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On-Road, page 6 - definition of Ag Operations precludes chipping of
wood waste in the field as an Ag/Forestry operation.  We have
argued with ARB staff for 3 years that chipping of orchard
removals, vine removals, orchard and vine prunings,forest harvested
tops and limbs and related brush and small tree removal are all
standard Ag/Forestry in-the-field operations before transport to a
biomass powerplant.

It makes no sense for ARB to preclude these activities from the
Ag/Forestry definition.  The chipping is simply to put the wood
waste in a transportable form.  You cannot haul the raw material in
a box truck because you cannot generate a sufficient payload to
make the transportation cost affordable.  Hence, the wood waste is
chipped in-the-field and then dumped into a chip van for
transport.

ARB is, in essence, encouraging use of inefficient box trucks that
will require two or three times as many trips to haul ag or
forestry wood waste to a biomass powerplant compared to
in-the-field chipping and using a chip van.