2. 1 Agriculture Regulations – Engines, CMPS, and Permitting Fall 2009 Sheraz Gill Supervising Permit Services Air Quality Engineer San Joaquin Valley Air Pollution Control District

3. 2 San Joaquin Valley Hot, sunny summers VOC, NOx Ozone Problem Cool, foggy winters Particulate problem

4. 3 What’s the problem? Valley air basin fails federal and state air quality standards. Ozone: smog Serious health risks Nitrogen oxides (NOx) + volatile organic compounds (VOCs) + sunlight and heat. Particulate matter: PM Serious health risks Sulfates, dust, soot, ash, salts and other pollutants

5. 4 District Rule 4702 – Internal Combustion Engines Goal of Rule: lower emissions from existing irrigation and other pump engines. Applies to all stationary and transportable internal combustion (IC) engines greater than 50 bhp including emergency back- up generators.

6. 5 District Rule 4702 – Internal Combustion Engines NOTE: This rule does not apply to mobile equipment that is self propelled (tractors, harvesters, etc.), wind machines, and ag equipment that is towed or mounted on a vehicle and is continuously moved during its operation (sprayers, bailers, etc.).

7. 6 Emission Requirements Diesel Ag Engines Replace Tier 0 with Tier 3 by January 1, 2010 –50-500 HP –501-750 hp but operate less than 1,000 hrs Replace Tier 0 with Tier 4 by January 1, 2011 –Greater than 750 hp but operate less than 1,000 hrs Replace Tier 1 and Tier 2 engines with Tier 4 by 2015 or a 12 years from installation date (but not later than 2018) –If Tier 4 is not available, Tier 3 can be installed without having to install Tier 4 in the future

8. 7 Emission Requirements Diesel Ag Engines Application due dates to replace Tier 0 –Permit applications due July 1, 2009 –Registration Applications due October 1, 2009 For any new engine (non-replacement) –If subject to Permit, obtain Authority to Construct prior to installing engine –If subject to Registration, Submit registration application prior to operation

9. 8 Emission Requirements Spark-Ignited Ag Engines Rich-Burn: –90 ppmvd NOx or 80% reduction –2,000 ppmvd CO –250 ppmvd VOC Lean-Burn: –150 ppmvd NOx or 70% reduction –2,000 ppmvd CO –750 ppmvd VOC Compliance date: January 1, 2009

10. 9 Options for Compliance Option 1 Remove and replace with electrical motor No permit or registration to abide by, No permit or registration fees, No emission control equipment to maintain, & No periodic monitoring or testing of engine and it’s emissions

11. 10 Options for Compliance Option 2 Replace with a Tier 3 (or latest-Tier) diesel certified engine Must emit less (on ppmvd basis) than existing engine For permitted farms, there may be some issues to increase engine size, talk to us Note: an ATC Permit is required prior to modification for permitted farms

12. 11 Options for Compliance Option 3 Limit operation schedule of TIER 0 engine to no more than 200 hrs Non-resettable time meter is required to ensure hours of operation Records shall be kept on a monthly basis Note: an ATC Permit is required prior to modification for permitted farms

13. 12 Options for Compliance Spark-Ignited ONLY Replace/retrofit with lean-burn engine Retrofits from natural gas rich-burn to lean-burn Note: an ATC Permit is required prior to modification for permitted farms

14. 13 Options for Compliance Spark-Ignited ONLY Retrofit rich-burn engine with a 3-way catalyst system Unless certified you shall: –Monitor (Portable NOx analyzer once every 24 months), –Source test every 60 months –Operator perform monthly inspections Note: an ATC Permit is required prior to modification for permitted farms

15. 14 Monitoring/Recordkeeping Monitor: –Operate and maintain per manufacturer –Monitor operational characteristics per manufacturer –Nonresettable operating time meter Record: –Monthly operating log

16. 15 Permit or Registration? Permit is required for all engines that: –Are subject to 4702 (Stationary or transportable IC engines greater than 50 bhp), and –At farms that emit more than 12.5 tons-NOx or VOC/year Soon to be 5 tons-NOx or VOC/year (2010)

17. 16 Permit or Registration? Permit-Exempt Equipment Registration (PEER) is required for all engines that: –Are subject to requirements of 4702 (Stationary or transportable IC engines greater than 50 bhp), and –Do not need permits Farm emits less than 12.5 tons-NOx or VOC/year  Soon to be 5 tons-NOx or VOC/year (2010)

18. 17 Permit or Registration? Subject to Registration if below the following: (based on 12.5 tons-NOx/yr and assuming 2,500 hours operation per year): –Tier 1 – 1,000 total HP engine (65% load) –Tier 2 – 1,235 total HP engine (65% load) –Tier 3 – 1,985 total HP engine (65% load)

19. 18 Upcoming Important Changes Designation to Extreme Non-Attainment EPA approval of District NSR Rule by March 2010 at latest –½ major source goes from 12.5 tons VOCs or NOx to 5 tons of VOC or NOx –Permit applications due 6 months after approval date

20. 19 Upcoming Important Changes Approximate HP exceeding the 5 tons of NOx/yr permitting threshold (assuming 2,500 hours operation per year): –Tier 1 - 400 total HP engine (65% load) –Tier 2 - 495 total HP engine (65% load) –Tier 3 - 795 total HP engine (65% load)

21. 20 Conservation Management Practices (CMP) Plans - Rule 4550 Purpose of Rule to limit fugitive dust emissions from farms The District definition of a Stationary Source still applies, i.e. contiguous and adjacent property. –This means a farmer with multiple sites will have to submit a Conservation Management Practices (CMP) plan for each site.

