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Supporting Documentation
WRAP Policy on
Enhanced Smoke Management Programs for Visibility
February 2003
WRAP is Jointly Administered by:
Western Governors’ Association National Tribal Environmental Council
[Ed note: This document has been formatted
for 2-sided printing (i.e., duplex printing).]
Supporting Documentation
WRAP Policy on
Enhanced Smoke Management Programs for Visibility
Prepared for:
The Fire Emissions Joint Forum
of the Western Regional Air Partnership
Prepared by:
Rebecca Reynolds Consulting, Inc.
10841 East 155th Place
Brighton, CO 80602
(303) 655-3773
www.rebeccareynolds.biz
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Table of Contents
I. WRAP ESMP Policy Development Process .........................................................I-1
Introduction.........................................................................................................I-3
ESMP Task Team Roster....................................................................................I-7
II. Chronological Record of the WRAP ESMP Policy Development .................... II-1
1) Park City, UT Meeting: September 26, 2001 (Task Team) ................................... II-3
a) Meeting Record................................................................................................. II-5
b) Meeting Product: Compilation of ESMP TT Work Group Products.............. II-11
2) San Diego, CA Meeting: December 4 – 7, 2001 (FEJF/Task Team) .................. II-19
a) Agenda ............................................................................................................ II-21
b) Meeting Record............................................................................................... II-22
c) Handouts: ...................................................................................................... II-43
i) Enhanced Smoke Management Program Document Outline (Draft) ...... II-43
ii) Guidance on ESMP Criteria and Elements DIGEST................................ II-44
iii) WRAP Wildland Fire Elements of a Basic Smoke Management Program
DRAFT – July 10, 2001............................................................................ II-47
3) Portland, OR Meeting: January 7 & 8, 2002 (Task Team) ................................... II-51
a) Agenda ........................................................................................................... II-53
b) Meeting Record............................................................................................... II-54
c) Handouts: ........................................................................................................ II-64
i) Enhanced Smoke Management Program Document Outline (Draft) ....... II-64
ii) Annual Emission Goals Document Outline (Draft) .................................. II-65
4) Denver, CO Meeting: January 16 - 17, 2002 (Writing Sub-Group) ..................... II-67
a) Handout ESMP Guidance Document Draft .................................................... II-69
b) Meeting Product: ESMP Guidance Document Draft (Revised) ..................... II-72
5) Tucson, AZ Meeting: February 5 – 7, 2002 (FEJF/Task Team)........................... II-83
a) Agenda ........................................................................................................... II-85
b) Meeting Record............................................................................................... II-86
6) Boise, ID Meeting: February 28 – March 1, 2002 (Writing Sub-Group) ............. II-91
a) Meeting Product: ESMP Multi-Level Approach Concept Paper.................... II-93
7) Phoenix, AZ Meeting: March 18 & 19, 2002 (Task Team)................................ II-105
a) Agenda ......................................................................................................... II-107
b) Meeting Record............................................................................................. II-108
c) ESMP Document Draft A, Version: 3/12/02 ................................................ II-A-1
8) ESMP TT Co-Chairs Conference Call: March 22, 2002 .................................... II-155
a) Conference Call Record (re: IOC Briefing Results) ..................................... II-157
i
Table of Contents
9) Denver, CO Meeting: April 4 & 5, 2002 (Writing Sub-Group) ......................... II-159
a) ESMP Document Draft B, Version: 4/2/02 .................................................. II-B-1
10) ESMP TT Conference Call: April 29, 2002........................................................ II-211
a) Conference Call Record (re: ESMP Document Draft Approval) ................. II-213
11) Coeur d’Alene, ID Meeting: May 15 – 17, 2002 (FEJF) ................................... II-217
a) Meeting Record ............................................................................................ II-219
b) ESMP Policy Draft C, Version: 5/15/02....................................................... II-C-1
12) ESMP Outreach Review Process ........................................................................ II-287
a) Introduction................................................................................................... II-290
b) Comments Compilation ............................................................................... II-291
c) List of Reviewers .......................................................................................... II-337
13) FEJF Conference Call: July 1, 2002 ................................................................... II-341
a) Conference Call Record (re: ESMP Policy Consensus Approval) ............... II-343
b) ESMP Policy Draft D, Version: 7/1/02......................................................... II-D-1
14) Denver, CO IOC Meeting: July 11, 2002 ........................................................... II-395
a) Meeting Record............................................................................................. II-397
b) ESMP Policy Draft E, Version: 7/8/02 ..........................................................II-E-1
15) Denver, CO WRAP Meeting: July 23-24, 2002 ................................................. II-447
a) Meeting Record (Excerpt of WRAP Meeting Minutes) ............................... II-449
16) FEJF Conference Call: August 20, 2002 ............................................................ II-451
a) Conference Call Record ................................................................................ II-453
b) ESMP Policy Draft F, Version: 8/16/02 ........................................................ II-F-1
17) Tempe, AZ WRAP Meeting: November 12-13, 2003 ........................................ II-499
a) ESMP Policy Draft G, Version: 10/15/02..................................................... II-G-1
III. WRAP ESMP Policy Final Approval: November 12, 2002............................ III-1
Final Consensus Approved Version:
WRAP Policy on Enhanced Smoke Management Programs for Visibility................. III-3
ii
Section I
WRAP ESMP Policy Development Process
WRAP ESMP Policy Development Process I-1
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WRAP ESMP Policy Development Process I-2
Introduction
This document represents a compendium of all materials related to the development of
the WRAP Policy on Enhanced Smoke Management Programs for Visibility (ESMP
Policy). The ESMP Policy has been developed over an eleven-month period by the
Enhanced Smoke Management Task Team (ESMPTT) of the Fire Emissions Joint Forum
(FEJF). The document provides a record of the evolution of the ESMPTT’s approach to
the ESMP Policy as well as the various iterations of the Policy document itself.
The ESMPTT is a group made up of state, tribal, and federal land management and air
quality agency representatives as well as those from industry, agriculture, academia, and
environmental organizations. During this process, the ESMPTT solicited stakeholder and
public input regarding both technical and policy issues. The process used to garner broad
stakeholder review and input is also documented in this report.
The ESMP Policy document, October 15, 2002, was submitted to the WRAP for review
and final approval at its November 2002 board meeting. The consensus-approved ESMP
Policy is provided as the final section of the Supporting Documentation and is posted on
the WRAP website.
Background
The Regional Haze Rule (Rule) requires states to develop implementation plans (SIPs)
for addressing regional haze in the Nation’s 156 mandatory Class I areas. Specifically,
the Rule requires effective management of fire sources. The Rule provides two pathways
for western states to follow as they implement the requirements of the Rule: 1) develop
their regional haze implementation plans per the nationally applicable provisions of
Section 308, or 2) Transport Region states may choose to incorporate the Grand Canyon
Visibility Transport Commission (GCVTC) recommendations into their regional haze
implementation plans under Section 309 of the Rule.
Enhanced smoke management programs are specifically required in Section 309 of the
Rule. However, if a state, under Section 308, has determined that fire emissions are
contributing to visibility impairment and that smoke needs to be addressed in its SIP, then
an enhanced smoke management program is a viable tool to accomplish this goal.
Therefore, the WRAP developed the ESMP Policy for states under both Section 308 and
309 to use to meet the requirements of the Rule.
FEJF-ESMPTT Work Process
To address the implementation of specific sections of the Rule, the Western Regional Air
Partnership (WRAP) has established several Committees and Forums. (See the WRAP
website at www.wrapair.org for Facts about WRAP and a WRAP Organizational Chart.)
The Fire Emissions Joint Forum (FEJF) is charged with addressing both policy and
technical issues concerning smoke effects that are caused by wildland and agricultural
fire on public, tribal and private lands. Further, the FEJF is responsible for developing
ESMP Policy Development Process I-3
tools for the WRAP that will assist states and tribes in the WRAP region in their
implementation of the Rule.
The Enhanced Smoke Management Program Task Team was commissioned at the
September 2001 FEJF meeting in Park City, Utah to develop guidance for states on
establishing enhanced smoke management programs. This was in response to the FEJF
Workplan, Task 2.4.2. Initial discussions on enhanced smoke management programs and
the Task Team process took place at the Park City Meeting. Mike Ziolko and Ann
Acheson agreed to co-chair the Task Team, and Rebecca Reynolds Consulting, Inc. was
contracted to facilitate the process.
From December of 2001 through May 2002, the ESMPTT was active, holding various
meetings and conference calls that are documented herein. As a Task Team of the FEJF,
it was pertinent that the ESMPTT interact on an ongoing basis with the FEJF and non-
members. This was achieved by conducting ESMPTT briefings at all FEJF meetings
during this period. The purpose of the ESMPTT briefings was to submit progress reports
as well as work products to the FEJF and non-members for input and approval.
In addition to the ESMPTT meetings, conference calls and briefings at the FEJF
meetings, the FEJF website was utilized to maintain another avenue of outreach to those
interested in the work of the ESMPTT. The Task Team web page, (located on the WRAP
website under Committees and Forums, Fire Emissions Joint Forum, Task Teams,
Enhanced Smoke Management Programs), was maintained with postings (e.g., meeting
and conference call notes, ESMP drafts, reviewer comments, etc.) to document the
activity of the ESMPTT.
Outreach Process
Once the ESMPTT had finished a complete draft of the ESMP Policy that the FEJF
reviewed and provisionally approved, the Task Team then conducted an outreach process
to solicit broader comment. The reviewer comments received during this process
provided the basis for the revision of the ESMP Policy Draft D that the FEJF approved on
July 1, 2002.
The outreach process included the development of a representative list of over 100
stakeholders and then the solicitation of reviewers’ official comment. This process was
approved by the WRAP’s Initiatives Oversight Committee (IOC) in lieu of public
workshops due to the timeframe of the WRAP approval process and Regional Haze Rule
Section 309 SIP deadlines.
The ESMPTT sent out review materials to 59 stakeholder representatives (see attached
list) who agreed to officially review and comment on the ESMP Policy. The ESMPTT
received comments from 28 of those representatives. All reviewer comment was
compiled into a single document that was posted on the website during the review period,
and is included herein.
ESMP Policy Development Process I-4
The draft ESMP Policy document that was used by reviewers and to which their section,
page and line numbers refer is included here as ESMP Policy Draft C.
Further Policy Development
Subsequent to FEJF consensus approval of the ESMP Policy draft on July 1, 2002, the
document was forwarded to the IOC and the WRAP, both of which convened in Denver,
CO on July 23-24, 2001. Although the basic policy statements were approved with
consensus, it was decided to give a review period for the entire ESMP Policy document
to the WRAP members that would extend to August. At this time, revisions were made to
the ESMP Policy based on the comments received, and then the document (Draft F) was
again approved by the FEJF, with minor revisions.
On October 15, 2002 Draft G of the ESMP Policy was submitted to the WRAP for its
final approval at the November 12-13th board meeting held in Tempe, AZ. The consensus
approved ESMP Policy document is posted on the WRAP website, and included in this
document.
ESMP Policy Development Process I-5
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ESMP Task Team Roster I-6
Western Regional Air Partnership
Fire Emissions Joint Forum
Enhanced Smoke Management Program Task Team
ROSTER
Ann L. Acheson (Co-Chair) Gretchen Barkmann
Air Program Manager Santa Fe National Forest
USFS Region 1 P.O. Box 1689
200 E. Broadway Santa Fe, NM 87504
P.O. Box 7669 Phone (505) 476-3799
Missoula, MT 59807 Fax (505) 827-0160
Phone (406) 329-3493 gbarkmann@fs.fed.us
Fax (406) 329-3132
aacheson@fs.fed.us
Suraj Ahuja Frances Bernards
Forest Service, Region 5 Planner
Mendocino National Forest Utah Division of Air Quality
825 North Humboldt St. 150 North 1950 West
Willows, CA 95988 Salt Lake City, UT 84116
Phone (530) 934-1169 Phone (801) 536-4056
Fax (530) 521-7394 Fax (801) 536-0085
sahuja@fs.fed.us fbernard@deq.state.ut.us
Trish Aspland Scott Downey
Western Governors Association EPA, Region 10
1515 Cleveland Place, Suite 200 Office of Air Quality, OAQ-107
Denver, CO 80202 1200 Sixth Ave.
