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USDA NRCS Combustion System Improvement of Mobile Engines Guidelines

The United States Department of Agriculture (USDA) Natural Resource Conservation Service (NRCS) Combustion System Improvement of Mobile Engines Guidelines (Guidelines) implements robust administrative requirements for incentive projects based on those in the Carl Moyer Program Guidelines to ensure that emission reductions are surplus, quantifiable, enforceable, and permanent. Although the Guidelines provide for multiple types of combustion system improvements, only those that can be classified as off-road mobile agricultural equipment replacement projects are being claimed for SIP credit at this time.

NRCS Guidelines Documents:

The following is a summary of how NRCS Guidelines ensure emissions reductions are SIP-creditable.

Under the NAQI, page 3 of the CA-NRCS program guidelines specifies that SIP creditable emissions reductions are “achieved from contracts or parts of contracts funded under the air quality initiative [that] are not required by any federal, state, or local regulation, settlement agreement, mitigation requirement, or other legal mandate.” A rule or regulation does not currently exist for off-road mobile agricultural equipment, so the emission reductions resulting from replacing existing mobile off-road agricultural engines funded under the NAQI per Conservation Practice Standard (CPS) 372 - Combustion Systems Improvement are surplus. The FY 2013 National Air Quality Initiative Programs Description is posted on-line at: ftp://ftp-fc.sc.egov.usda.gov/CA/programs/EQIP/2013/2013_EQIP_Air_Quality_Initiative_ProgDesc.pdf. The 2012 CA-NRCS program guidelines are posted on-line at: ftp://ftp-fc.sc.egov.usda.gov/CA/programs/AQI/2012_Combustion_Systems_Improvement_Policy_and_Procedures.pdf

The District provided technical assistance to CA-NRCS in developing their calculation methodologies. The methodologies from the Carl Moyer Program are the basis for components included in CPS-372 and its supporting documents for the NAQI, including the CA-NRCS program guidelines. The District provided technical assistance to CA-NRCS in developing their calculation methodologies, which are consistent with the Carl Moyer Program. The NRCS Field Office Technical Guide places a ten-year lifespan for projects implemented under CPS 372 – Combustion System Improvement, which is also consistent with the Carl Moyer program. A conservation practice lifespan is the minimum time (in years) the implemented practice is expected to be fully functional for its intended purpose (NRCS General Manual, Title 450, Part 401.15) http://directives.sc.egov.usda.gov/viewerFS.aspx?hid=19430
A list of California NRCS practice standard life-spans are posted on-line at: http://efotg.sc.egov.usda.gov/references/public/CA/List_of_Practices_Lifespans_2012-12_CA_Numeric.xlsx
The emission reductions for each project, including projects with multiple old units for one new unit, are calculated using the methodologies outlined in the Carl Moyer Guidelines. Additionally, all equipment engines are inspected to verify they are certified to ARB standards before they are paid out. All equipment engines are cross-referenced against an ARB executive order that verifies the emission of every equipment engine. The NRCS calculation worksheets and emission factors are posted on-line at: ftp://ftp-fc.sc.egov.usda.gov/CA/programs/EQIP/2013/2013_EQIP_Air_Quality_Initiative_Attachments.pdf

The NRCS inspects equipment in proposals prior to contract development to verify the existing mobile off-road agricultural equipment is operational per CPS-372 specifications. Destruction of existing equipment is certified by the disposal operator and participant and date-stamped photos are provided. Certification worksheet is posted on-line at: ftp://ftp-fc.sc.egov.usda.gov/CA/programs/EQIP/2013/2013_EQIP_Air_Quality_Initiative_Attachments.pdf. On an annual basis NRCS reviews at least 5% of all active projects. From these project reviews NRCS verifies that the new equipment is still operational. http://directives.sc.egov.usda.gov/RollupViewer.aspx?hid=25728. Per Subpart C, 512.22, participants have control of the land for the length of the proposed contract through deed, lease, or other written authorization. If the applicant does not own the land, the landowner must give written consent to install, operate, and maintain the practice through the lifespan of the practice. This is conducted through a partnership with the USDA Farm Service Agency, who is responsible for program eligibility support.
Subpart F covers Contract Administration and provides for recovering liquidated damages for certain deviations to a contract. Handling contract violations are addressed in Subpart H where violations of contract terms must be corrected by the participant within a reasonable period of time to comply. If the violation continues, the contract may be terminated and future program participation deferred.

NRCS eligibility is based on the county that the tractor resides in; in this case the tractor has to reside within one of the eight counties of the San Joaquin Valley. Under the NAQI, the NRCS prioritizes applications based on a county’s non-attainment designation within California. Applications received from attainment areas are not eligible. Currently, only the emission reductions originating from within the eight San Joaquin Valley counties are seeking SIP credit under this proposal. The destruction of the existing mobile off-road engines and equipment are verified per CPS 372 specifications, posted on-line at: http://efotg.sc.egov.usda.gov/references/public/CA/372-spec-09-2010.doc. Destruction certification worksheets are posted on-line at: ftp://ftp-fc.sc.egov.usda.gov/CA/programs/EQIP/2013/2013_EQIP_Air_Quality_Initiative_Attachments.pdf. The NRCS also has a stipulation that the tractor has to be tied to the land where it is in use. This requires that the tractor be used 100% of the time in the San Joaquin Valley. Under the NAQI, NRCS staff verifies by site visit the operational condition of the existing mobile off-road agricultural equipment. Destruction of the existing equipment and emissions certification verifications are performed to determine contract compliance.
The NRCS Combustion Systems Improvement of Mobile Engines incentive program is unique from other incentive programs in that NRCS is explicitly prohibited from identifying grantees by name. As directed by the Farm Bill (Food Security Act of 1985 (7 U.S.C. § 608d(2))), NRCS must maintain the confidentiality of information provided by an agricultural producer participating in the NRCS Combustion Systems Improvement of Mobile Engines incentive program. The information is exempt from mandatory disclosure and may not be used in judicial or administrative proceedings without the consent of the person involved.