22. 21 Conservation Management Practices (CMP) Plans - Rule 4550 Applicability: –Greater than 100 acres of crops –Dairies with over 500 mature Cows (Milk and Dry cows) –Feedlot Cattle with over 190 head –Other CAFs CMP Apps were due on Dec. 31, 2004

23. 22 Conservation Management Practices Categories Land Preparation/Cultivation (Cropland) Harvest (Cropland) Other (Cropland) Unpaved Roads Unpaved Vehicle/Equipment Traffic Areas CAFO Manure Handling and Storage

24. 23 CMP Forms Alfalfa Citrus Corn, Grain, and Silage Cotton Dry Beans, Cereal Grains, Safflower, Wheat, and Barley Grapes Nut Crops Onions and Garlic Sugar Beets Tree Fruit Vegetables, Tomatoes, Melons, and Other Dairy Feedlot Poultry Unpaved Roads & Unpaved Vehicle/Equipment Areas

25. 24 Examples of CMPs Chemigation/Fertigation Application of chemicals thru an irrigation system Examples –Addition of herbicide or fertilizer through water application –Aerial application Benefits –Reduces the need to travel in-field for application purposes –Reduces # of passes & soil disturbance –Increases efficiency for application

26. 25 Examples of CMPs Combined Operations Combination of equipment to perform several operations during one pass Examples –Combining cane cutting, discing, and flat-furrowing in a single pass for vineyards –Use of one-pass till equipment in ground preparation or crop tillage, cultivation & fertilization of field crop in a single pass Benefits –Reduces # of passes necessary to cultivate the land –Reduction of soil compaction & time to prepare fields

27. 26 Examples of CMPs Conservation Irrigation Conservation of the quantity of water used Examples –Use of drip or buried line systems –Water flow meters or soil monitoring devices to avoid over- irrigation Benefits –Conserves water –Reduces weed population

28. 27 Examples of CMPs Night Farming & Harvesting Examples –Farm during night time, when it’s dark –Increased humidity may increase soil surface moisture thereby helping contain PM emissions from tillage. Operation at night where practical when moisture content levels are higher and winds are lighter Benefits –Decreases concentration of PM during day –Increase in ambient humidity

29. 28

30. 29 Modifications to CMPS A CMP modification application need to be submitted for any changes not covered by the current CMP for the following: –Change in crop type –Addition/subtraction of crop acreage –Change in Conservation Management Practice (CMP) There is no fee to make changes to your CMP plan

31. 30 CMP Recordkeeping The owner/operator of the farm must keep a copy of all approved CMP plans for five years. Conversely, if a farm is exempt from the CMP Rule, all necessary information to show exemption from the Rule must be maintained.

32. 31 Compliance The District is committed to assisting growers in complying with these rules and regulations. Non-compliance with these rules and regulations may lead to enforcement action with the potential for a penalty.

33. 32 FEES: Permits vs Registration (PEER) Filing FeeAnnual Fee Pre- Construction Permits? BACT? Permits Hourly Process fee $71 app fee due up front 51-99 bhp = $80 100-199 bhp = $117 200-399 bhp = $240 400-799 bhp = $479 800-999 bhp = $602 1,000-4,999 bhp = $749 Yes PEER $24 or $85 $23 or $57No

34. 33 CMP Fees The initial plan fee varies from $74 to $294.00 (depending on the number of animals). The initial plan fee varies from $141.00 to $642.00 (depending on the acreage of the farm). There is a renewal fee of $117 every two years. There is NO CMP fee, if facility has a permit for any equipment.

35. 34 District Grant Funding Heavy-Duty Engine Program –Agricultural Irrigation Pumps Received over 8,000 applications Contracted over $91 million –Agricultural Off-Road Vehicles Received over 2,900 applications Contracted over $12 million

36. 35 Current Funding Opportunities Stationary and portable Ag irrigation pumps –Engine repower (non-Tier 0 engines) –New electric motor purchase Mobile off-road Ag vehicles –Repower & retrofit Forklifts –New electric forklift purchase –Retrofit of LSI forklifts

37. 36 District Resources Small Business Assistance –Modesto (209) 557-6446 –Fresno (559) 230-5888 –Bakersfield (661) 392-5665 Emission Reduction Incentive Program (ERIP) –(559) 230-5800 Ag website (www.valleyair.org)www.valleyair.org –Automated emission calculations –Application Forms

38. 37 Contacts/References Sheraz Gill (559) 230-5900 SJVAPCD www.valleyair.org

39. 38 Ag Workshops Tuesday, 10/27 –9am – San Joaquin Farm Bureau – Stockton –1:30 pm - Stanislaus Ag Center - Modesto –6 pm - Merced County Farm Bureau - Merced Thursday, 10/29 –9 am - Madera Fairgrounds - Madera –1:30 pm - Kerman Community Center - Kerman Tuesday, 11/3 –9 am - Tulare County Farm Bureau - Visalia –1:30 pm - Reedley Community Center - Reedley Wednesday, 11/4 –9 am - UCCE Conference Room -Bakersfield –1:30 pm - Kings Fairgrounds - Hanford