Phone (303) 623-9378 Seattle, WA 98101
Fax (303) 534-7309 Phone (206) 553-0682
taspland@westgov.org Fax (206) 553-0110
downey.scott@epa.gov
Jason Baldwin Mark Fitch
Executive Director Arizona Department of Environmental
Madera County Farm Bureau Quality
1102 S Pine T5109B
Madera, CA 93637 3003 N Central Ave
Phone (559) 674-8871 Phoenix, AZ 850122809
Fax (559) 674-0529 Phone (602) 2072374
jasonbaldwin@sbcglobal.net Fitch.mark@ev.state.az.us
ESMP Task Team Roster I-7
John Graves Vicky Komie
Assistant Smoke Management Program NM Air Quality Bureau
Manager 2048 Galisteo
BIA Santa Fe, NM 87505
C/o ADEQAQD Phone (505) 955-8009
3033 N. Central Avenue Fax (505) 827-1523
Phoenix, AZ 85014 vicky_komie@nmenv.state.nm.us
Phone (602) 207 2277
Fax (602) 207 2366
graves.john@ev.state.az.us
Mark Gray Scott Kuehn
WA Department of Natural Resources Plum Creek Timber
Resource Protection Division 140 N. Russell
P.O. Box 47037 Missoula, MT 59801
Olympia, WA 98504-7037 Phone (406) 542-3273
Phone (360) 902-1754 Fax (406) 5491885
Fax (360) 902-1781 skuehn@plumcreek.com
mark.gray@wadnr.gov
Dennis Haddow Peter Lahm (FEJF Chair)
US Fish & Wildlife Service Air Resource Program Manager
C/o NPS Air USDA, Forest Service
P.O. Box 25287 C/o ADEQ-AQD
Denver, CO 80225 3033 N. Central Avenue
Phone (303) 969-2091 Phoenix, AZ 85012
Fax (303) 969-2822 Phone (602) 207-2356
dennis_haddow@nps.gov Fax (602) 207-2366
pete_lahm@compuserve.com
Kerry E. Kelly, P.E Gary Neuroth
Department of Chemical and Fuels 9231 N. Camino Vista Lane
Engineering Phoenix, AZ 85028
Kennecott Research Center Phone (602) 867-4478
1495 East 100 South, Room 105 scruffy1@home.com
Salt Lake City, UT 84112-1114
Phone (801) 587-7601
Fax (801) 585-5607 Bruce Oulrey
kelly@eng.utah.edu California Air Resources Board
1001 I Street
Sacramento, CA 95814
Phone (916) 322-6155
Fax (916) 322-3646
boulrey@arb.ca.gov
ESMP Task Team Roster I-8
Bob Palzer, Ph.D. Jeff Schmidt
Chair, National Sierra Club Air Community Assistance Coordinator for
Committee NRCS
501 Euclid Bureau of Land Management
Ashland, OR 97520 Fire & Aviation
Phone (541) 482-2492 222 N. Central Ave.
Fax (541) 482-0152 Phoenix, AZ 85004
bob.palzer@sierraclub.org Phone (602) 417-9324
Fax (602) 417-9554
Jeff.Schmidt@az.usda.gov
Dave Randall Marcus Schmidt
(FEJF Member, Small Business Air Program Manager (Acting), R-2/R-4
Representative) Smoke Management Specialist,
Air Sciences Inc. BLM-CO, R-2
12596 West Bayaud Ave. Colorado State Office-BLM
Lakewood, CO 80228 2850 Youngfield St.
Phone (303) 988-2960 x221 Lakewood, CO 80215
Fax (303) 988-2968 BLM (303) 239-3607
drandall@airsci.com FS (303) 275-5759
Cell (303) 249-9502
Fax (303) 239-3811
marcus_schmidt@co.blm.gov
Rebecca Reynolds (ESMPTT Evan M. Shipp
Facilitator) San Joaquin Valley Air Pollution
President Control District
Rebecca Reynolds Consulting, Inc. 1990 E. Gettysburg Avenue
10841 East 155th Place Fresno, CA 93721
Brighton, CO 80602 Phone (559) 230-5809
Phone (303) 655-3773 (office & cell) Fax (559) 230-6064
Fax (303) 655-3776 evan.shipp@valleyair.org
rr@rebeccareynolds.biz
Beth Sauerhaft Pete Stewart
USDA-NRCS New Mexico Zone Smoke Coordinator
Nat’l Ecological Climatologist 3005 E. Camino del Bosque
P.O. Box 2890, Room 6158 Silver City, NM 88061
Washington, D.C. 20013 Phone (505) 388-8243
Phone (202) 720-8578 Fax (505) 388-8204
Fax (202) 720-1814 ptstewart@fs.fed.us
Beth.Sauerhaft@usda.gov
ESMP Task Team Roster I-9
Alan Stover Mike Ziolko (Co-Chair)
SD Department of Agriculture Meteorology Manager
2202 University Oregon Department of Forestry
Hot Springs, SD 57747 2600 State Street
Phone 605-745-5820 Salem, OR 97310
Fax 605-745-4553 Phone (503) 945-7452
alan.stover@state.sd.us Fax (503) 945-7454
mziolko@odf.state.or.us
Greg Zschaechner
Utah Interagency Smoke Program
Coordinator
P.O. Box 144820
Salt Lake City, UT 84114-4820
Phone (801) 539-4151
Fax (801) 536-0031 Backup (801) 536-0085
gzschaechner@worldnet.att.net
ESMP Task Team Roster I - 10
Section II
Chronological Record of the WRAP ESMP Policy
Development
Chronological Record II - 1
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Chronological Record II - 2
ESMP Task Team Meetings
Park City, Utah: September 26-28, 2001
Chronological Record II - 3
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Chronological Record II - 4
ESMP Task Team Meeting
Park City, Utah
September 26, 2001
Meeting Record
Participants: Suraj Ahuja, USFS, R5; Gretchen Barkman, USFS NM; John Graves, BIA
AZ; Mark Grey, WDNR; Vicky Komie, DEQ, NM; Pete Lahm, USFS (FEJF Chair); Jeff
Schmidt BLM- (NRCS), AZ; Marcus Schmidt, CO BLM/USFS; Mike Ziolko, ODF
(ESMP Task Team Chair), DEQ, AZ; Greg Zschaechner, Utah BLM.
Opening Comments (M. Ziolko)
• General Overview of Task Team Work
ESMPTT is developing framework for enhanced smoke mgt program
requirements.
• Relationship with Emissions Task Team (ETT) and Natural Background Task Team
(NBTT) work
Other task teams have needs from ESMPTT and have identified needs for
ESMPTT to address. ETT needing some emissions methodology; ESMPTT needs
to refine "manage" and "control" from NBTT.
• Review of GCVTC and Regional Haze Rule requirements
A. Considerations from GCVTC
1. Efficiency
2. Economics
3. Law
4. Land management objectives
5. Reduction of visibility impacts
B. Considerations from RHR
1. Minimize emissions
2. Smoke dispersion
3. Alternatives
4. Public notification
5. AQ Monitoring
6. Surveillance/monitoring
7. Evaluation
Opening Comments (P. Lahm)
ETT and NBTT Needs "Range"
Other task teams need output from ESMPTT. ESMPTT work combines elements of all
task teams and builds ESMP framework.
1. Criteria for ESMP
Chronological Record II - 5
ETT focusing on developing an emissions inventory, modeling will be
done March 2002 for 309 states. 2018 emissions projection will also be
produced with controls and without controls. Where potentially will
ESMPs be applied? Most immediate needs of ETT are:
• Criteria needed for what are states will be in 2018 submissions
with ESMP
• Annual goal methodology needed, ASAP
NBTT/IOC-wants to see greater explanations as to what is natural and
anthropogenic. Also looking for clarity for management versus control and
what does this mean for BSMP and ESMPs. As ESMP is developed, need
to know how natural background will fit into an ESMP and how emissions
will be managed versus controlled.
2. Annual Goal Methodology
Part of the ESMP process, although there is no consensus as to what these
goals will be. Goals will be achieved through use of burning alternatives,
emission reduction techniques... ETT needs a "range of control strategies
and alternatives. Are we looking at a goal or a cap?
Differences Between 308 and 309 Requirements
• 309 states' reasonable progress means emissions reduction, not visibility
improvement
• 308 states' reasonable progress means visibility improvement.
• Tribes can opt into 309
• California appears to be heading towards 308 status to focus on health issues,
but see benefit in WRAP modeling/EI work
• 308-ag and wildlands address adequacy and apportionment for all sources
Due Dates
• Criteria and annual goal methodology needed ASAP
• 5/2002-ESMP recommendations/framework for consideration at 6/2002
WRAP meeting
• 12/31/2003-SIPs from 309 states to EPA
Funding
1. Framework and recommendations: $100,000
2. Emission Goal: $10,000 (plus $15,000 which is included in 1)
3. Funding Mechanism: $25,000
4. FETM (w/ETT): $15,000
Group Discussion
Criteria to Trigger ESMP (review from August 27, 2001 conference call)
1. Implementation: Which states will need to have an ESMP? How will ag, tribes, or
other types of unregulated burning or burning conducted under an existing BSMP be
Chronological Record II - 6
affected by the implementation of an ESMP? Also need to consider transport from
WRAP states to Class I areas in other states.
Possible triggers for ESMP:
1. Receptors and/or # of receptors
2. Proximity to receptors
3. Significant ag burning
4. Energy development
5. Fire use for natural resource benefits
6. Population
7. Non attainment areas
8. Significant increase in emissions
9. MOU with enforcement provisions
10. Entire state/partial state/multi-state
11. Matrix considering activity versus source/source area
12. Emissions of “x” tons/day
2. What will be the elements of an ESMP?
Our assumption is that elements of a BSMP are already in place.
ESMP elements to build on
1. Emissions tracking
2. Emissions reductions/alternatives
3. Emissions goals
4. Emissions information tracking (visibility monitoring)
5. Modeling
6. When/where ESMP will be need/used
7. Regional approach/interstate coordination/communication
ESMPTT Breakout Session of FEJF Meeting
Park City September 27, 2001 p.m. and September 28 a.m.
Participants: Suraj Ahuja, USFS, R5; Trish Aspland, WGA; Gretchen Barkman, USFS
NM; Frances Bernards, DEQ, Utah; Mark Grey, WDNR; Vicky Komie, DEQ, NM; Scott
Kuehn, Plum Creek Timber; Darla Potter, DEQ, WY; Jeff Schmidt BLM, (NRCS), AZ;
Marcus Schmidt, CO BLM/USFS; Mike Ziolko, ODF; Greg Zschaechner, Utah BLM.
1. The ESMPTT developed mission and goal statements, shown below.
Mission Statement
By working with other Task teams, identify, develop and deliver the framework
requirements to FEJF for ESMPs and annual emission goal methodology.
Goals
1. Identify when ESMPs would be implemented
2. Describe in detail the elements of an ESMP
3. Provide and annual goal methodology
2. A schedule for key meetings and products was developed.
Chronological Record II - 7
Discussion about the need and ability to conduct a workshop to present ideas and
solicit input. Given the tight time frame under which the TT is operating, we
tentatively agreed to go with extended outreach instead of conducting a workshop.
The need for facilitation for the group's work was also identified. (see #3, below).
October 19 Task group ideas to Mike
26 Mike summarize and get info to task group
31 Conference call to discuss elements and matrix
November
December 4-5 FEJF Meeting
6 & 7 Task Team meeting
January
February 5 pm ESMP
6 & 7 FEJF discuss draft work
March ESMP meeting? Or conf call
April Final draft ready. ESMP meeting?
May 14 ESMP all day
15 & 16 FEJF
**When is IOC/TOC? Do we need to coordinate with their meeting?
June WRAP meeting
3. Facilitator and Budget
Sufficient funds are available for a facilitator to be hired. The TT has a short time frame
in which to work, too. Darla Potter presented the NBTT budget for the workshops and
facilitator.
Costs for NBTT work:
Workshops
Denver $ 9,500
Phoenix $ 4,000
Consultant (18 mos.) $67,000
6 TT meetings: $ 2,873
What would facilitator do for the TT?
• Work with small workgroups as necessary
• Work with ESMPTT
• Coordinate work
• Review documents
Chronological Record II - 8
Action item: Mike will draft a Scope of Work for TT review for work from Oct - May
2002.
4. Consider development of a criteria matrix to determine when an ESMP is
needed.
Four major areas were identified. ESMPs may be necessary depending upon a range of
area coverage or impact potential ranging from the project level to multi-regional level.
Need to refine and complete where and when ESMP would be required. Matrix
developed from earlier discussion (#1)
Criteria Matrix
Area Project County Airshed Tribe Multi- All Other region
source or state state WRAP (non-WRAP)
A. (GROUP)
1. Receptor of significant smoke from another area
2. Source of significant smoke to another area
3. Population/density
4. Non-attainment areas
5. Combined Class !/Non-attainment area concern
6. Proximity to Class I area
B. (GROUP)
1. Potential to impact
2. Significant increase in emissions
3. Number of Class I areas
4. Emissions of "x" tons/day
5. Fuel loading "x" tons/day
6. "x" acres/day-per "x" fuel type
7. Total acreage
C. COMPETING SOURCES (CUMULATIVE EFFECTS)
1. Point source energy development
2. Fire for natural resource benefits
3. Size of emission reduction ratio/potential
4. Diversity of concurrent fire sources (ag/rx/wild)
5. Other area sources
D. (GROUP)
1. MOU with enforcement provisions
2. Number of NAAQS violations
3. Failure to successfully implement BSM
Chronological Record II - 9
5. Workgroups were clarified that would identify elements in an ESMP. (follow-up
to groups established in Aug 27 conference call.)
Global task areas for elements in ESMP (volunteer group leader listed first). Each
workgroup would identify what potential strategies could be included in its respective
topic area. List will be sent to Mike and compiled for review on Oct 31 conference
call.
