Great Basin Unified Air Pollution Control District: Agricultural Operations

Conservation Management Practices for Farms in Inyo, Mono and Alpine Counties
Agricultural operations along Scenic Highway 395 south of Big Pine, CA

CONSERVATION MANAGEMENT PRACTICES FOR FARMS IN INYO, MONO AND ALPINE COUNTIES PROGRAM DESCRIPTION

The very nature of producing food and fiber crops generates dust and small particulate matter, commonly referred to as PM-10 (Particulate Matter with an average size of 10 microns or less—about one-seventh the diameter of a human hair). For many years farmers have worked to reduce the amount of dust generated from agricultural practices as a means of preserving topsoil, controlling certain dust-loving pest populations and maintaining good neighbor relations.

In California, over the last few years attention has been focused on reducing dust and PM-10 emissions from on-farm activities as part of the effort to help improve the state’s air quality. Many areas of the state will never attain the federal or state PM-10 standards unless agricultural activities implement additional dust control measures. In addition, as more land is developed next to and within agricultural areas, dust that in the past did not impact people in their homes or at their jobs, is now having a direct impact on people’s health. In 2004, the state passed a law known as SB 700 that makes agricultural operations subject to the same air pollution requirements as other commercial and industrial operations and requires farm activities to implement additional measures to control air pollution.

The Great Basin Unified Air Pollution Control District (serving all of Alpine, Inyo and Mono Counties) has adopted rules to control dust emissions from agricultural practices in an effort to attain and maintain the federal and state standards for PM-10. The rules, Rule 502 (Conservation Management Practices) and Rule 307 (Conservation Management Practices Plan Fee), require farmers to implement and document an annual plan to reduce dust and PM-10 emissions from on-farm sources, such as from unpaved roads and equipment yards, during land preparation, harvest activities and from other cultural practices. These plans are known as Conservation Management Practices (CMP) Plans. In order to recover the cost of plan processing and field inspections, the Air District will collect fees from those farms that must comply with the CMP requirement.

►What is required?

Farm operators with 40 acres or more outside of residential areas or 10 acres or more within residential areas (5 or more residences within ¼ mile of farm boundaries) of contiguous, or adjacent, farmland are required to prepare and implement CMP Plans for each crop they farm.

►Conservation Management Practices Plan

A Conservation Management Practice is an activity or practice that farmers will implement on their farms to help reduce dust emissions. Examples of CMPs include activities that reduce or eliminate the need to move or disturb the soil; activities that protect the soil from wind, such as wind breaks and wetting the soil; equipment modifications that physically produce less dust; application of dust suppressants; speed reductions on unpaved roads and yards; alternatives to burning brush or prunings; and activities that reduce agricultural chemical applications through use of integrated pest management practices.

This packet identifies the currently accepted, crop-specific practices to reduce PM-10 emissions in each type of farming activity. The CMPs were developed by Air Districts throughout the state as well as, representatives from the USDA-Natural Resources Conservation Service, Resource Conservation Districts, agricultural organizations and commodity groups, and other state and federal agencies. The latest list of CMPs can also be found on the California Air Pollution Control Officer’s Association (CAPCOA) Agricultural Sources Clearinghouse of Air Pollution Reduction Methods at: www.capcoa.org/Agclearinghouse.

In order to assist farm operators with the preparation of CMP Plans, the District has prepared forms for Alfalfa (CMP 1) and Field and Row Crops (CMP 2). Additional forms for other crops or operations will be prepared as needed or upon request. The use of these forms is optional. Any form of plan that meets the requirements of District Rule 502 may be submitted. Blank forms are included in this handout and may be photocopied as needed. The forms can also be downloaded from the Air District website located at www.gbuapcd.org/farm and filled in electronically.

Depending on the crop, farmers are required to implement five additional CMPs, including one from each of the following categories:

·         Land preparation and cultivation

·         Harvest activities

·         Unpaved roads

·         Unpaved equipment yards

·         Other cultural practices

Confined animal feed operations (CAFOs) are also subject to the requirements of Rule 502. CAFO operators should contact the District before preparing a plan to discuss these requirements.

Each farmer with 40 or more contiguous acres outside residential areas or 10 or more acres near residential areas must complete a CMP Plan. Residential areas are defined as five or more residences within one-quarter mile of the farms boundaries. CMP Plans must include the following information:

1)      a map of the operation that designates where each CMP is being implemented;

2)      the General Information form (CMP A);

3)      the Unpaved Roads and Unpaved Vehicle/ Equipment Areas form (CMP B); and

4)      a form for each crop farmed (numbered CMP forms) [CMP 1, CMP 2]

A list of approved dust suppressants available for use to help reduce PM-10 emissions from unpaved roads and equipment yards is included here.

The CMPs were designed to reduce air pollution and to provide farmers with flexibility in selecting measures. If a CMP in a category can't be implemented, then a grower may select an alternate CMP from another category. To allow flexibility and innovation, there is an "Other" practice in each category, which may be used if the new practice can show equal or greater emission reductions than the currently approved practice, and is approved by the District's Air Pollution Control Officer (APCO).

►Deadlines

The CMP program phases in over a three year period. For agricultural operations in the Owens Valley PM-10 Planning Area (the southern Owens Valley between Tinemaha and Haiwee reservoirs, requirements begin in January 2006. For the Mono Basin and Mammoth Lakes areas, requirements go into effect in January 2007. For the balance of the District, the CMP Plan rule is effective in January 2008. Please contact the District to determine which area your operation falls into.

►Costs and fees

There is a flat fee (call the District to get the current fees quoted) for initial review and approval of a CMP Plan. This covers the cost of District personnel reviewing the plan and the first year of field inspections. The fee must be paid upon submittal of the CMP plan for review.

Every year a CMP Plan annual renewal (call the District to get the current fees quoted)must be submitted to the Air District. The District will invoice approved plan holders for the annual fee. After five years, if there has been no change in the CMP plan and no CMP plan violations, the annual renewal fee will be reduced.

A CMP Plan may be modified and resubmitted to the Air District at no cost anytime a practice or crop has changed. No CMP plan fees will be required if a District Permit to Operate is required for the operation (this would apply to very large operations only).

►Contact information

District staff can assist anyone that needs help with the preparation of a CMP plan. Plans and inquiries should be directed to the District’s Bishop office. For agricultural operation inquiries Email: farm@gbuapcd.org

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