cover crops consist of any vegetative cover that maintains more than 60 percent ground cover. Short-term cover be grown between major crops. Plants are then tilled into the soil prior to or during major crop planting. Longer-term cover may be maintained by periodic mowing to maintain at least 60 percent cover. Specific information on cover crops can be obtained from the Cooperative Extension Service or the NRCD office.



## Cross-Wind Ridges

Rule Definition

“Cross-Wind Ridges” means soil ridges formed by a tillage operation.

Purpose

Ridges formed by tillage operations create protective windbreaks that disrupt the erosive forces of high winds.

Suggestions for Implementation

It is recommended that: Ridges formed by tillage or planting should be aligned across the prevailing wind direction. While 90 degrees or perpendicular is preferred, benefits can still be realized with ridges as close to perpendicular as possible. If ridges deteriorate and become ineffective due to weathering or erosion, they should be reestablished, unless doing so would damage a growing crop. This practice is best adapted on soils, which are stable enough to sustain effective ridges, such as clayey, silty and sandy loam soils. It is not well adapted on unstable soils, such as sands, loamy sands and certain organic

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## Cross-Wind Strip-Cropping

Rule Definition

“Cross-Wind Strip-Cropping” means planting strips of alternating crops within the same field.

Purpose

Growing crops or managing residue as a protective cover in strips across the prevailing wind direction can break the effects of high wind events.

Suggestions for Implementation

It is recommended that: Cross-wind strip-cropping system consists of at least two crop or residue cover alternating strips. Strip widths should be at least 25 feet but no more than 330 feet. Strips should be aligned across the prevailing wind direction. While 90 degrees or perpendicular is preferred, benefits can still be realized when the strips are oriented as close to perpendicular as possible. Protective cover includes, but is not limited to a growing crop, grasses, legumes, grass-legume mixtures, standing stubble or tilled residue with enough surface cover to provide protection.



## Cross-Wind Vegetative Strips

Rule Definition

“Cross-Wind Vegetative Strips” means herbaceous cover established in 1 or more strips within the same field.

Purpose

Herbaceous cover creates a protective windbreak that disrupts the erosive forces of high winds, especially during critical wind erosion periods.

Suggestions for Implementation

It is recommended that: Herbaceous cover should be composed of perennial or annual vegetation, growing or dead. Strips consist of at least one row of plants, providing the porosity can be achieved with a single row that contains

no gaps. When two or more rows are required to achieve the required porosity and to avoid gaps, the rows should be spaced no more than 36 inches apart. Annual vegetation strips be composed of more than one row. Strips designed for this purpose have a minimum expected height of two feet. Strips designed for this purpose achieve a minimum porosity of 40 to 50 percent. Spacing between strips (not within row) not exceed 12 times the expected height of the herbaceous cover. Spacing between strips be adjusted to accommodate widths of farm equipment to minimize partial or incomplete

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## Integrated Pest Management

Rule Definition

“Integrated Pest Management” means the use of a combination of techniques including or ganic, conventional and biological farming practices.

Purpose

Integrated pest management creates beneficial insect habitat that reduces the use of herbicides/ pesticides, thereby reducing the number of passes for spraying. It also reduces soil compaction and the need for additional tillage.

Examples of Integrated Pest Management

Monitoring crop for pests to accurately and effectively apply contro l

measures. Incorporate biological practices into farming operation to reduce need for spraying.



## Manure Application

Rule Definition

“Manure Application” means applying animal waste or biosolids to a soil surface.

Purpose

Applying manure to maintain or improve chemical and biological condition of the soil can help reduce wind erosion

and PM10.

Suggestions for Implementation

• If the application or storage of manure is near a water source, precautions should be taken to prevent accidental leakage, spillage or runoff that will result in undesirable effects on soil, water and plants.

• Caution should be used when applying manure to ensure that state and local regulations are not violated.

• Caution should be used when certain manures are applied as they can volatilize and contribute to odor and

ammonia emissions.

• Manures should be incorporated as quickly as possible to reduce odor and ammonia emissions, and to preserve nutrient value if the area is to be cropped in the future. •

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## Mulching

Rule Definition “Mulching” means applying plant residue or other material that is not produced on site to a soil surface.