1. Emissions tracking: Suraj, Vicky, Bob, Mark G
2. Emission Reductions/Alternatives: Mark G., Bob, Scott, Vicky
3. Emissions Goals: (no leader),Mark F., Dave Randall, Pete, Bob
4. Emissions info tracking (visibility monitoring): Marcus, Greg, Mark G,
Bob, (John G?)
5. Modeling: (no leader), Mark F, Suraj, Bob
6. Regional Approach/coordination: Greg, Marcus, Frances, (Jeff?)
7. Funding Mechanism (review BSMP wildland survey): Gretchen, Marcus,
Trish
6. Annual Goal Methodology
Pete provided further explanation on what is required for annual goal methodology
work. ESMPTT needs to address the following:
1. Is the emissions goal a cap or a goal to work towards? GCVTC says it is a
cap. Others say it is a goal.
2. What sectors fit into an annual goal---natural sources? Anthropogenic
sources? Or???
3. To what type of averaging period does the goal apply (1 year, 5 years,
seasonal????)
4. Is maintenance burning included or not?
5. Is wildfire excluded?
6. What areas or types of land do we include or exclude.
7. Controls
Pete provided the group with an example of possible control requirements, shown
below. ESMPs capture emission goals; BSMPs address emission reductions. BSMP
uses the EPA Interim Policy on Fire; ESMP uses RHR requirements.
X Acres No control
% Control
Z=control
Reduction
Y with
Chronological Record II - 10
Meeting Product
From the Park City, Utah Meeting
September 26, 2001
Compilation of ESMP TT Work Group Products:
Enhanced Smoke Management Plan Criteria and Elements
November 30, 2001
Enhanced smoke management programs will need to be developed in areas (county,
airshed, state, multi-state) meeting certain criteria. Once it has been determined that the
criteria are met in a given area, then special smoke management elements need to be
implemented. In some cases, elements may be a more detailed implementation of Basic
Smoke Management Program requirements. In other situations, a much greater level of
oversight of burning may be required.
The assumption is made that Basic Smoke Management Plan requirements previously
recommended by the FEJF are in place, where necessary. The following provisions are
in addition to the BSMP requirements.
1. Emissions tracking: Suraj, Vicky, Bob, Mark G
1. Natural or Anthropogenic
2. Post Burn emissions of blackened acres
3. Location
4. Name of Unit
5. Burn Name
6. Burning Category (Wildland, WUI, Agricultural)
7. Airshed
8. Purpose of Burn
9. How far from Clean Air Corridor?
10. Emission reduction techniques used
11. Amounts of Emission reductions
12. Justification if alternatives to burning not employed
13. Distance from Class I Areas
Vicki developed the fields initially. Conference call on 10/26: Vicki Komie, Marc Gray,
Suraj Ahuja were in attendance.
The questions for the group are:
Any addition or deletion to fields?
Emissions---PM10/PM2.5, SO2, NO2, VOCs---or just PM2.5?
Location of Burns---Latitude Longitude of the midpoint of the burn (Do we need
to give location for multi day burns everyday?)
Do we need a separate category for WUI?
Do we need to make a list for required and optional fields or all the fields are
required?
Chronological Record II - 11
Do we need justification here or in the NEPA documents?
2. Emission Reductions/Alternatives: Mark G., Bob, Scott, Vicky
3. Emissions Goals: Mark F., Dave Randall, Pete, Bob
Note: The ideas below represent a single person’s point of view and is only intended to
be used for discussion purposes. This has not reviewed by the Emissions Goals task
group.
“......annual emissions goals for all fire programs, where appropriate, be established by
the year 2000. These goals will be set to minimize emissions increases from such
programs to the maximum extent feasible.”
The Grand Canyon Visibility Transport Commission, June 1966
“Establishment of annual emissions goals for fire, excluding wildfire that will minimize
increases in emissions to the maximum extent feasible...”
64 FR 35753, Regional Haze Rule §51.309(d)(6)(V)
Ideas for Emissions “Caps” and/or “Goals”
Questions that need to be addressed
• Are we going to address “caps” or “goals” is wildland, Prescribed Natural
fires, and wildfires going to be considered when determining emissions
caps/goals Note: GCVTC states that “emission goals for all fire programs
where appropriate, be established....”
• Are these caps/goals only going to be employed when the criteria for an
ESMP is invoked or will they be in place at all times
• Will these caps/goals be applied to the whole state, or county by county,
air shed, climate division or air control division, or left up to the states best
interest
• Will intra-state or other region trading of goals be allowed once the
goal/cap is invoked
• Will only “Anthropogenic-emissions” be place under goals/caps or all
type of burnings
• Will there be consideration of different caps for different type of burns:
(e.g., restoration, maintenance, wildland fire use and wild fire burning,
agricultural & Conservation Reserve Program) or will all burnings
regardless of burn type be lumped under one goal/cap
A Method to Calculate Caps/Goals
• Consideration for inter-annual climate variability should be considered
when calculating the emissions caps/goals.
• X-year running caps/goals, for example:
Use a five-year running mean for all fires in the state, county or some
other division to establish an emission goal for the next year calculating
Chronological Record II - 12
emissions goals this way would be easy and should encompass climatic
variability such as ENSO events warm and cold.
• The program may want to investigate the necessary parameters to develop
a “climatic fire index” to help forecast the forthcoming fire season. and
use this information along with the running mean emissions goal/cap.
This may allow some flexibility in smoke program
Questions
• Should the planned burns for the respective year be registered
before calculations of annual caps/goals:
• When should the mean annual emissions goal/cap be calculated
from (e.g., when should the fire “season” begin). Does it start on
June 1st so the annual goal would include one wild fire and one
prescribed fire season? Let each program chose their own starting
time; any problems here?
Issues
• Based on a x-year running mean of emissions, has the potential to
include climate forecasting and climate variability
• Easy to apply to any set political boundaries
• changes as the need for burning changes
• Goals/caps could be linked to the use of alternatives, (e.g., cap may
be increased with an increase use of alternatives) viewed as an
incentive program
• Hard and fast caps with few if any changes once in place
• Does not allow for mid season changes should weather
characteristics allow for an increase in burning
• If there are X number of years of poor burning conditions and
these values are used to determine the goal for the following year
the goals/caps would be low for a good burning year
4. Emissions info tracking (viz monitoring): Marcus, Greg, Mark G, Bob, (John G?)
Two guidance documents for tracking emission information for visibility monitoring can
be: EPA’s “Guidance for Tracking Progress Under the Regional Haze Program” and
“Guidance for Estimating Natural Visibility Conditions Under the Regional Haze
Program”
o In order for any visibility policy to be effective, there must be an appropriate
benchmark or threshold of existing conditions against which a measurement of
progress or reduction can be obtained. Data from existing IMPROVE must be
tracked. To understand more clearly the impacts on visibility from fire, additional
receptors maybe identified and monitors established.
o A baseline condition using (2000-2004) data from Improve network will
need to be established.
o Current conditions of the best and worst days will be calculated from the
average of the last 5 years of monitored data.
Chronological Record II - 13
o Natural Conditions will need to be estimated for the 20 percent worst and
20 percent best days.
o Information related to the current levels of emission reduction technologies used
in fire management and agriculture burning, the emission reduction options that
are available for the use of fire (including costs and efficiencies), and methods to
project changes in the future.
o This information can be used for determining whether reductions in
emission are being met. [Emission Goals or Caps]
o An ongoing five-year emission inventory of prescribed, wildland fire and
agriculture burning will be kept.
o Wildfire suppression emission saving could be calculated for emission
trading or meeting emission caps.
5. Modeling: Mark F, Suraj, Bob
I had requested Modeling Conference call also planned for the same day but no one
called. My preliminary list is
1. Weather parameter probably from MM5-
2. Wind Speed
3. Wind Direction
4. Mixing Height
5. Temp
6. Humidity
7. Distance to receptor/sensitive sites
8. Location of receptor site
9. Location of other burns
10. Emission production rates
11. Ignition time
12. Burn time
We will discuss them at the conference call for edition and deletions. I have another
meeting going on so I may not stay for whole conference call.
6. Regional Approach/coordination: Greg, Marcus, Frances, (Jeff?)
Items described below apply for wildfire, prescribed fire, and agricultural burns.
Inter-State Coordination
-Collect information on sensitive receptors (hospitals, schools, Class I Areas, airports,
etc.) by airshed from adjoining states downwind. List by UTM for application to a GIS
display for smoke modeling and tracking.
Inter/Intra-State Coordination
-Inform Regional level center of anticipated burns for the year. This would initiate the
burn sequencing process.
Chronological Record II - 14
-Require regional approval and real-time tracking of burns. With the regional tracking
concept, the regional level coordination center could better coordinate multiple burns
across the western region, avoiding multiple-layering impacts on airsheds and across state
boundaries. This would permit for informed last minute decisions so that airshed
optimization can occur.
-Maintain a regional smoke web site so that burns can be identified the week prior and
burn approvals given several days in advance for multiple day buns. Determining when
multiple day burns can be carried out requires advanced meteorological analysis and
planning. Taking advantage of multiple burn days will in the long run reduce intensities
of PM production.
Inter-State Notification
-Develop an auto-dial notification list where known smoke sensitive individuals exist.
This would be utilized when unanticipated smoke intrusions occur so that sensitive
individuals could take precautionary measures.
Both Inter/Intra-State Notifications
-Collect information within each airshed pertaining to sensitive receptors.
-Collect information within each airshed pertaining to recurring special events and
specifically planned events, e. g., annual marathon races, community parades and special
events, county fairs, opening hunting season, state holidays, etc. Whether or not they
were a concern during the actual burn would depend on a number of factors such as:
weather, public acceptance, public education efforts, news releases, etc. Information
could be collected by UTM for application to a GIS.
-Develop enhanced smoke notification lists for pre-established climatologically airflow
patterns scenarios. Draw upon lists for pre-burn notification and advanced warning
should weather change to outside of prescribed transport wind.
-Enhance the BSMP smoke home page to include information on current smoke flows,
and anticipated PM density maps with identified time frames for burns. Utilize this
information to plan and regulate the timing of burns down wind.
-Establish smoke flow pattern notification phone/email lists across airshed and state
boundaries. These would be utilized for advanced warning of planned burns and when
smoke transport winds were unsatisfactory.
Modeling
-Use typical airflow patterns using climatological data and model smoke dispersion using
various smoke dispersion models.
Chronological Record II - 15
-Model the year’s set of planned burns using BlueSky, NFSPuff, or some other model.
This would allow for optimizing annual airsheds and reduce multi-laying of transport
smoke.
Monitoring
-Use of real-time PM monitoring equipment in smoke sensitive areas and for visibility
concerns. Preferred use of 2.5 µ monitors. Establish thresholds for mandatory and
recommended use. Use to educate public in PM levels and for public and media
notification. Use as a tool to sensitize the public to various PM levels. Post the
information on the smoke home page.
-Access real-time high-resolution satellite data for verifying and tracking smoke. Use
this data to better improve regional scheduling of burns in future
Climatology/Mesonet
-Climatological analysis is needed to determine when multiple day projects can be carried
out.
-Conduct analysis of regional airflow patterns so that statistically safe opportunities for
burning throughout the year can be taken advantage of, spreading the smoke over a
broader time period.
7. Funding Mechanism: Gretchen, Marcus, Trish
The following is a list of possible methods for funding smoke management programs:
A. Funds obtained from users of prescribed fire.
a. MOU/MOA/Consortium Funds
o Each member/signatory pays an annual membership fee and there is an
additional per acre fee for accomplished burns. The fee varies
depending on whether it is a forest or range burn. (Consider additional
“start-up” costs when programs are initiated).
o Agencies that have signed the MOU contribute funds.
b. Permit/Emission Fees
o Permit fees may vary depending on the type of burn. Some examples
follow:
A fee for each burn plan and an additional fee based on actual
acreage burned.
A predetermined fee for a 30-day single-site permit, another
fee for a multiple site annual permit of 1-500 aggregate acres,
with another fee for > 501 aggregate acres.
Fees based on emissions from the previous calendar year. Fees
adjusted periodically to cover Department costs.
Chronological Record II - 16
A $20 fee is charged for an open burning permit.
Inspection fees are paid to the Fire Rescue Department before a
permit is issued. A fee of $75 is charged for a 30-day single
site permit. For a multiple site annual burn permit, a fee of
$250 is charged for 1-500 aggregate acres and $350 for more
than 501 aggregate acres.
The state portion of the smoke management program is fee
funded. Currently the fees for “major open burners” are based
on actual or estimated amount of air pollutants emitted in the
last calendar year. This is calculated based on tons of
particulate matter, oxides of nitrogen, and volatile organic
compounds using emissions guidelines from the AP-42
handbook. The fees are adjusted periodically to cover the
Department’s costs and the cost of the Meteorologist/Program
Coordinator for operating the smoke management program.
In-kind services may be used to reduce the fees of some major
open burners.
c. Acreage assessments.
o An assessment, per acre, to register a unit for burning, then an
assessment per acre actually burned. Assessments vary by type of
burn. As an example: $810 fee for each burn plan submitted and an
additional fee based on the actual acreage burned. For prescribed
burns: $480/acre burned, for marsh/tule burns: $156/acre burned.
