California Cotton Ginners & Growers Associations

California Citrus Mutual

California Grape and Tree Fruit League

Fresno County Farm Bureau

Nisei Farmers League

April 29, 2005

Mr. Andrew Steckel

Rulemaking Office Chief (AIR-4)

U.S. Environmental Protection Agency, Region IX

75 Hawthorne Street

San Francisco, CA  94105

Re:	Revisions to California State Implementation Plan, San Joaquin
Valley Unified Air Pollution Control District – Particulate Matter
from Agricultural Operations

Dear Mr. Steckel,

On behalf of the agricultural community in the San Joaquin Valley, I
want to thank you for the opportunity to comment on the San Joaquin
Valley Unified Air Pollution Control District’s Rule 4550 –
Conservation Management Practices (CMP).  As stated in EPA’s proposed
approval, this rule contains requirements to control fugitive dust
(PM10) emissions from agricultural operations.   

The agricultural industry understands the impetus and the need for Rule
4550.  It is clearly understood that the San Joaquin Valley is
non-attainment for PM10 and that agriculture is one of many sources of
PM10.  We strongly believe that a workable program has been developed to
address fugitive PM10 from agricultural sources.  In fact, we are of the
strong opinion that Rule 4550 is the most comprehensive and effective
regulation to address agricultural air quality in the nation and, as
such, should be approved by EPA and adopted into the State
Implementation Plan (SIP).  No other program adopted in the country to
control fugitive PM10 emissions from agriculture requires submittal of
the actual CMP plan for each location.  No other adopted program will be
able to so extensively quantify the emissions reductions generated by
the program as the San Joaquin Valley’s.  These emissions reductions
are being extensively reviewed and calculated based on actual acreage
covered, actual crop types grown, CMPs chosen and emissions research
conducted on farms in the San Joaquin Valley.  

The CMP program developed by the San Joaquin Valley Unified Air
Pollution Control District, in concert with the agricultural community,
is truly the most comprehensive program in reducing fugitive PM10 from
farming operations.  The list of CMPS contains over 100 CMPs in some 18
categories and was developed over a 9 month period, during which several
meetings were held with growers, grower representatives, air district
personnel and EPA officials.  In addition, the specific rule went
through an additional 9 months of development, where the public had
their input to the rule and its contents.  The input provided by the
growers will help to ensure success in implementing the rule.  Many
practices have already been demonstrated, and hopefully will be widely
accepted among the grower community.  Innovative ideas such as
conservation tillage not only address air quality, but help growers to
reduce operating costs, thereby helping to promote acceptance among
farmers in the San Joaquin Valley.  

Again, I want to thank you for allowing us to comment on the
SJVUAPCD’s Conservation Management Practice (CMP) Rule.  We
respectfully request that EPA approve the San Joaquin Valley Unified Air
Pollution Control District’s Rule 4550 – Conservation Management
Practices and incorporate said rule into the State Implementation Plan
(SIP).  Should you have any questions regarding these comments, please
contact Roger Isom at (559)252-0684.

Sincerely,

California Cotton Ginners & Growers Associations

California Citrus Mutual

California Grape and Tree Fruit League

Fresno County Farm Bureau

Nisei Farmers League

c:	Wayne Nastri, EPA Region IX

	Kerry Drake, EPA Region IX

	Dave Crow, SJVUAPCD

	Jan Kahn, Kahn, Soares & Conway

Mr. Andrew Steckel

  DATE \@ "MMMM d, yyyy"  January 23, 2006 

Page   PAGE  2 