Purpose Adding a protective layer to the soil surface reduces soil movement in high wind events. This practice also conserves soil moisture, which can reduce surface movement of soil.

Suggestions for Implementation

It is recommended that:

• This practice can be used after low residue producing crops, like cotton, are harvested.

• Materials for mulching are acquired as waste products from other enterprises.

• These include, but are not limited to, wood bark, chips, shavings, and saw dust; food processing wastes; and small grain straw/chaff.

• Mulches are applied by blowers, hydro applicators, disk type straw punchers and spreaders.

• When small grain straw is used, spread at least 4,000 pounds straw per acre, distribute evenly and partially incorporate into the soil.

• When wood fibers are used, spread at least 2,000 pounds per acre or achieve 80 percent cover

.



## Multi-Year Crop

Rule Definition “Multi-Year Crop” means a crop, pasture, or orchard that is grown, or will be grown, on a continuous basis for more than one year.

Purpose Surface covers, such as crops, pasture and orchards, that are grown and maintained for a long duration, protect the soil surface from erosive winds. The longer a crop or cover is protecting the soil surface, the less time the surface is susceptible to wind erosion.

Examples of Multi-Year Crops are:

• Alfalfa

• Citrus

• Roses

• Livestock pastures

• Nuts (Pecans)

• Sod

### -25- 

## Permanent Cover

Rule Definition

“Permanent Cover” means a perennial vegetative cover on cropland.

Purpose

Maintaining a long-term (perennial) vegetative cover on cropland that is temporarily not producing a major crop protects the soil surface from erosive winds.

Suggestions for Implementation

It is recommended that: Perennial species of grasses and/or legumes be used to establish at least 60 percent cover. When perennial species are used, maintenance by periodic mowing or swathing/baling is encouraged. Specific information on permanent cover types can be obtained from the Cooperative Extension Service or all

NRCD offices.



## Planting Based on Soil Moisture

Rule Definition

“Planting Based on Soil Moisture” means applying water to soil before performing planting operations.

Purpose

Planting based on soil moisture reduces PM10 during the planting operation and is effective from the time of planting until crop establishment. Planting based on soil moisture is one of the most efficient practices to reduce PM10 between planting and crop emergence. Moisture causes soil to crust and therefore PM10 is not easily transported into the air.

Suggestions for Implementation

Care should be taken to avoid over compact ion of the soil, which could result in additional tillage operations. Irrigation should be applied as soon after soil preparation for planting as possible. After watering, a thin crust develops on the soil surface, which stabilizes the soil until planting The time between bed lifting, irrigation and planting should be minimized as much as possible. Use the soil moisture “feel method” to determine adequate soil moisture. See the Natural Resource Conservation Service publication #1619 “Estimating Soil Moisture by Feel and Appearance.” This publication is available at

all NRCD offices. •

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### -26- 

## Residue Management

Rule Definition

“Residue Management” means managing the amount and distribution of crop and other plant residues on a soil

surface.

Purpose

Leaving crop and other plant residues on the soil surface can protect the soil between the time of harvest of one crop and emergence of a new crop, thus helping reduce wind erosion and the generation of PM10.

Suggestions for Implementation

Many different residue management systems have been developed. Some examples include: Reduced tillage systems, such as mulch-till, which partially incorporate surface residues and involve no plowing. No-till, this involves planting directly into the soil without any alteration to the seedbed. One example is planting a new crop directly into the grain stubble. Soil protection by crop residues can be increased by leaving residues on the soil surface as long as possible (e.g. by delaying tillage operations until just before planting).

It is recommended that: Stubble be left standing at six inches or more. Tillage be limited during this period to undercutting tools, such as blades, sweeps or deep tillage implements, such as a ripper or subsoiler. Loose residue be uniformly distributed on the soil surface. Residues from previous crops be left to maintain 60 percent ground

cover. Specific information on determining small grain residue equivalents can be obtained from the Cooperative Extension Service or all NRCD

offices. Consult NRCS Standard and Specification for Residue Management, # 329 and 3 44 . This document is available

at all NRCD offices. 

## Sequential Cropping

Rule Definition
“Sequential Cropping” means growing crops in a sequence that minimizes the amount of time bare soil is exposed

on a field.