B. Grants and/or Appropriated Funding
o A combination of many sources including EPA grant, city and county
governments, fire protection assessments, property taxes.
o General revenue program/appropriated funds.
o EPA grant/other grant funds.
o Annual contract with state Health Department.
o Department funds and the Air Partnership Performance Grant, the
vehicle for EPA grant funds.
o Smoke management operations for agriculture/silvicultural burns
absorbed by the local operating budgets. Fees may be submitted
before authorization to burn for certain types of burning.
C. Combination of Appropriated funds, fees, and/or taxes
o General fund, harvest tax, per acre fees, and direct payment for service
fund the program. Some examples:
OAR 629-043-041 describes the acreage assessment. An
MOU exists with federal agencies in northeast Oregon for
direct payment. The acreage assessment is $0.50/acre to
register a unit for burning and $2.50/acre for piled burn
accomplishments and $5.00/acre for broadcast and under burn
accomplishments. Fee exemptions are allowed for forest
health burning and units less than 3 acres in size.
Chronological Record II - 17
DNR’s outdoor burning program is funded through the state
general fund, fire protection assessments of forestland, and
burning permit fees. Fees for silvicultural burning are assessed
on estimated consumed tons. The state legislature appropriates
funds to DNR for administration and enforcement of the SMP.
Funds are appropriated from the state General Fund, the Air
Pollution Control Account, and from property taxes (forest
protection assessment). Fees assessed for burning are
deposited into the Air Pollution Control Account. Only about
30% of the money needed to administer the SMP and the
inseparable outdoor burning regulation program is currently
covered by burn permits.
The local air quality program is 70% funded by the state
through a grant from the EPA, then funded by permit fees and
equal contributions from Rapid City and Pennington County.
o In-kind services in conjunction with permit fees.
Chronological Record II - 18
ESMP Task Team Meetings
San Diego, California: December 4-7, 2001
FEJF Meeting & ESMP TT Breakout Session
Chronological Record II - 19
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Chronological Record II - 20
ESMPTT Meeting
San Diego, California
December 4 – 7, 2001
Agenda
December 4
ESMP Breakout Session (3:00 – 5:00 p.m.)
I. Welcome/Introductions
II. ESMPTT Timeline
III. Work Group Check In
V. Review 12/5 – 7 Agenda
December 5
ESMP Breakout continued (8:15 a.m. – 2:00 p.m.)
I. Work Group Reports
II. Work Group Deliverables Defined/Timeline Set
III. Terms Defined/Glossary
December 6
ESMPTT Meeting (8:00 a.m. – 5:00 p.m.)
I. Annual Emission Goals Methodology Discussion
Questions: Goal or Cap? Wildfire included or not? Difference between
wildfire under suppression & wildfire managed for resource benefit? Are
these goals/caps going to employed when the criteria for ESMP is invoked
or at all times? Applied to whole state, county by county, airshed, climate
division, or?? Will intra-state trading of goals/caps be allowed? Will only
Anthropogenic emissions be placed under goals/caps? Is there a different
goal/cap for each type of fire? Progress assessed annually or every five
years or?? Others??
II. ESMP Criteria Discussion
December 7
ESMPTT Meeting continued (8:00 a.m. – Noon)
I. ESMP Elements Review & Discussion
II. Next Steps/Assignments
Chronological Record II - 21
ESMPTT Meeting
San Diego, California
December 4 – 7, 2001
Meeting Record
Summary of ESMPTT Work Assignments (see notes below for details)
ESMP Element Workgroups
To clarify each element, each workgroup will write a narrative answering the basic 5Ws
(Who, What, Where, When, Why) for their ESMP element.
NO LATER THAN COB 12/21/01. Email to Mike Ziolko, cc: Ann A./Rebecca R.
Workgroup Leads:
Emissions Tracking: Vicky Komie (pp. 8, 20)
Emissions Reduction: Scott Kuehn (p. 8)
Impact Reduction: Scott Kuehn (p.8)
Alternatives to Burning: Ann Acheson (p.9)
Information Tracking: Marcus Schmidt (p.10)
Technical Tools: Suraj Ahuja (p.10)
Regional Approach: Greg Zschaechner (pp. 10, 19)
Program Administration Section: Gretchen Barkmann & Mike Ziolko (pp. 10-11)
Note: You may want to start with the Why (rationale). ALSO: remember to consider the
two filters of the RHR Criteria and the NBTT – FEJF Memo items (see detailed lists of
these on page 11 below)!
Annual Emissions Goal Methodology Workgroups
For those taking on Emissions Goal work, feel free to enlist help from whomever you
choose or go it alone, as you wish. Something is due from each of you COB 12/21/01.
Workgroup Leads:
M. Fitch: Spatial/Temporal Averaging (p. 16), The Number (p.16 & 17), Source Type (p.
17); F. Bernards: Trading (p.17); D. Haddow: Accountability (pp.17/18); Scott Kuehn:
Incentives (p. 18)
Miscellaneous:
Glossary: Mike Ziolko (p.21)
Outreach White Paper: Jeff Schmidt (Mark F. will get you NBTT Workshop list) (p.21)
ESMPTT Ag. Participation: Mike Ziolko (p. 21)
Draft the Memo to ETT: Mike Ziolko (p. 8 & 10)
GENERAL: When workgroups are having conference calls, please broadcast the call-in
information to the entire ESMPTT so that all who want can participate.
Chronological Record II - 22
December 4 ESMPTT Breakout Session
Participants: Mike Ziolko, Co-Chair/Oregon Dept. of Forestry; Bob Palzer, Sierra Club;
Bruce Oulrey, CA Air Resources Board; Beth Sauerhaft, USDA-NRCS; Jeff Schmidt,
USDA-NRCS/BLM; Scott Kuehn, Plum Creek Timber; Vicky Komie, NM Air Quality
Bureau; Suraj Ahuja, USDA-FS; Evan Shipp, San Joaquin Valley APCO; Pete Stewart,
USDA-FS/SW Region; Frances Bernards, Utah Division of Air Quality; Crystal Loesch
(for Ann Acheson, ESMPTT Co-Chair), USDA-FS/Region 1; Rebecca Reynolds,
Facilitator.
The ESMPTT met for an hour to cover some housekeeping issues, to distribute
background literature to aid the group in its deliberations, and to clarify the focus of the
meeting sessions of the next three days.
Task Team Housekeeping: ESMPTT rosters and schedule circulated, as well as other
background handouts (Summary of BSMP document, Digest of Statutory and other
guidance on ESMP, the NBTT Policy on Categorizing Fire Emissions). Updated roster
and schedule to be sent out with San Diego Meeting Notes.
ESMPTT Schedule: Given the June WRAP meeting deadline for ESMPTT deliverables
and the various approval steps prior to it (FEJF, IOC/TOC), the ESMPTT will want to
have a solid draft of all its products by March 1, 2002.
ESMPTT Deliverables: Discussion on what exactly the ESMPTT is tasked to produce.
Agreed:
1) ESMP Guidance Document that considers BSMP
2) An Annual Emissions Goal Methodology
ESMPTT Priorities for San Diego meeting:
1) Review BSMP Elements & Current ESMP Elements to check for
linkage between them, and to verify that the current ESMP Elements are
correct.
2) Hear ESMP Elements Working Group Reports & Give Input
3) Discuss and Decide on ESMP Criteria (i.e., what triggers an ESMP) –
see Criteria Matrix developed in Park City.
4) Discuss and Develop a Straw-Man Annual Emissions Goal
Methodology
5) Develop an ESMPTT Workplan for the next several months
6) Think about an ESMPTT Glossary, using NBTT and others as starting
point.
December 5 ESMPTT Breakout Session
Participants: Mike Ziolko, Co-Chair/Oregon Dept. of Forestry; Bob Palzer, Sierra Club;
Bruce Oulrey, CA Air Resources Board; Beth Sauerhaft, USDA-NRCS; Jeff Schmidt,
Chronological Record II - 23
USDA-NRCS/BLM; Scott Kuehn, Plum Creek Timber; Vicky Komie, NM Air Quality
Bureau; Suraj Ahuja, USDA-FS; Evan Shipp, San Joaquin Valley APCO; Pete Stewart,
USDA-FS/SW Region; Frances Bernards, Utah Division of Air Quality; Crystal Loesch
(for Ann Acheson, ESMPTT Co-Chair), USDA-FS/Region 1; Rebecca Reynolds,
Facilitator.
12/5 Breakout Session Agenda:
I. Q&A
II. Overview of BSMP/noting any Ag differences (Scott Kuehn)
III. Review Current ESMP Elements (Mike Ziolko)
IV. Refine ESMP Elements (Group)
Specifically: Clarify what ESMPTT is looking for from each ESMP Elements
workgroup as a first step to developing the ESMPTT Workplan
I. Q&A Session:
What is the focus of the ESMP (meaning just Regional Haze, or also including NAAQS
and PM2.5?, i.e., an extension of BSMP)
Some thought the BSMP handled the nuisance and public health issues, and that ESMP
was “enhanced” specifically to address visibility. And that the ESMP would be built on
top of, meaning including, the BSMP, and therefore would address all clean air issues.
Some felt that the ESMP must deal with all clean air issues, if it was to be effective.
If the focus of ESMP is regional haze, what about SIPS? Long term vs. short term? How
will this affect the ESMP elements? If we were to consider the SIPS in the ESMP, our
dialog will be better. Is the ESMP in support/conformity of Regional Haze, NAAQS,
SIP?
What is the (our) definition of “Visibility”? – Does it include plume blight? Regional
haze?
Agreed that these questions would surface again in our discussions on Annual Emissions
Goal and ESMP Criteria, and would be tabled until that time.
II. BSMP Review: (S. Kuehn)
Interim Guideline was the biggest basis for the BSMP development, with the emphasis on
protection of NAAQS and health and welfare directives, such as impact reductions, etc.,
at all levels.
Assumption: an ESMP will include all BSMP; in other words, you cannot have an ESMP
without a BSMP.
All BSMP recommendations were written as “shoulds”, when in fact some of them will
end up being more directive (“musts”). Scott & Diane were waiting for comments before
Chronological Record II - 24
deciding. Scott gave his view of what were the “should” recommendations and what were
the “musts”. He also thought that some of the BSMP “shoulds” would become “musts” in
the ESMP.
Scott’s View of “Musts” and “Shoulds” (using the numbering of the Summary of the
BSMP document prepared by Rebecca)
A. Authorization to Burn
A1: this means a daily authorization and should be so indicated.
A2:
A3:
Note: for A2 & A3, recommend adding “smoke management criteria” in the title.
B. Minimizing Air Pollution Emissions (Note legislative barriers for Ag)
B1: must for FLMs, should for Ag (difficult because burner training not currently
available for Ag)
B2:
B3:
B4:
B5: must
B6-B7: shoulds.
B7: a “should” in BSMP, but indicates ESMP. These can be at different strengths, needs
a tiered approach derived from potential impacts.
C. Smoke Management Components of Burn Plans
C1: FLMs must include smoke management components in burn plans; regulatory
authorities should assist private landowners… Large Ag. burners should have a burn
plan. [Delete “large” as descriptor of fire in the last sentence – too vague]
C1-4: shoulds.
D. Public Education and Awareness
D1: should; importance varies by location
D2: should; needs to be developed and increased!
D3: should; too many of the privates are unaware of smoke management efforts and
programs.
E. Surveillance and Enforcement
E1: should
E2: must
E3: must
F. Program Evaluation and Reporting
(Add: characterize air quality visibility emissions/ develop a baseline as the starting
point)
F1: last sentence re: adequate information may be ESMP; first two sentences are musts
(3-5 years apart).
Chronological Record II - 25
F2: must
G. Optional Air Quality Protection
G1: must
G2: must
G3: should
G4: must
BSMP with regard to Ag: Most all of the BSMP would apply to Ag, except for B1
(Training: mostly because it currently doesn’t exist), C1, second part only (some type of
burn plan) due to legislative barriers to Ag burning. We need to develop explanation and
reasoning appropriate to Ag; and use the Ag survey to develop specific Ag examples for
each.
Comments/Discussion:
--You can’t view visibility in isolation; regulatory processes vary greatly between
regional haze and visibility.
--The BSMP framework is to manage smoke and impacts, not reduce them; an ESMP
brings you more into control, reduction, and at the regional level. This issue of “Manage”
versus “Control” that the NBTT brought up in their Policy needs to be addressed further
by the ESMPTT. The ESMP must show more refinement, such as what reduction
measures were taken. Assess local effects and regional effects; analysis looks at more
items and on a broader scale.
--Very refined inventories are needed in the BSMP (for local impacts) and the ESMP (for
regional impacts).
--Local SIPs address impacts to non-attainment areas with a fine boundary where impacts
are addressed, and not addressed beyond that boundary.
--BSMP needs some refinement to address impacts from the development of an ESMP.
We need to address items such as what is in an Enhanced program that is not in the basic
program? What do we need for both basic and enhanced: refinement of inventory,
modeling, analyses on smaller scale.
