NACAA Fall NACAA Meeting Fall October 29, 2007 Samir Sheikh Perm it S erv ices Manager San Joaquin Va V lley Air Pollution Control lley District

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1 Update on CAFO and Ag Burn Regulations in the San Joaquin Valley NACAA Fall Meeting October 29, 2007 Samir Sheikh Permit Services Manager San Joaquin Valley Air Pollution Control District

2 San Joaquin Valley Hot, sunny summers Ozone Problem C f i Cool, foggy winters PM problem

3 CAFOs in California $7 Billion Business (Annual Gross) Emissions from CAFOs in California 87 tons/day VOC (4%) y ( ) 19 tons/day PM10 (1%) 274 tons per day NH3 (38%) Judged by emissions or money, CAFOs in California are predominantly dairies 57 tons/day VOCs (66% of CAFO emissions) $4 billion income (57% of CAFO $)

4 CAFOs in the SJV Predominantly dairies: 1,500 Dairies (2.6 million head) Also: 275 Beef Feedlots, 800 Chicken Ranches, 30 Turkey Ranches CAFO emissions in SJV 60 tons VOC per day (15% of inventory) 42 tons VOC per day from dairies (11%)

5 Dairies in the SJV But dairies in the San Joaquin Valley aren t only the largest VOC-emitting CAFO, they re the largest VOC-emitting stationary source category in the inventory: Dairies 42 tons/day (11%) Oil and Gas Production 30 tons/day (8%) Food and Ag Processing 11 tons/day (3%) Coatings/Solvents 8 tons/day (2%)

6 Regulation of Dairies in SJV California air permitting mature & stringent But dairies (and other Ag) exempt per State SB 700 lifted Ag air exemption, 1/1/04 SB 700 required (among other things): 1) Permits (emissions > 1/2 major source) 2) Conservation o Management age e Practices ces 3) Temporary offsets exemption 4) CAF emissions reductions so, what happened next??

7 Regulation of Dairies in SJV SJV immediately required permits (currently 400) Pre-construction ti permits for modifying, i expanding, or new CAFOs But, then got sued by the dairy industry! Didn t like the permits timing, emission factors, or BACT When the lawsuit settled: 1. Permits were required 2. VOC emission factor increased (12.8 to 19.3 lb/hd-yr) 3. BACT required (postponed digesters) so where are we today with regulating dairies?

8 Existing Dairy Requirements Rule 4570 (Large CAF Rule)(6/15/06) Reduces VOC/NH3 emissions by requiring best available retrofit mitigation measures Conservation Management Practices (8/19/04) Reduces PM10 emissions by requiring practices on unpaved roads, equipment yards, land prep, harvest, and AFO housing and feeding areas Other stationary source requirements, like engine emission limitations, gas tank requirements, etc. and new/expanding dairies?

9 Dairy BACT Achieved in practice measures for VOC Flush (or vacuum or scrape) lanes 4 times per day Weekly corral scraping or manure removal Many more Achieved in practice measures for PM10 Shade structures in open corrals Upwind/downwind windbreaks Many more Technologically Feasible not yet cost effective Technologically Feasible, not yet cost effective Capture and control of housing, lagoons, silage

10 Ambient Air Quality & Health Risk Assessments Health Risk Analysis Project cannot cause potential health risk to nearby residences/businesses Ambient Air Quality Impact Analysis Project cannot cause detrimental impact on ambient air quality Emission impacts modeled using dispersion models Emissions must be mitigated for project to be approved

11 Emissions Banking/Offsets Ag sources exempt from offsets under SB 700, until reductions are bankable Working on rule that would allow banking of emissions reductions at dairies Must be real, permanent, enforceable, quantifiable, and surplus Reviewing latest research to revise dairy emission factors/controls Will be developed and work shopped in conjunction with dairy ERC banking rule.

12 Update on Implementation Have worked extensively with trade groups and universities to provide outreach/training to dairies Rule 4570/CMP compliance -- >90% Philosophy: Prefer outreach to violations (so that you don t have them in the first place) Have held dozens of assistance workshops Provide assistance during inspections But, have and will issue NOVs to dairies that violate our rules, such as building w/out permits Have issued 80 NOVs, over $300, in fines Work aggressively to bring violators into compliance

13 Open Burning (Rule 4103)

14 District Open Burning Program Rule 4103 Regulates/prohibits open burning of agricultural waste in the San Joaquin Valley Air Basin Smoke Management System Staff analyzes daily air quality impact of open burning. Allocates burn allowances in 103 zones based on impact analysis.

15 Open Burn Ban Schedule Phase I: Diseased crops Phase II: Materials from field crops, prunings, and weed abatement Phase III: Orchard removals and phasedown for rice straw Phase IV: Other materials, vineyard removals, and surface harvested prunings.

16 Recent Major Amendments 6/1/07 Prohibition Prohibit burning of orchard removal materials. 6/1/10 Prohibition Extension Apple, Pear, Quince, Citrus and Fig Crops. Small orchards (<20 acres /yr). Reduce rice burns to 50%.

17 CH&SC Div 26, Postponement of dates if the District determines that (a) there is no economically feasible alternative, (b) there is no long-term biomass funding commitment, (c) issuance of permits not cause a federal air quality violation, and (d) ARB concurs with the District's s determinations.

18 Reasons for 2010 Postponements Apple, Pear, and Quince orchards No feasible alternatives - fire blight. Mulching or transport for chips can spread disease to uninfected trees. Citrus orchards No feasible options - disposal problems. Clay soil in root ball degrades refractory walls in biomass plant. Woody nature of chips makes composting difficult.

19 Reasons for 2010 Postponements Rice Stubble No feasible alternative to burns- disposal problems. Few straw balers and small market. No winter water supply for decomposition. Burning controls disease stem rust. Small orchards (<20 acres) Sometimes, no feasible alternative - difficult to get services to small farms. No economically feasible option: Higher per-acre costs for services due to set-up costs.

20 Some Stats Year Acres PM10 PM2.5 CO NOx SOx VOC tpy tpy tpy tpy tpy tpy ,680 3,770 3,544 31,621 2, , ,686 2,916 2,744 24,646 1, , ,768 2,511 2,361 21,324 1, ,014 and the numbers will continue to drop as the program further develops

21 Got Questions? Samir Sheikh