Purpose

By reducing the amount of time bare soil is exposed, sequential cropping helps reduce the window of time that the cropland is susceptible to PM10 erosion.

Some examples of sequential cropping include: Planting a winter grain crop between final harvest of a cotton crop and the planting of the next cotton crop. Close rotations of vegetable crops.

Suggestions for Implementation

It is recommended that: The amount of time bare soil is exposed be limited to 30 days or less. Rotations be provided for acceptable substitute crops in case of crop failure or shift in planting intentions for

weather related or economic reasons. •

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### -27- 

## Surface Roughening

Rule Definition

“Surface Roughening” means manipulating a soil surface to produce or maintain clods.

Purpose

The formation of clods helps disrupt the erosive force of the wind over an unprotected soil surface. Soil clods can be formed by tillage implements under appropriate soil moisture conditions.

Suggestions for Implementation

Not all soils are able to form clods. Review the local soil survey or contact the NRCD office to help determine a specific field’s soil type. Caution should be used to determine the most opportune time to roughen the soil surface while considering the tillage needed prior to planting, crop to be grown and irrigation water management needs (surface roughening can dry the upper soil profile more rapidly than not disturbing the soil).



## Transgenic Crops

Rule Definition

“Transgenic Crops” means the use of plants that are genetically modified.

Purpose

Transgenic crops reduce the need for tillage or cultivation operations, as well as reduces soil disturbance. Can also reduce the number of chemical applications.

Examples of Transgenic Crops

Genetically altered seed

Nematode resistant rootstock •

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### -28- 

## Tree, Shrub, or Windbreak Planting

Rule Definition

“Tree, Shrub, or Windbreak planting” means providing a woody vegetative barrier to the wind.

Purpose

Barriers placed perpendicular to the wind direction can reduce wind speeds by changing the pattern of airflow over the land surface, which helps to reduce wind erosion and PM10.

Suggestions for Implementation The distance of 10 times the barrier height is considered the protected area downwind of the barrier. Single row plantings are most popular in field windbreaks because they use less water and occupy the least amount of land area for the amount of protection derived. Recommended species for planting can be obtained at all NRCD offices. The planting should be done at a time and manner to insure survival and growth of selected species. Moisture conservation or supplemental watering should be provided for plant establishment and growth, as well as the use of drought tolerant species. Windbreaks should be aligned across the prevailing wind direction. While 90 degrees or perpendicular is preferred, benefits can still be realized when windbreaks are aligned as close to perpendicular as possible. The interval between windbreaks should be determined using current approved wind erosion technology

available at all NRCD offices. •

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•Agricultural Best Management Practices General Permit RecordThe following is an example of a form that you can use or duplicate. You are not required to use this form.Name of commercial farmer________________________________________Date_________________________Mailing or physical address of the commercial farm_______________________________________________________________Phone_______________________________________________________________________________________City____________________________State________Zip_________________Email________________________Selected Best Management Practices. A commercial farmer must implement at leastTWOpractices from each category.CATEGORYI:Tillage&Harvest□Cessation of Night Tilling□Chemical Irrigation□Combining Tractor Operations□Equipment Modification□Green Chop□Integrated Pest Management□Limited Activity during High-wind Events□Multi-year Crop□Planting Based on Soil Moisture□Precision Farming□Reduced Harvest Activity□Reduced Tillage System□Tillage Based on Soil Moisture□Timing of Tillage Operation□Transgenic CropsNotes:CATEGORYII:Non-Cropland□Access Restriction□Aggregate Cover□Artificial Wind-barrier□Critical Area Planting□Manure Application□Reduce Vehicle Speed□Synthetic Particulate Suppressant□Track-out Control System□Tree/Shrub/Windbreak Planting□WateringNotes:CATEGORYIII:Cropland□Artificial Wind-barrier□Cover Crop□Cross-wind Ridges□Cross-wind Strip-cropping□Cross-wind Vegetative Strip□Integrated Pest Management□Manure Application□Mulching□Multi-year Crop□Permanent cover□Planting Based on Soil Moisture□Residue Management□Sequential Cropping□Surface Roughening□Transgenic Crops□Tree/Shrub/Windbreak PlantingNotes:



### -29-Signature:___________________________________________________________

# Stakeholders and Collaborating Partners

Arizona Cotton Growers Association

Arizona Department of Agriculture Arizona Department of Environmental Quality

Arizona Farm Bureau Federation Arizona Nursery Association Maricopa Association of Governments Maricopa County Air Quality Department Maricopa County Farm Bureau

Natural Resource Conservation Districts

USDA Agricultural Research Service

USDA Natural Resources Conservation Service US Environmental Protection Agency Region IX University of Arizona - College of Agriculture and Life Sciences University of Arizona - Cooperative Extension, Maricopa County

Western Growers Association

# APPENDIX D

Public Process

## The Arizona Departm ent of Environmental Quality (ADEQ) will hold a public hearing to receive comments on a proposed revision to the 2001 Agricultu ral Best Management Practices – Maricopa County PM 10 

## Serious Area State Implementation Plan (SIP). In 2007, the Governor’s Agricultural Best Management Practices Committee adopted ne w best management practices (BMPs) to the existing list of BMPs. The Arizona Legislatur e also passed Senate Bill 1552, which doubled the required BMPs per category of agricultural activities and extended the area of application of BMPs. State rules already reflect these changes. ADEQ will submit a revised SIP to the U.S. Environmental Protection Agency (EPA) to reflect the legislative and rule changes. 

# PUBLIC COMMENT AND HEARING NOTICE

ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION

PUBLIC HEARING ON PROPOSED AGRICULTURAL BEST MANAGEMENT

PRACTICES - MARICOPA COUNTY PM 10 

## SERIOUS AREA

STATE IMPLEMENTATION PLAN REVISION

The public hearing on the proposed plan will be held at 3:00 p.m . on Wednesday, Oc tober 28, 2009, at the Arizona Department of Environmental Quality, 1110 West Washington Street, Phoenix, in conference room 145. All interested parties will be given an opportunity at the public hearing to submit relevant comments, data, and views, orally and in writing.

The public comment period for the proposed SIP re vision will end upon the closure of this public hearing or at 5:00 p.m. on Wednesday, October 28, 2009, whichever is later. Comments postmarked on or before that date will be accepted. Comments should be addressed, faxed, or e-mailed to:

Lisa Tomczak Air Quality Planning Section Arizona Department of Environmental Quality 1110 W. Washington Street
Phoenix, AZ 85007 FAX: (602) 771-2366

E-Mail: tomczak.lisa@azdeq.gov

The draft report is also available for review at the location below.

Arizona Department of Environmental Quality First Floor Library 1110 W. Washington Street
Phoenix, Arizona 85007 Lorraine Cona, (602) 771-4335

# Public Hearing Agenda

Printed on recycled paper 

## AIR QUALITY DIVISION

Proposed Maricopa County PM 10 

## Serious Area State Implementation Plan Revision Agricultural Best Management Practices

Arizona Department of Environmental Quality 1110 W. Washington Street, Phoenix, Arizona; Conference Room 145 3:00 p.m.; Wednesday, October 28, 2009

Pursuant to 40 CFR § 51.102 notice is hereby given that the above referenced meeting is open to the public.

1. Welcome and Introductions

2. Purposes of the Oral Proceeding

3. Procedure for Making Public Comment

4. Brief Overview of the proposed SIP revision

5. Question and Answer Period

6. Oral Comment Period

7. Adjournment of Oral Proceeding

Copies of the proposal are available for review at the Arizona Department of Environmental Quality (ADEQ) Library, 1110 W. Washington St., Phoenix, Arizona. For additional information regarding the hearing please call Lisa Tomczak, ADEQ Air Quality Division, at (602) 771-4450 or 1-800-234-5677,

Ext. 771-4450.

Persons with a disability may request a reasonable acco mmodation, such as a sign language interpreter, by contacting Dan Flukas at (602) 771-4795 or 1-800-234- 5677, Ext. 771-4795. Requests should be made as early as possible to allow sufficient time to ma ke the arrangements for the accommodation. This document is available in alternative formats by contacting ADEQ TDD phone number at (602) 771-4829.