--Do we want to consider combining BSMP and ESMP into a single, contiguous
document? Easier on the user and would ensure more continuity between the two. Group
agreed it would be well worth considering.
--In re: F1, where are we on baselines? How many burners do we have, what kind of
problems are we addressing, etc. to address what type of smoke management program
you have (basic or enhanced).
--NOTE: Identify and characterize air quality, emission, visibility baseline, for each
region, based on developed criteria. This would be a developed framework, for where to
start.
Chronological Record II - 26
--What are the criteria/triggers for a BSMP? All SIPs?
--The CAA requires smoke management programs. This is now coming to the forefront
due to the RHR. States should be doing BSMP, but haven’t.
--In re: B5, contingency plan -- clarify difference between having contingency plans in
place versus having the authority to carry them out. This lack of authority can create a
time lag between exceedance and corrective actions. Note: contingency plans - do
burners have authority to act on these?
-- In re: C1, FLMs have 10-year plans, problem of timeframe in planning. C1 addresses
burn plans. Immediate feedback is needed for burn plans if the 10-year plan affects.
--The whole key to the success of any plan is what in fact can be monitored or enforced.
Refer to E. Best thing is to make these things work and avoid litigation.
The basic elements of the BSMP should not be applied in a blanket fashion; rather, they
should be a tiered program. For example, Ag burners would only need burn plans for
burns that have the potential to impact sensitive areas. Regulatory agency could address
this in their permitting process. Burn plans could be annual or individual plans.
--In re: A -- If you have a prescription indicating a specific burn window, and more than
one permitted burn achieves their window at the same time, this could be a problem. In
this case, permitting is not enough; we have to make sure burns are allocated on any
given day.
--In re: Scope and Applicability -- ultimately whatever we do will be administered by
rules and regulations at the state and fed level. How can we impact state SIPS to lever
against state legislation barriers? NOTE: In our document refer to EPA’s RHR language
addressing states need for smoke management.
-- In re: C4, air quality monitoring – we cannot act as though it is sufficient right now.
Because of the local nature of some impacts there should be more special purpose
elements for monitoring in appropriate areas. [Scott captured this comment made by
Evan]
III. Review Current ESMP Elements (M. Ziolko)
Agreed: ESMPTT will work toward a final deliverable of one Guidance Document for
Smoke Management Programs that includes both BSMP and ESMP. This will mean more
work for the ESMPTT, but will result in a more valuable end product. Note: one potential
problem with combining the two is getting one large document approved through WRAP.
ESMPTT started with the RHR, the Grand Canyon Recommendations and the FEJF
Workplan and made them the basis for the ESMP elements.
Chronological Record II - 27
The ESMPTT is currently working with the following seven elements:
1) Emission Tracking
Workgroup status: have developed a list of items that would be tracked,
the list is not prioritized, it can be added to. Vickie K. will report to group
on 12/7 for input.
2) Emission Reduction
Workgroup status: haven’t received anything from the group at this time,
but they do have an outline
3) Emission Goals
Workgroup status: Mark Fitch has done a white paper on an Annual
Emissions Goal Methodology, which the group will discuss on 12/6.
Question here is: does the ESMP still have an emissions goal element? Or
is the task to develop an Annual Emission Goal Methodology that is a
companion to the ESMP Guidance Document? Wait to answer until after
the 12/6 discussion.
4) Information Tracking
Workgroup status: nothing from this group yet, what do we need in an
ESMP?, address Regional Haze, to meet the needs of emission tracking
5) Modeling
Workgroup status: very skeletal so far, needs a lot of work. Several
individuals have discussed and developed some ideas we need to share in
and among the modeling group. To determine what models we will use,
when do you model, etc. The group will ID where to go from here. There
will be a conference call on this 12/12 – contact Suraj for details. Bob Palzer
wants to be involved.
6) Regional Approach/Coordination
Workgroup status: draft of how to do inter and intrastate coordination,
regional coordination on a WRAP basis, some modeling elements,
notification and monitoring needs for coordination. Greg Z. will report to
group on 12/7 for input.
7) Funding
Workgroup status: originally was considered one of the ESMP elements,
now may be put into another section (perhaps Program Administration).
Workgroup has fleshed this out well -- Contains the wildland survey data,
pretty complete list of what is being used as funding for smoke
management programs. Note: cooperative funding will be a MUST
element of an ESMP!
Chronological Record II - 28
Comment/Discussion:
--ESMPTT will need to consider the progression of developing an ESMP over time for
each of the elements, as part of its work. We are charged with making this a progressive
implementation. Tracking will address inventory development. Modeling will be
completed on different levels to meet different needs, and tracking should capture this.
--Suggest changing Emissions Tracking to “Emission Inventory and Tracking”, then
bullet the four components under title. Not adopted.
--Retrospective vs. real time inventories, make initial guess and use it to make decisions
and then refine.
--When workgroups are having conference call, please broadcast the call-in information
to the entire ESMPTT so that all who want can participate.
IV. ESMP Element Refinement: (Started on 12/5 p.m. and completed 12/6 p.m.)
Agreed: To clarify each element, the group decided that a narrative answering the basic
5Ws (Who, What, Where, When, Why) would be written for each element to be returned
by the Workgroup Lead noted below to Mike Ziolko via email NO LATER THAN COB
12/21/01.
Note: You may want to start with the Why (rationale). ALSO: remember to consider the
two filters of the RHR Criteria and the NBTT – FEJF Memo items (see detailed list of
these on page 11 below).
1) Emission Tracking* (relates to BSMP A1, B7, C1-3, F1)
Who does it?
What do they track? (See list started -- remember to note terms for Glossary!)
When (seasonality, etc.)
Timeline (step wise progression, phased in)
Why do they do it? (Rationale) -- e.g., Emissions Tracking enables the
demonstration of reasonable progress.
In addition: for what purpose(s)? – e.g., inventory, modeling, status, trends, etc.
Where is the tracking needed? Where will it take place? (landowner,
geography, etc.)
*Remember: this is universal for ALL fire sources!
Workgroup Lead: Vicky Komie
2) Emission Reduction (relates to BSMP B3, B7, moved Alts. to Burning -- see below)
Who does it?
What do they do and How? (see BSMP)
When? (seasonality, etc.)
Timeline? (step wise progression, phased in)
Why? (Rationale)
Where?
Chronological Record II - 29
Workgroup Lead: Scott Kuehn
3) Impact Reduction (relates to BSMP B3-5, C2, G2, added this element)
Why?
What? (do they do; list of how/techniques)
When? (do they do it; seasonality, etc.)
Timeline (step wise progression, phased in)
Where (is the tracking needed and where will it take place, landowner and
geography)
Workgroup Lead: Scott Kuehn
4) Alternatives to Burning (relates to BSMP B2, B7, separated from #2 above)
Why? (Rationale)
Other 4 Ws
Timeline (Phased in, see Frances’ group).
In addition, consider: is this an ESMP element like the others or a tool or
method?
Coordinate with Finneran’s Group on this!
Also, should the title of this be changed to “Non-burning alternatives”? –
what we mean here is alternatives that do not involve lighting a match on
site. Let’s be clear.
ESMP might have to require justification for why no alternatives are used.
Alternatives should be tracked!
If alternatives are chosen, and emissions are not produced, will anyone
know, how would you track it, etc.?
Incentives?
Workgroup Lead: Ann Acheson
Emission Goals (delete from ESMP Elements)
Agreed: This is no longer an ESMP Element – Emissions Goals will be
referenced in the introductory material in the Guidance Document and
linked to the Annual Emissions Goal Methodology. See Emission Goal
Methodology Discussion below for Workgroup Assignments.
[Group ended 12/5 session here – continued this section on 12/6.]
December 6 ESMPTT Meeting
Participants: Mike Ziolko, Co-Chair/Oregon Dept. of Forestry; Jeff Schmidt, USDA-
NRCS/BLM; Scott Kuehn, Plum Creek Timber; Vicky Komie, NM Air Quality Bureau;
Suraj Ahuja, USDA-FS; Evan Shipp, San Joaquin Valley APCO; Pete Stewart, USDA-
FS/SW Region; Mark Fitch, AZ DEQ; Greg Zschaechner, Utah Interagency Smoke
Management; Dennis Haddow, USFW; Marcus Schmidt, BLM/Colorado; Pete Lahm,
FEJF Chair/USFS; Crystal Loesch (for Ann Acheson, ESMPTT Co-Chair), USDA-
FS/Region 1; Rebecca Reynolds, Facilitator.
Chronological Record II - 30
12/6 ESMPTT Meeting Agenda
I. ESMP Element Refinement cont’d.
II. ESMP Criteria
III. Annual Emissions Goal Methodology
I. ESMP Element Refinement: continued
5) Information Tracking (relates to BSMP F1, 2nd sent.; includes Visibility Monitoring)
• Emissions (how is this different from 1 Emissions Tracking above?)
• Ambient Monitoring (reference Group working on this)
• Non-burning alternatives (ditto)
• 5 Ws application
Memo needed to the ETT and Alternatives to Burning TT asking what they need for SIPS
– Mike Z. will draft and get Vicky Komie (Emissions Tracking) and Marcus Schmidt
(Information Tracking) to review.
Need a review of any systems out there. Use the SMP Wildland and Ag Surveys to
identify the states that are tracking, then write to these and request information on their
tracking elements. Do this ASAP.
Workgroup Lead: Marcus Schmidt
6) Technical Tools (relates to BSMP??)
(replaced “Modeling and Interpretation” after much discussion)
The tools include: Modeling, Monitoring, GIS, and maybe Non-Burning
Alternatives (Ann A. will still treat Non-Burning Alts as Elements – group will
review at January meeting in Portland)
5Ws, plus remember linkage to….
• Regional Coordination
• Planning
• To demonstrate impact reduction
• Demonstrate attainment of NAAQS
• Other
ADD: Regional tracking center (some future proposal??)
7) Regional Approach/Coordination (relates to BSMP A3)
• 5 Ws
Workgroup Lead: Greg Zschaechner
Funding Mechanisms (deleted from ESMP Elements)
Agreed: Funding was considered more of a Program Administration issue, and the
group agreed to move it to the section outlined below as a separate section of the
Guidance Document. (see below)
Chronological Record II - 31
NEW SECTION: PROGRAM ADMINISTRATION
The group agreed that a section dealing with the administrative issues of Smoke
Management Programs would be beneficial. Funding Mechanisms was moved
here, with the other items listed below.
Funding
Statutory Authority
Surveillance and Enforcement
Public Notification
Burner Qualification
Program Evaluation
Workgroup Lead: Gretchen Barkmann*
*Gretchen was not at the meeting, but the group hoped that she might be willing to take
on this new section. The work she did on Funding was excellent. Mike Ziolko agreed to
contact her about it, brief her, and support her in developing product in this area, if she is
amenable. Apply the 5Ws as appropriate, developing something for review by 12/21/01.
ESMP Element Filters: RHR & NBTT Memo
In relation to the Elements, the group was reminded of the RHR section that lists six
criteria upon which all enhanced smoke management programs must be based. Each of
the workgroups developing ESMP Elements will need to consider these in their work.
They are as follow:
1) Law
2) Economics
3) Visibility Effects
4) Land Management Objectives
5) Efficiency
6) Emissions Reduction Opportunities
Also, the NBTT submitted a Memo to the FEJF making them aware of a number of
issues that had come to the NBTT’s attention during the course of its work. Some of
these issues relate directly to the work of the ESMPTT. Again, all of the ESMPTT
working groups will need to consider the following in their work:
1) Natural versus Anthropogenic Emissions
2) Non-mandatory Class 1 areas
3) Cultural Resources (Tribal)
--in re: the feasibility of alternatives
4) Step-wise Progression of SMPs
5) “Manage” versus “Control”
6) Guidance/reference to what is feasible vis-à-vis alternatives to burning
If you are unclear as to any of the above, please consult the RHR page 35771, Sect. 6, iv.
And for the NBTT issues, please read the Policy for Categorizing Fire Emissions (handed
out hard copy at the San Diego Meeting) as well as the NBTT draft Memo to FEJF that
itemizes and explains the ESMP issues (also distributed at the San Diego Meeting).
Chronological Record II - 32
II. ESMP Criteria (Triggers)
Pete Lahm provided some background for the discussion on ESMP Criteria. His points
included:
1) According to the RHR, the distinguishing point of an ESMP is that it considers
visibility, in addition to nuisance & health.
2) What the RHR does not specify is under what circumstances the ESMP applies.
3) The BSMP is understood to be a beginning point for the ESMP.
4) In the RHR referencing the GCVTC Recommendations mentions establishing
criteria.
5) Since there is a jurisdictional element to the criteria, and it probably does not
make sense for an ESMP to be triggered by a single, isolated event, the ESMPTT
developed a matrix as a way to address this. (At the Park City Meeting)
6) The matrix, however, is quite complex, and could possibly be pared down to its
priority elements. What might those be?
The group discussed some of their operating assumptions:
BSMP will be there-ESMP builds on top of it.
BSMP addresses nuisance and health issues.
ESMP adds visibility.
Trigger is Regional Haze for ESMP, but ESMP would be negligent if it did not
consider nuisance and health concerns – will do so since it builds on BSMP.