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# PROPOSED 2009 REVISION MARICOPA COUNTY PM 10 

# SERIOUS

AREA AGRICULTURAL BEST MANAGEMENT PRACTICES

STATE IMPLEMENTATION PLAN

Oral Proceeding

Hearing Officer Script

October 28, 2009

Wendy Flood: Good afternoon and thank you for coming. I now open this public hearing to receive

comments on the proposed 2009 Revised, Re vision for the Maricopa County PM 10 

## Serious Area –

Agricultural Best Management Practices State Im plementation Plan (SIP) (from this point on,

AgBMP SIP Revision).

It is now Wednesday, October 28, 2009. The lo cation is Room 145, Arizona Department of

Environmental Quality, Phoenix, Arizona. My name is Wendy Flood and I have been appointed by

the Director of the Arizona Department of Envi ronm ental Quality to preside at this proceeding.

The purposes of this proceeding are to provide the public an opportunity to:

1) hear about the substance of the proposed AgBMP SIP,

Corky Martinkovic: AgBMP

Wendy: I’m sorry, what?

Corky: AgBMP

Wendy: AgBMP, excuse me. SIP

2) ask questions regarding the proposed AgBMP SIP, and

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## 3) present oral argum ent, data, and views regard ing the proposed AgBMP SIP in the form of

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## comments on the record.

Lisa Tomczak is here representing the ADEQ Air Quality Planning Section. W ill other ADEQ

employees please introduce themselves?

Ira Domsky: Ira Domsky, Deputy Director, Air Quality Division.

Emily Bonanni: Emily Bonanni, Air Quality Compliance.

Corky Martinkovic: Corky Martinkovic, Air Quality Planning.

Steven Peplau: Steven Peplau, Assessment.

Diane Arnst: Diane Arnst, Planning Section Manager.

Viviene Burns: Viviene Burns, Water Quality Division, Compliance and Enforcement.

The proposed AgBMP SIP was released for pub lic com ment on September 21, 2009. The notices

appeared in the Arizona Republic and the ADEQ website.

The procedure for making a public comment on the record is straightforward. If you wish to

comment, you need to fill out a speaker slip, which is availab le at the sign-in table, and give it to me.

Using speaker slips allows everyone an opportunity to be heard and allows us to m atch the name on

the official record with the comments.

You may also submit written comments to me he re today. Please note, the com ment period on

proposed AgBMP SIP closes at the completion of this public hearing or 5:00 p.m . today, whichever

is later.

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## The agenda for this hearing is sim ple. First, we will present a brief overview of the proposed

AgBMP SIP. Next, I will conduct a question and answer period. The purpose of the question and

answer period is to provide information that m ay help you in making comments on the revision to

the proposed AgBMP SIP. Thirdly, I will conduct th e oral com ment period. At that time, I will

begin to call speakers in the order that I have received speaker slips.

Please be aware that any comments you make at t oday' s hearing that you, please be aware that any

comments you make at today's heari ng that you want the Departm ent to formally consider must be

given either in writing or on the record during the oral comment period of this proceeding.



# * * * * *

At this time, Lisa will give a brief overview of the AgBMP SIP Revision.

Lisa: As detailed in the AgBMP SI P revision, the Maricopa County PM 10 

## Serious

Nonattainment Area has a long and complex regul atory history. On December 31, 2006,

the nonattainment area failed to attain the PM 10 

## NAAQS. Because of the failure to attain,

the Clean Air Act requires t hat emissions in the PM 10 

## nonattainment area be reduced by 5

percent each year until the PM 10 

## standard is attained. This requirement prompted the

Governor’s Agricultural Best Management Prac (cough), Best Management Practices

Committee to research and evaluat e options to further reduce PM 10 

## emissions from

agricultural activities.

The proposed AgBMP SIP revision contains a description of the new five BMPs, a

description of the expanded area of application of the BMP program to include the

Maricopa County portions of the PM 10 

## nonattainment area, and a description of the new

requirements for the number of BMPs required per agricultural category. A brief description

of public outreach activities is also included in this SIP. The new BMPs adopted by the

Committee were selected based on feasibility and e fficacy for the farming community in the

nonattainment area. The new BMPs include cessation of night tillage on high pollution

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## advisor y days, green chop, integrated pest management, precision farming, and transgenic

crops. Senate Bill 1552, passed by the Arizona Legislature in 2007, expanded the area of

application of BMPs to include the Maric opa County portions of Area A and required two

BMPs rather than one BMP to be implem ented per agricultural category.

The new BMPs and the requirements of SB 1552 are reflected in revisions to Arizona

Administrative Code R18-2-610 and 611. The ru les were developed as an exempt rule in

order to be included in the Maricopa Association of Governm ents 2007 Five Percent Plan

for PM-10 for the Maricopa County Nonattainment Area , submitted by ADEQ to EPA on

December 31, December 21, 2007. This SIP revision updates t he Maricopa County PM 10 

## Serious Area SIP for Agricultural Best Managem ent Practices, origi nally submitted to EPA

by ADEQ in June 2001.

This concludes the explanation period of the proceeding on the proposed AgBMP SIP.



# * * * * *

Are there any questions before we move to the oral comment period?



# * * * * *

I now open this proceeding for oral comments.

I do have three speaker slips. Read the whole s lip, right? Rick Lavis, re presenting Arizona Cotton

Growers Association. Do you wish to make oral statement?

Rick Lavis: I do Madam Chairman.

Wendy: Okay.

Rick: Thank you. I appreciate the opportunity to (microphone falls down)

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## So much for having my own microphone. (laughter)

Rick: In concluding my 35 minute remarks. (la ughter) Madam Chairman, thank you very much for

the opportunity to comment on the submission of this proposed SIP to EPA. Since this is basically

an agricultural submission, I am just going to make a few comments.

This program has been in place for almost 13 years. W hen Agriculture was asked to participate in

the 1998 effort, we were 13% of the problem, a nd we agreed to develop on our own, a Best

Management Practices program, which included th ree categories. In each category, we were only

supposed to choose one BMP to utilize as his contribution to the reduction of PM 10 

## emissions in the

nonattainment area.

As you well know, and as your statement in adva nce indicated, EPA in 2007 said you are not doing

enough. So everybody who was involved in the PM 10 

## nonattainment area would have to do more.

Agriculture responded by a number of things they did. (1) T hey evaluated all the existing BMPs that

they had in place to determine their efficacy and e ffectiveness. They decided to add five additional

BMPs, AgBMPs, to that list, which I find in your stat em ent. In addition to that , we agreed to require

the grower to choose two events from each category, instead of just one. In addition, the Department

of Environmental Quality asked us to consider the expansion of the AgBMP program to what is

know as Area A. Although not officially nonattainment , it is certainly a part of the overall area

quality shed that the Department is concerned about.

We talked among ourselves for a l ong period of time and then agreed to expand the BMP program to

Area A in Maricopa County only, because certainly a pa rt of that part A, or Area A (? ). So, in

respect to those decisions, we are, have concl uded that the tons reduction was approxim ately, I

believe, 540 tons, which would be added to that am ount require to meet 5% of our goal for the

submission to EPA.

There has been some issue, not an issue, but a question about our educati onal effort or outreach. I

would like to comment on the fact th at the, Jeannette Fish and the Maricopa County Farm Bureau, as

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## a part of the Ag coalition, put together a progr am to find outreach to all our growers in the

nonattainment area, and I will let her speak to that.

In addition, we did publish a second brochure, which is here, and it was a follow-up to the original

brochure that was issued in 1997 or 1998, when we first got into this program . This, we published

approximately 2700 copies of this brochure, and it was sent to approxim ately 1800 growers in the

county, nonattainment area. It was an effort to m ake sure that everyone was aware and understood

what the new rules were.

Now, we believe that we are contributing (?) to th is ef fort, and we will continue to do so in every

way we can to be a partner in the effort to reduce PM 10 

## emissions in this nonattainment area and

attempt to also reach attainment.

With that, Madam Chairman, thank you very much fo r allowing m e to participate. If you have any

questions, I certainly will be happy to answer them.

Wendy: Seeing no questions for Mr. Lavis, we will move to the next speaker slip. Ms. Jeannette Fish

of the Maricopa County Farm Bureau, do you wish to make an oral statement?

Jeannette Fish: Yes, I do. Thank you. Before I do, I n eed to ask Mr. Lavis, since he handed over to

me the piece of the report which I wrote for him a nd didn’t bring m y own piece of it. Could I please

have that sheet of paper, Mr. Lavis?

Rick: Yeah.