Regional Haze Rule is the ONLY statutory trigger for ESMP.
ESMP Criteria are based on Air Quality problem(s)
There is a threshold for ESMP.
And then held a lengthy discussion concerning what circumstances would trigger the
need for an Enhanced Smoke Management Program. Some of these were:
• Objective Values
Ranking
Weighted value scale on a couple of criteria
• 3 or more Class I areas in a state
• Protection of 20% best days**
• Class I proximity
• Emission Density
**If you can assess attribution to degradation of the best or maintenance of the worst
days, then…ESMP. Note: can do with existing data, but it is an assessment process and
to do it with all IMPROVE data is 2 years off (lag-time issue).
The group then asked does RHR Sect. 309 automatically trigger ESMP? And the group
agreed that, YES, it does. The group then considered whether that interpretation of the
RHR made the development of ESMP Criteria moot, and decided YES. Therefore it was
Chronological Record II - 33
decided that according to the RHR, the ESMP is triggered by the State going under Sect.
309.
The group then asked what of the states going under Sect. 308? It was agreed that it
would be optimal if all states considered visibility in their SMPs, and that, like the NBTT,
the ESMPTT would address in the introductory section of the Guidance Document its
recommendation to treat both 308 and 309 states the same with regard to SMP
development. The ESMPTT will work with the rationale developed by the NBTT and
modify where appropriate.
III. Annual Emissions Goal Methodology
The group clarified that the development of an Annual Emissions Goal Methodology is a
separate task from developing the ESMP Guidance Document for the ESMP as outlined
in the RHR (p.35771, sect.6, v.). Although these two documents will undoubtedly
reference each other and will need to be linked, they are two distinct deliverables.
According to the RHR the goal of the Annual Emissions Goal Methodology is:
“to minimize emission increases from fire to the maximum
extent feasible.” --RHR, p. 35771
The group discussed the scope of the Goal: regional Haze or beyond? It was felt that if
only regional haze, that would need to be made clear in the Goal introductory section –
i.e., implications to ozone, PM2.5 not addressed here. Further, the group will recommend
that this apply to both 308 and 309 states. The underlying assumption here will be that
ALL emissions will be tracked (see Policy on Categorizing Fire Emissions).
Opening Comment/Discussion:
--I am concerned about needing to burn, to restore ecosystem balance, and not wanting
the Annual Emissions Goal to prohibit this. (Goal-not to inhibit burning).
--Are we going to set a number? Five-year period…? You could set the number not
necessarily as a cap.
--The number that we choose could be softer and may not need to have dire
consequences.
--There needs to be some sort of backstop on that number; industry will not support just a
paper exercise.
--The Emission Goal should be something that in some circumstances would inhibit
burning -- anything else would not be a viable approach to air quality. The terminology
in the RHR does differ between static sources and fire. The Goal also need not be as
restrictive as industry regulation. However, it does need to be nearly as serious as
stationary source regulation. A cap is not the only way, but I feel the FEJF must establish
Chronological Record II - 34
a legitimate goal that is track-able and for which folks are held accountable. There is an
equity issue here.
--The goal would not be a decreasing goal, but would also not be so high as to make it
impotent.
--The goal also addresses private landowners, not just FLMs.
--Yes, but the lion’s share of the acreage is FLM.
--The goal could be associated only with an increase.
--Treat all fire emissions sources equitability and address air quality legitimately. Who
burns is irrelevant; minimizing emissions is what’s important.
--FLMs have a unique problem: fuel loading. This makes a cap for them much more of a
problem than for Ag landowners.
--Do we set the Goal for emissions increase? Or for the whole package? Do we include
wildfire or not?
--Methodology for reducing emissions is different for FLMs and Ag. All Ag. burning
will eventually be “Anthropogenic”, whereas FLMs are working toward all “Natural”
(when “anthropogenic” restoration burning is done, all will be “natural” maintenance
burning).
--There are two aspects to this: 1) are we looking at an emissions goal or minimizing
emission increases? Do we go beyond minimizing emission increases? 2) How do we
deal with the wildfire in the RHR? Include or exclude wildfire?
--The GCVTC recommendations include both. Although wildfire emissions may be
excluded from the Emissions Goal, it could be used to modulate the Emissions Goal for
other types of fire -- in fact, this will happen to some extent naturally.
--Do we need to address the natural dynamic? (Operational Management)
--Yes, although there is an operational checks and balances system. It will still probably
be necessary to link it to something more tangible than the system that is in place.
--Generally the checks and balances system in place is a cooperative effort at best.
--We cannot rely on the manager to operationally comply with the language of the RHR.
--The oversight role is important and needed, but if there is a management scheme for
this it can work toward enforcement.
Chronological Record II - 35
--The PM 2.5 has the potential to shut down prescribed fire.
-- I recommend outside influences: SIP process, stakeholders. What happens locally will
be way more restrictive than what we do here.
--Who will use this goal? And what will they need?
--Agreed: the Goal must not be totally benign. We need to figure out how we will
average – the averaging period/scheme. There must also be an accountability mechanism
built in. RHR does allow states to further develop/determine what we set as the Goal and
Methodology.
--We need to have at lest 2 choices for how states set up their SIPS
--But the end point must be the same.
--Yes, but the two different types of burners (FLM & Ag.) have substantially different
issues. So we may need separate tracks for them.
--Keep in mind that other sources (stakeholders) also contribute to emissions and have
their own plans.
--WRAP is not a regulatory entity, so States can ignore the tools we develop.
--Yes, but forcing mechanisms do exist. We need to create a framework that allows
implementation consistently. Universal application.
--Can we build in enough latitude to make these universally workable? –Yes.
--The dual element for land types (Ag and FLM) is on the table: can we leave Ag out
since they are not projecting emission increases?
--No, we need to consider ALL for equity’s sake.
--In the context of goal (minimizing increased emissions), Ag is constant or declining, so
in fact, we are not addressing them. We should suggest that this assumption (that Ag. is
constant or declining) be re-tested every 5 years to make sure the assumption still holds.
And we need to make clear the conditions of this assumption.
--It is difficult to work Ag. in anyway if we don’t know what they do, so we should focus
on wildland.
--But if we don’t know the Ag numbers, should we ignore them?
--What is expedient now, for us today? --Go with the Ag. Assumption (see comment in
bold above)
Chronological Record II - 36
--We need to develop a consistent method that we tie-in with tracking and quantify
emissions as they relate to fire in order to arrive at a regional goal.
Annual Emission Goal Issues:
1. Spatial/Temporal Averaging
• Starting Point (1996? 2004? -- May have emission increase before then, but
SIP implementation deadline could be good to tie with.)
• Averaging period
• What time of year to start? – Calendar year cycle? Wildfire season? Other?
• Regional-Geo/Political
(Use FEJF emissions calculation for Emission Tracking – Link to ETT)
Brainstorm on Spatial:
Wrap-wide, including NV, AK, Hawaii
State by State
Class 1 source receptor relationship
Multi-State
Regional (e.g., NW, etc.)
Airshed/Air Basin
Entity (e.g., USFS, Forest/District, Administrator, Ag. sector)
County
National
International burning?
Brainstorm on Temporal: Methodology for the averaging period to set the goal
(e.g., running average, block average)
Daily
Monthly
Seasonally
Day of week
Annually
Periodic (e.g., every 3, or 5 years)
Climatologically
Historically
Workgroup Lead: Mark Fitch
2. The Number
• In what terms? Pollutant? Acres? Emissions? Ground-up or Top-down
developed?
• Number should be evaluated every 3-5 years and adjusted either way.
Workgroup Lead: Mark Fitch
3. Trading (Between Fire Sources; Fire Sources with other sources)
The group discussed the pros and cons of including trading:
Pros:
1) Alts to burning = credit? Incentives.
2) Does not have to be implemented immediately.
Chronological Record II - 37
3) Two sources: intersource (between fire and other sources) and
intrasource (between fire and fire type)
4) Equity: deals with equity issue among all sources.
Cons:
1) Complex: accounting, impact, all emissions
5) Temporal issue: inter-annual variability makes trading problematic
between sources (fire and others).
6) Fires are high PM making them a questionable market for trading.
General Comments: You can trade outside of Fire. If we trade among each other
we will eventually all go down. Trading becomes valuable when you open it up to
all sources.
White Paper Developer: Frances Bernards
4. Source Type
Is it an individual source (e.g., Plum Creek) or source sector (e.g., Ag.) See
“Number” for linkage to top-down/bottom-up development question
RHR: excludes “Wildfire”
NBTT: distinguishes between “Natural” and “Anthropogenic”
Possible Options:
• All Fires
• Exclude all wildfire and natural
• Exclude sources that are not increasing
• Exclude Ag. (with conditions) *See Ag Assumption above comment in
bold
Why not Ag.?
1) Poor numbers difficulty in implementing goal
2) Currently not as variable
3) If not increasing, shouldn’t be included.
Workgroup Lead: Mark Fitch
5. Accountability/Backstop (a.k.a. The Penalty)
Group brainstorm on possible penalties:
Fine
Reduce acres (curtailment of burning – see Oregon & Washington approaches
on this)
Other issues:
Who will be penalized/held responsible? Individual or mass?
When? After 1, 2, 3 exceedances??
Under what circumstances?
2 Tiers: State & Burners
o States: this document will acknowledge EPA oversight responsibility,
done on a Class 1 by Class 1 basis
o Burners: this will address how States will hold burners accountable
(penalty)
Ideas for how States can hold burners accountable:
Chronological Record II - 38
Lose right to comment on PSD permits (not equitable – not everyone has
Class 1s, but interesting)
All burners required to use ESMP
Burners lose burn certificate
Formal agreement between states & Class I areas for burning
Credits taken away
Must develop system to allocate burn targets to individual burners.
If they exceed the goal 2 years in a row the goal becomes a cap.
Fines
Revision or development of alternative fuel treatment programs.
Required to implement environmental treatment program, e.g., tree planting
Workgroup Lead: Dennis Haddow
6. Incentive Program
Equity: make sure I get incentives if I decrease emissions.
Group ideas for incentives if Goal is not exceeded:
By use of this system: Increase in alternatives for burning equals increase
in goal number.
Reduction of fee rate (pay by emission produced)
Decreased emissions gives you a higher burn priority
Utilization of alternatives equals higher burn priority
One Forest’s good offsets another Forest’s bad
Workgroup Lead: Scott Kuehn
December 7 ESMPTT Meeting
Participants: Mike Ziolko, Co-Chair/Oregon Dept. of Forestry; Jeff Schmidt, USDA-
NRCS/BLM; Scott Kuehn, Plum Creek Timber; Vicky Komie, NM Air Quality Bureau;
Evan Shipp, San Joaquin Valley APCO; Pete Stewart, USDA-FS/SW Region; Mark
Fitch, AZ DEQ; Greg Zschaechner, Utah Interagency Smoke Management; Marcus
Schmidt, BLM/Colorado; Pete Lahm, FEJF Chair/USFS; Crystal Loesch (for Ann
Acheson, ESMPTT Co-Chair), USDA-FS/Region 1; Rebecca Reynolds, Facilitator.
12/7 ESMPTT Meeting Agenda:
I. ESMPTT Workgroup Reports
II. Glossary
III. Outreach
IV. Schedule, Roster, Meeting Notes
I. ESMP Elements Workgroup Reports
Regional Approach/Coordination
Greg Zschaechner presented his revisions of the Regional Approach/Coordination
material he has emailed to everyone. Greg recorded all comment and will make revisions.
The following represents the changes that were discussed:
Interstate Coordination:
Chronological Record II - 39
Unit measurement will be opened to accommodate programs that will be
utilizing this information (e.g., UTM vs. Lat./Long. Not TRS)
Change “adjoining downwind states and sensitive receptors”, drop the word
downwind
Suggest multiple GIS layers to represent sensitive receptors
Population exposure is a sensitive receptor
Add a layer for monitoring systems (e.g., EPA, State, Local, etc.)
Change subhead “inter-state coordination” to “information collection”
Add a layer for selective meteorological sites
Inter-/Intra-State Coordination:
Levels of coordination (e.g., inter-intra, regional, coordination centers, etc.)
Funding of coordination
Change “Regional-level center” to “State or local center” (2nd para., 2nd sent.)
Phased approach with recommendations at each level
Programs are currently driven by NAAQS and nuisance issues instead of visibility
issues -- local or states should do assessment of what conditions occur that prompt
looking at regional transportation, not just local issues.
Modeling:
Leave this section in, but as a reference. Drop BlueSky, etc., -- pick up under
Modeling in Technical Tools, Element #6 above
Monitoring: Same
Add WinView (software), for public education and awareness
NOTE: Develop an Appendix with a list of all recommended software (e.g., Blue Sky,
WinView, NFSPUFF, etc.)
ESMPTT will review the new revision with his work on the 5Ws at the January meeting.
Emissions Tracking
Vicky Komie then presented the latest material on Emissions Tracking. The following list
of fields to be tracked were presented and discussed:
Note: Wildfire and Ag components! -- there is a need for tracking to be universal for all
fire sources!
1) Entity
2) Burn name
3) Purpose of burn
--Maintenance
--Fuel Reduction
--Etc.
4) Natural or anthropogenic
5) Location (e.g., lat long)
6) Burn in or near Class I area?
Chronological Record II - 40
(Define near!)
7) Burn within clean-air corridor
If lat/long is mapped it will indicate if the burn is within a clean-air
corridor (Note: Acknowledge that as the RHR progresses this will be true,
but currently the descriptions for clean air corridors are vague.)
8) Emission Reductions
--Category
--Etc.
9) Emission reductions-calculations
See checklist
10) Post-burn daily estimated emission
--Acreage
--Fuel Load
--Etc.
11) Justifications for not using alternatives
--Economics; Benefits of burning
--Feasibility of burning
--Etc.
12) Category of burning (AG, Wildland, Wildland Urban Interface, etc.)
13) Airshed
NOTE: Need Memo to ETT (see Information Tracking ESMP Element #5 above)
make sure the purposes of what is to be tracked are clear to tie-in with ETT.
II. ESMPTT GLOSSARY
Throughout the meeting the group listed possible terms they would like to include in the
ESMP glossary. In addition to the list made during the meeting (represented below), the
group also received a hard copy of an extensive glossary that Colin Hardy has compiled
for Smoke Management. Included in his glossary, is the NBTT glossary developed as an
appendix to the Policy for Categorizing Fire Emissions.
Mike Ziolko will review Colin’s glossary and make a recommendation at the
January meeting for which terms he feels the ESMPTT should include. Mike’s draft
will be ready 12/21/01.
VISIBILITY (include regional haze? Plume blight? – yes! See FEJF definition)
PLUME BLIGHT-example of nuisance
REGIONAL HAZE
IMPACT-NAAQS
SMOKE SENSITIVE
FLM BURN PLAN
ENTITY
SOURCE
IMPACT REDUCTION, (“Manage”)
EMISSION REDUCTION, (“Control”)
Chronological Record II - 41
NUISANCE-see, taste, smell; e.g., soiling of clothes on clothesline
ALTERNATIVES TO BURNING, not burning, or NONBURNING ALTERNATIVES,
no prescribed fire, no ignition source
CLEAN AIR CORRIDOR
NON-ATTAINMENT AREA
SMOKE EFFECTS (see FEJF definition, p2)
III. ESMPTT Outreach
Ag & Rangeland are concerns for the ESMPTT, as well as for the FEJF in general. The
FEJF discussed ideas for getting increased participation in its work during the Forum
session. (see FEJF Meeting notes for San Diego on the FEJF website)
As far as ESMPTT Ag. participation, the TT can go to the Communications Committee
for names, but ESMPTT will need to make contact directly. Mike Ziolko will follow-up
on this.
Jeff Schmidt (NRDC) offered to prepare a white paper on outreach for the ESMPTT. He
will have this by 12/21/01 for the Co-Chairs to review.
It was noted that the ESMPTT also has the extensive NBTT Senior Staff workshop list to
use. Mark Fitch will get this & other relevant NBTT material to Jeff.
IV. ESMPTT Schedule, Roster and Meeting Notes
!!NEW ESMPTT Meeting: January 7 & 8, 2002 – Portland, OR!!
Location tentatively set for The Vintage.
Monday, 1/7 Noon – 5:00 p.m.
Tuesday, 1/8 8:00 a.m. – 5:00 p.m.
Rebecca will get arrangements going thru WGA and will email the TT when she sends
out Meeting Notes on Tuesday 12/11/01.
The purpose of this meeting will be to review all workgroup progress that is due on
12/21/01 COB to Mike Ziolko (please cc: both Ann Acheson & Rebecca Reynolds – see
roster for email addresses.)
Rebecca R. will email the TT the San Diego Meeting Notes, with an updated Schedule
and Roster on Tuesday, 12/11/01.
Chronological Record II - 42
Handouts for San Diego Meeting
San Diego, California
December 4 – 7, 2001
Enhanced Smoke Management Program
Document Outline (Draft)
I. Executive Summary
II. Introduction
A. Background (GCVTC/RHR)
B. BSMP/ESMP
C. 308/309
III. Guidance
A. ESMP Criteria
(What circumstances trigger the need for an ESMP?)
B. Elements of the ESMP
(The ESMP defined)
IV. Guidance Annotation
A. Criteria
Regulatory Context
Relate to BSMP
B. Elements (Explanation, Examples, Methodology)
Emissions Tracking
Alternatives to Burning/Emissions Reductions Techniques
Modeling
Regional Approach/Coordination
Funding Mechanisms
V. Appendices
A. Glossary of Terms
B. Other?
Chronological Record II - 43
Handouts for San Diego Meeting
Guidance on ESMP Criteria and Elements
DIGEST
Grand Canyon Visibility Transport Commission
States, tribes, state and federal land management agencies and private parties should
create and implement management programs that address public health, visibility and
land management objectives by the year 2000.
ESMP should consider factors:
- Efficiency
- Economics law
- Land management objectives
- Reduction of visibility impacts
Regional Haze Rule
Programs related to fire. The plan must provide for:
1. Fire Management Planning. Documentation that all Federal, State and private
prescribed fire programs within the State evaluate and address the degree visibility
impairment from smoke in their planning and application. SMPs include: actions to
minimize emissions, evaluation of smoke dispersion, alternatives to fire, public
notification, air quality monitoring, surveillance and enforcement, and program
evaluation.
2. A statewide inventory and emissions tracking system of VOC, NOx, elemental
and organic carbon, and fine particle emissions from fire.
3. Identification and removal wherever feasible of any administrative barriers to the
use of alternatives to burning in Federal, State and private prescribed fire programs
within the State.
4. ESMPs for fire that consider visibility effects, not only health and nuisance
objectives, and that are based on the criteria of efficiency, economics, law, emission
reduction opportunities, land management objectives, and reduction of visibility
impact.
5. Establishment of annual emission goals for fire, excluding wildfire, that will
minimize emission increases from fire to maximum extent feasible and that are
established in cooperation with States, tribes, Federal land management agencies, and
private entities.
Chronological Record II - 44
EPA’s Interim Policy
Purposes of SMPs are to mitigate the nuisance and public safety hazards posed by smoke
intrusions into populated areas; to prevent deterioration of air quality and NAAQS
violations; and to address visibility impacts in Class I Federal areas.
Basic Components:
A. Authorization to Burn
B. Minimizing Air Pollutant Emissions
C. Smoke Management Components of Burn Plans
1. Actions to Minimize Fire Emissions
2. Evaluate Smoke Dispersion
3. Public Notification and Exposure Reduction Procedures
4. Air Quality Monitoring
D. Public Education and Awareness
E. Surveillance and Enforcement
F. Program Evaluation
G. Optional Air Quality Protection
AAQTF
Tier 2 Smoke Management Program: a voluntary program that is designed for those
States, or those areas within a State, where agricultural burning for resource benefits
would be expected to cause or significantly contribute to violations of the NAAQS or
visibility impairment in Class I areas. A Tier 2 SMP would be indicated when pollutant
emissions from agricultural burning combine with geographic and meteorological
conditions likely to result in air quality values that may exceed the NAAQS.
Parameters are designed to minimize air quality impacts to surrounding populated areas
and the regional airshed in general.
1. Authorization to Burn
2. Reducing Air Pollutant Emissions
3. Smoke Management Program Components
4. Producer/Public Education and Awareness
5. Surveillance and Enforcement
6. Program Evaluation
FEJF Workplan
Objectives of BSMP & ESMP
Develop criteria and elements for prescribed fires, wildland fires managed for resource
benefits/prescribed natural fires, and agricultural fires. Objectives are to ensure:
1. No health-based NAAQS are exceeded
2. Nuisance smoke is mitigated
3. Smoke impacts on visibility are minimized in Class I areas and meet the
GCVTC recommendations.
Chronological Record II - 45
ESMP will focus on the issues of advanced emissions reduction techniques and the
reduction of visibility impact.
The recommendations developed by the FEJF for an ESMP will provide guidelines for
the managing of emissions from fires with the main purpose to reduce visibility impacts
in Class I areas. An ESMP will include all aspects of a BSMP, plus recommendations of
when & where an ESMP should be implemented. Criteria for use of an ESMP include,
but are not limited to:
- When and where an ESMP should be recommended
- Reduction of visibility impacts
- Emission reduction strategies
- Alternative management practices
- Implementation schedule for the ESMP
An ESMP should consider:
- Emissions reduction strategies
- Alternatives to burning management practices
- Efficiency
- Economics
- All laws and statutes
- Land management objectives
- The reduction of visibility impacts in context of regional haze and cross
boundary transport.
Issues:
- An emissions tracking system for visibility impairing pollutants
- Accountable annual emission goals
- Alternative management practices and accounting system for non-burning
activities
- Emissions reduction strategies
- Visibility impact monitoring
- Modeling to aid in reduction of visibility impacts in Class I areas
- Local and regional coordination of fire activity
Chronological Record II - 46
Handouts for San Diego Meeting
Western Regional Air Partnership
Wildland Fire
Elements of a Basic Smoke Management Program
DRAFT – July 10, 2001 – DRAFT
DIGEST
A. Authorization to Burn
A1. Legal Authority to Authorize a Burn (page 14)
Recommendation: The regulatory authority should establish a means or system
to authorize a prescribed burn. The information concerning all approved burns
needs to be made available for emissions tracking and inventory purposes.
A2. Instrument or Tool Used to Evaluate a Burn (page 15)
Recommendation: The level of effort or extent of authorization should be based
upon the air quality impact (public health, NAAQS, visibility, and nuisance)
prescribed burning may have on an area. It is recommended that the regulatory
authority work with the land owners/managers to develop criteria for what level
of authorization should be required (based on acreage, emissions, potential
impact, etc.)
A3. Criteria to Approve a Burn (page 16)
Recommendation: Regulatory authorities should coordinate when burning is
close to jurisdictional boundaries.
B. Minimizing Air Pollution Emissions
B1. Burner Qualifications (page 19)
Recommendation: It is recommended that regulatory authorities consider a
minimum level of qualification for individuals conducting or approving burns.
This will help ensure that techniques for minimizing air pollutant emissions are
evaluated.
B2. Alternatives to Burning and Their Incentives (page 20)
Recommendation: It is recommended that alternatives to burning be evaluated
on all burns. These evaluations should be based upon all available alternatives
that are economically feasible to implement and that minimize other
environmental impacts while meeting land management objectives.
B3. Emission Reduction and Impact Techniques (page 21)
Recommendation: Emission/impact reduction techniques should be included on
all burns. These techniques should be economical to implement and minimize
other environmental impacts.
Chronological Record II - 47
B4. Impact Reduction (page 22)
Recommendation: Regulatory authorities should implement regulations that
state that a person may not cause or permit any emission that is injurious to
human health or welfare, animal or plant life, or property, or that would
unreasonably interfere with the enjoyment of life or property or intrude into any
smoke sensitive area. Regulatory authorities may need to implement setback
requirements for tribes’ sacred sites.
B5. Impact Reduction Contingency Plans (page 25)
Recommendation: Land owner/managers should have specific contingency
plans that will be implemented if smoke impacts occur or meteorological
conditions deviate from the desired condition.
B6. Monitoring Smoke Impacts (page 25)
Recommendation: Regulatory authorities should require that real and potential
smoke impacts be monitored while emissions are produced.
B7. Emission Reduction Tracking and Documentation (page 26)
Recommendation: Regulatory authorities should require documentation of
emission reduction techniques and estimates of their resulting emission
reductions.
C. Smoke Management Components of Burn Plans
C1. Recommendation: Federal land managers should include smoke
management components in burn plans as described in the Interim Policy.
Regulatory authorities should assist private landowners in preparing smoke
management components of burn plans for large fires that have the potential to
impact smoke sensitive areas. (page 31)
C2. Evaluate Smoke Dispersion (page 31)
Recommendation: Burn plans should include methods for evaluating smoke
dispersion impacts to smoke sensitive areas.
C3. Public Notification and Exposure Reduction Procedures (page 32)
Recommendation: Burn plans should include a notification process that is
responsive to potential or actual smoke impacts. Burn plans should also include
documentation procedures and contingency actions to be taken during smoke
intrusions.
C4. Air Quality Monitoring (page 33)
Recommendation: State ambient air quality monitoring networks and on-site
visual observations should be used to monitor smoke impacts. In addition, land
owners/managers and the regulatory authority should establish site-specific air
monitoring networks or practices.
Chronological Record II - 48
D. Public Education and Awareness
D1. General Public Education Programs (page 36)
Recommendation: Where appropriate, land owners/managers and regulatory
authorities should implement educational programs that are as aggressive as
possible. The level of effort should be based on the special needs of each area.
D2. Informing the Burn Community (page 37)
Recommendation: Regulatory authorities should provide training to the land
owners/managers regarding SMPs, and any other permit or rule requirements.
D3. Public Involvement in Planning Process (page 37)
Recommendation: Land owners/managers and regulatory authorities should
adopt policies to use aggressive outreach methods to solicit early and effective
public involvement in the planning and regulatory development process.