Jeannette: Thank you. Good afternoon, my name is J eannette Fish. I am the Executive Director of

the Maricopa County Farm Bureau. We have approxim ately 900 agricultural members of our

organization within the boundaries of Maricopa C ounty. My com ments will be very short. First of

all, I would like to touch on what Mr. Lavis refe rred to, and that was the educational outreach. In

2008, we held two meetings in the month of May and invited everyone who belongs to Farm Bureau,

the Nursery Association and the Cotton Growers Association, to attend those m eetings. One was

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## held on May 10 th 

## on the West side, at Estrella Mountai n Community College. We counted 55 people

in attendance. On the 22 nd 

## of May, we held one on the East side , at the Arizona Farm Bureau offices.

There were 29 people by my count who were, who a ttended that one. These people, of course, would

have passed that information as they went back to their hom es. That program included an overview

of the Best Management Practices Program, why we needed to do m ore, a presentation on what the

ADEQ inspector does, an update on what was going on with the County rules at that time, which I

did a PowerPoint presentation then from Rusty Van Leuven, of the Agricultural Consultation and

Training Program at the Department of Agriculture on how he could assist them in complying with

these new requirements and then wrap up on what needs to be done by you. In other words, the

farmers. That was done by Kevin Rogers and Dan Thelander.

In addition, the various agricultural organizations printed articles in their publications over the space

of 2007 and 2008. I know my own little newsletter had something about complying with dust

regulations in every issue in both years of 2007 and 2008. In fact, I think that m y members are

getting really tired of hearing from me about that.

In addition, the remainder of my comments are th at we, agriculture, under the new SIP, has doubled

its requirement for the people involved in road cr op f arming in this county. We’ve extended the area

where Best Management Practices must be utilized, specif ically to the west and the southwest parts

of the county. In turn, that therefore expands the num ber of farms and farmers that are involved in

the Best Management Practices Program. We added additional Best Managem ent Practices as Lisa

outlined in her overview, and yet with doing all of th is, we managed to do it by meeting the statutory

requirements to be effective in reducing PM 10 

## that may be generated by agricultural operations and

be economically feasible for the farmers to adopt.

Thank you for the opportunity to comment, and I would be happy to answer any questions.

Wendy: Seeing no questions, the next speaker slip is Mr. Joseph Sigg from the Arizona Farm

Bureau. Do you wish to make oral comment?

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## Joseph Sigg: Yes, I do, Madam Chairman. My name is Joseph Sigg. I represent the Arizona Farm

Bureau. I will not be repetitious. I accept and support the comments that Mr. Lavis and Ms. Fish

have already said. Obviously, we do support the proposition. I want to m ake that very clear.

Agriculture continues to be a part of this pro cess in a cooperative way, and we expect to in the

future. I will be glad to entertain any questions. Thank you.

Wendy: Okay. Seeing no questions, the next speak er is Mr. Robert Shuler from the Western

Growers Association. Do you wish to make oral statement?

Robert Shuler: I do. My name is Robert Shuler. I do represent W estern Growers Association. As the

previous speakers have said, I too support the comme nts that have been m ade by them. We also as

an organization support the revised AgBMPs as well as the proposed statewide, or State

Implementation Plan revisions. With that, I will answer any questions.

Wendy: Okay. Seeing there are no more questions and having no further speaker slips, this

concludes the oral comment period of the proceeding.



# * * * * *

If you have not already submitted written comments, you may submit them to me at this time.

Again, the comment period for this draft report closes at 5:00 p.m. on Wednesday, October 28, 2009.

I have not received any written comments. All speakers have spoken, so thank you for attending.

The time is now 3:27, and I now close this oral proceeding.

### RESPONSIVENESS SUMMARY

to Oral Comments Taken at the Public Hearing and Written Comments Received on the Proposed Agricultural Best Management Prac tices State Implementation Plan Revision

The public hearing on the Proposed Agricultural Best Management Practices State Implementation Plan Revision was held on Wednesday, October 28, 2009, at the Arizona Department of Environmental Quality (ADEQ), conference room 145, 1110 West Wash ington Street, Phoenix, Arizona. Four oral comments were received during the hearing. ADEQ received six written comment during the public comment period, which ended October 28, 2009 . The public comments and ADEQ’s responses are

described below.

Comment 1: In Chapter 3.0, Section 3.1, please provide references for the emission reductions that are cited for each of

the five BMPs.

ADEQ Response: References to the Appendix, “Agricultural Best Management Practices Technical Support Document” will be added to the Agricultural Best Management Practices State Implementation Plan. This technical support document describes the calculation of the emission reductions for the five BMPs.

Comment 2: In Chapter 3.0, Section 3.2, Emission Reductions from Revision to the BMP Program: It is not clear why there is so much emphasize on the “Cessation of Night Tilling” BMP. This is one of five additional BMPs being added to the list of options but it is the only BMP specifically di scussed in Section 3.2.

ADEQ Response: The Cessation of Night Tilling BMP was discussed in more detail than the other BMPs because PM 10 

### emissions generated from ni ght tilling have the potential to sharply increase PM 10 

### concentrations due to strong nighttime inversions trapping these em issions relatively close to the ground.

Comment 3: In Appendix A, Agricultural Best Management Practices Rule: the last page of the rule is missing.

ADEQ Response: ADEQ will submit the full rule with the final submission to EPA.

Comment 4: In Appendix B, Technical Support Document, page 14, first paragraph: the second sentence appears to be

incorrect. The sentence states that “The ‘harvested acres of field crops’, rate of change factor was used to develop projected uncontrolled and controlled em issions for Tillage & Harvest BMPs and Noncropland/Unpaved Farm Roads BMPs, while the ‘harvest ed acres of all crops’ rate of change factor was used to develop projected emissions for the Cropl and/Windblown Agriculture BMPs.” However, inreviewing the calculations it appears that “Harvested acres of all crops” was used to calculate Noncropland/Unpaved Farm Roads emissions and “Harvest ed Acres of Field Crops (2003 as base year)” was used to calculate “Cropland/Windblown emissions”.

### ADEQ Response:

The second sentence was incorrect. It will be revised to read: The “Harvested Ac res of Field Crops” rate of change factor was used to develop projected uncontrolled and controlled em issions for the Tillage & Harvest BMPs, the “Harvested Acres of All Crops” rate of change factor was used to develop projected

uncontrolled and controlled emissions for the Non- cropland / Unpaved Farm Roads BMPs, and the “Harvested Acres of Field Crops (base year 2003)” rate of change factor was used to develop projected

uncontrolled and controlled emissions for the Cropland/Windblown Agriculture BMPs.

Comment 5: In Appendix B, Technical Support Document, page 14, first paragraph: please explain why a 2005 base year rate of change factor for “Harvested Acres of Field Crops” is being used for “Tillage & Harvest BMPs” and a 2003 base year rate of change factor for “Harvested Acres of Field Crops” is being used for “Cropland/Windblown emissions”.

ADEQ Response: The methodology for calculating windblown dust emissions in the MAG 2007 Five Percent Plan (documented in the TSD, Appendix II, Exhibit 3 in Appendices Volume Four) averages wind and activity data for the years 2001-2005. Since 2003 was the midpoint year of this analysis, 2003 was chosen as the base year for calculating the growth factors for agricultural windblown dust emissions.

Comment 6: In Appendix B, Technical Support Document: Attachment #1, Table A-1, page Attachment 24 & 25: The same Maricopa BMP control efficiency (42%) w as used for all speed reduction control measures. The control efficiency for “reducing speed from 25.9 to 5 mph” could not possibly be the same as “reducing speed from 25.9 mph to 25”. The San Joaquin CMP control efficiencies vary based on the speed reduction with larger speed reductions resulting in higher the control efficiencies.

ADEQ Response: Table A-1 was developed to compare Maricopa BM Ps against the San Joaquin CMPs. Since the Maricopa BMP for speed reduction states that speeds should be reduced to 15 mph, and does not include speed reductions other than 15 mph, the same Ma ricopa BMP emission reduction, 42%, was listed for comparison with the other emission reductions list ed for the San Joaquin speed reduction CMPs. However, since using the 42% emission reduction to compare to the San Joaquin CMP speed reductions other than 15 mph can be confusing, Table A-1 will be revised to remove th e 42% emission reductions listed for these other speed reductions for the Maricopa BMPs.