E. Surveillance and Enforcement
E1. Standards, Trigger Levels, Alerts, Requirements for Enforcement(page 40)
Recommendation: The regulatory authority should clearly establish criteria that
state when surveillance and enforcement should be conducted. It is recommended
that the criteria be established in statutory rules.
E2. Types of Monitoring and Surveillance (page 42)
Recommendation: Surveillance and enforcement should be tailored to achieving
compliance with applicable rules and laws.
E3. Enforcement Actions and Penalties (page 43)
Recommendation: Enforcement and penalties should be focused on repeat
violators and instances of NAAQS exceedances (or significant contributions to
NAAQS exceedances) or established visibility criteria exceedances/violations.
The regulatory authority should work with the land owners/managers to develop
criteria for what level of NAAQS and/or visibility monitoring is needed based on
acreage, emissions, potential impacts, etc.
F. Program Evaluation and Reporting
F1. Reporting (page 46)
Recommendation: SMPs should require annual reports for areas with high levels
of burning. The annual reports should serve as a “report card” and include
summaries of burn activity, burn restrictions, air quality data, significant smoke
intrusions, and complaints. Land owners/managers should provide adequate fire
information to regulatory authorities so they may develop accurate annual
statewide emission inventories.
Chronological Record II - 49
F2. Periodic Evaluation (page 47)
Recommendation: Each element of the SMP should be evaluated as often as
needed, but at least once every three to five years.
G. Optional Air Quality Protection
G1. Recommendation: Regulatory authorities and land owners/managers should
continually look for and investigate optional techniques, strategies, programs, and
alternatives to better protect air quality and reduce visibility impacts. (page 49)
G2. Special Protection Zones and Additional Requirements (page 49)
Recommendation: Consideration should be made to establish special protection
zones around smoke sensitive areas to provide additional air quality protection
requirements. Tribal religious areas should be considered for special protection.
G3. Performance Standards (page 50)
Recommendation: Performance standards should be established that trigger
additional requirements for issues such as visibility impacts, emissions,
complaints, and public nuisance.
G4. Additional Smoke Management Requirements if Performance Standards
Have Been Exceeded (page 51)
Recommendation: Regulatory authorities should establish procedures for when
performance standards are exceeded.
Chronological Record II - 50
ESMP Task Team Meetings
Portland, Oregon: January 7 & 8, 2002
Chronological Record II - 51
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Chronological Record II - 52
ESMPTT Meeting
Portland, Oregon
January 7 & 8, 2002
Agenda
Purpose of Meeting: To review all workgroup products submitted on 12/21/01 on both
the ESMP Elements and the Annual Emissions Goal Methodology, and to develop the
next steps for the ESMPTT.
Monday, January 7th Noon - 5:00 pm
I. Welcome Mike (Noon)
II. Presentation of Workgroup Products Ann (12:10 – 12: 45 p.m.)
ESMP Elements
Clarifying Questions/Comments
III. Group Review & Comment All (12:45 – 4:45 pm)
ESMP Elements
15 min Break as needed
IV. Review Tasks for Day 2 Rebecca (4:45 – 5:00 pm)
Tuesday, January 8th 8:00 am - 5:00 pm
I. Good Morning! Ann (8:00 am)
II. Review Prior Day’s Accomplishments Rebecca (8:05 -- 8:30 am)
III. Continue Review & Comment All (8:30 – 10:00 am)
ESMP Elements
IV. Break (10:00 – 10:15)
V. Presentation of Workgroup Products Mike (10:15 – 10:45 am)
Annual Emissions Goal Methodology
Clarifying Questions/Comments
VI. Group Review & Comment All (10:45 am – Noon)
Annual Emissions Goal Methodology
VII. Lunch (Noon – 1:00 pm)
VIII. Continue Review & Comment All (1:00 – 4:00 p.m.)
Annual Emissions Goal Methodology
IX. Develop ESMPTT Workplan to Next Meeting Rebecca (4:00 – 5:00 pm)
Chronological Record II - 53
ESMP Task Team Meeting
Portland, Oregon
January 7 & 8, 2002
Meeting Record
Attending: Ann Acheson, USFS Region 1 (ESMPTT Co-Chair); Suraj Ahuja, USDA FS;
Frances Bernards, UT DEQ; Brian Finneran, OR DEQ; Mark Fitch, Arizona DEQ; Mark
Gray, WDNR; Scott Kuehn, Plum Creek Timber; Pete Lahm, USDA FS AZ (FEJF
Chair); Gary Neuroth, AZ DEQ; Bob Palzer, Ph.D., Sierra Club; Jeff Schmidt, BLM, AZ
NRCS; Evan Shipp, SJVAPCD; Mike Ziolko, OR Dept. of Forestry (ESMPTT Co-
Chair); Rebecca Reynolds, RRC, Inc. (ESMPTT Facilitator)
Summary
I. ESMP
The group considered a tiered approach to the ESMP Guidance Document, and decided
to adopt it. There will be five levels to the ESMP that will accommodate the inclusion of
visibility into states and tribes smoke management plans. The work done by the Task
Team on the various ESMP elements will be integrated into the five levels, augmented by
an implementation timeline for each. This approach will be presented to the FEJF at the
Tucson meeting.
II. Annual Emissions Goal Methodology
The group considered a goal that would focus on the utilization of emissions reductions
techniques, rather than one that would attempt to quantify emissions levels. The operating
assumption here is that the more emissions reductions techniques are employed, the more
emissions will be reduced. The Task Team will present this to the FEJF at the Tucson
meeting.
III. Trading
The group considered including a trading program in both the ESMP and the Annual
Emissions Goal Methodology. At the end of the discussion, the majority of the Task
Team remained unclear as to whether they would support including a trading program or
not. The group agreed to have the trading program concept further fleshed out for
consideration at the Tucson ESMPTT meeting. The group would decide then whether or
not they want to include a trading program, and will present that decision to the FEJF.
IV. Assignments
1. Writing Team (Ann A., Scott K., Rebecca R., Greg Z. – if available)
Prepare drafts of both the ESMP Guidance Document and the Annual Emissions Goal
Methodology, based on the work accomplished in Portland. Both will be sent to the
ESMPTT and the FEJF as pre-work for the Tucson meeting.
Chronological Record II - 54
Email to FEJF & ESMP TT on 1/30
2. Trading Paper
Further develop the Trading Program concept for review by the ESMPTT in Tucson.
Frances B. -- due 1/23 to Co-Chairs & Rebecca
Email to ESMPTT on 1/30
3. NAAQS: BSMP ~ ESMP
Develop ideas for creating conformity and/or a cross link between BSMP and ESMP.
Evan S. with Suraj A. and Bob P. -- due 1/23 to Co-Chairs & Rebecca
Will be integrated with ESMP Doc.
4. Visibility Impact Assessment Options
Evan S., Mark F. and Pete L. will develop options for conducting visibility impact
assessment under Level 1 of the ESMP. -- Due 1/18 to Co-Chairs & Rebecca
Will be integrated with ESMP Doc.
Full Meeting Notes
Focus for Day 1, January 7, 2002 Focus for Day 2, January 8, 2002
1. ESMP 1. Finish ESMP
2. Review of Work Products 2. Trading Concept
3. Annual Emissions Goal
I. ESMP: A TIERED APPROACH
In San Diego, the idea came up of taking a tiered approach to the ESMP. Pete Lahm and
Mark Fitch said they would put together their thoughts on this for the next meeting. The
following represents the Tiered Approach they put forward for the group’s consideration.
Some underlying assumptions and outside input informed the development of the Tiered
Approach:
First: Pete presented ESMPTT progress to date at the recent IOC meeting. In light of the
huge disparity that exists between states’ approach to smoke management, the IOC did
not support a “one-size fits all” approach. Also, IOC did not think that having all states
end up at some future point in time at the same place with regard to SMPs would work.
Second: Taking into account the discussion in San Diego concerning the desire to create a
continuum between BSMP and ESMP, it would be optimal to take NAAQS / Nuisance
issues into account in ESMP. The Task Team will need to think more about how to do
this.
Chronological Record II - 55
Third: It is assumed that the ESMP adds the visibility component to BSMP, and that the
BSMP is based on the EPA’s Interim Guidance for wildland, and the AAQTF’s
recommended policy for Ag. Therefore,
ESMP=BSMP + VIZ (impact to all Class 1 Areas Need to make distinction
between Colorado Plateau and Others?)
ESMP is mandatory for 309 States according to the RHR, but we will recommend
universal application
Emissions Tracking vis-à-vis visibility is also mandatory across the board.
[Note: Rangeland is huge un-quantified source sector.]
With the above in mind, the Levels of the ESMP were proposed as follows:
Level I -- The main issue in Level 1 is: Are you having an impact or not?
Elements:
BSMP plus
[Note: BSMP = NAAQS primarily]
1. Emissions Inventory (How? Transmissometer Reading / IMPROVE?) By 2004*
2. Visibility Impact Assessment** by 2005 or
2006
[Alternative language: “Contribution to Visibility Impairment” (RHR p 35771)]
**Big Question: HOW TO MEASURE???
Trigger to move beyond Level I 1 deciview or more contribution to visibility
impairment in Class 1 areas
*This is the date for Visibility baseline (5 year span: 00-04)
Implementation: SIPs must be committed to by the end 2003 SIP…so by the end of
2004?
(SIP Approval ranges from 6 months to10 years!?)
Will there be a different implementation timeline for 308 and 309 states?
Level II
Elements:
All of the above, plus
1. Real time Reporting Process “Passive Coordination”
Level III
Elements:
All of the above, plus
Chronological Record II - 56
1. Alternatives to burning, other techniques to reduce emissions
Level IV
All of the above, plus
1. Regional Coordination “Active Coordination”
Level V
Elements:
All of the above, plus
1. “Smoke Czar” Full WRAP Region-wide Effort
Clarifying Points:
• Different Levels in different areas/sources in the state will be allowed
• No “backsliding” on existing SMP
-- However, one determining factor for ESMP Tiers is Visibility Impact, meaning it is
possible to move up or down Levels
• NAAQS will be included in Levels; what about Nuisance? TASK
• Define/Explain Trigger: TASK
20 worst days, 1 deciview at any Class 1 Area, Continuous contribution – not
additive
• Use NBTT rationale that creates a universal between 308 and 309. (Still maintain
308/309 distinction… and timeline will be different)
309: SIP 2003: 16 Colorado Plateau Class 1s
SIP 2008: All Class 1s
Tiered Approach Discussion
• Continuity between BSMP & ESMP – NAAQS in particular
Necessary for communicating to implementers (State Regulatory & Burners)
Evan may have ideas on this? He’ll develop with others. TASK
-- Need ¶ on BSMP ESMP, i.e., NAAQS, Visibility TASK
• Regional Impact? address through modeling
• What might be a recommended de minimus level? (See AAQTF; also: ETT
addressing)
• Meteorology -- factor in? In modeling? TASK
• Do any Level changes trigger a SIP revision? -- Don’t think so – do we need to
consider?
Visibility Impact Assessment Issues
• Uniform Methodology mandatory for equity
Method – progression, evolves over time, but must be uniform.
• Could use Photographs – time lapsed
Chronological Record II - 57
• WRAP could address task on Visibility Assessment
• What triggers movement up Levels?
If source sector contributes to impact on visibility (1 deciview or more)
Continued impact – 1 deciview or more
Trend oriented
Does it need a NAAQS equivalent? How to link?
• RHR has established criteria for a visibility baseline (RHR p.35766, also referred to
in Guidance Document for Tracking Progress p.1-2)
• What does Visibility Impact mean?
• Modeling is being done right now with an inventory. Will levels of emissions
indicate impact?
o Retrospective analysis on 20% worst days.
o Start with monitored data from a site… then model.
• What is “significant” – ESMPTT defines starting point as 1 deciview for all source
sectors.
[This may be challenged & we may need to re-define]
• What if Agriculture meets 1 deciview – does that mean that ALL Ag moves up the
tier? Or only those sources near Class 1? States can decide how they want to handle
- different levels in different areas or not.
Will EPA be ok with the state addressing the SIP in a source-specific manner?
EPA cannot require “cookie cutter” application.
• Out of State Impacts (in RHR) to consider
• Add into Technical Tools Rationale: we all need to be using the same tools –
uniformity in analysis! (Or in Intro – overarching principle…)
• State starts at Level 1 or wherever it currently is.
-- Need ¶ on “Backsliding.” TASK
TIERED APPROACH MODIFICATIONS (from Group Discussion)
General Assumptions:
1. At a minimum, IMPROVE program is fully operational. Other indicators will be used
to measure deciview.
2. Analytical Tools are WRAP approved* and available to be able to use IMPROVE data.
*or WRAP process to approve
3. Must be able to do Visibility Impact Assessment (define) – tools not currently
available – but must be by (date) . This ESMP is predicated on this!
4. States should have SMPs certified!!!
[Add to the Appendix: BSMP (Kuehn/Riley document) must/shoulds; Digest TASK]
Chronological Record II - 58
TRIGGER: Sources that contribute to impact of 1 deciview or more at any Class I area
move up to the next Level. Who makes this determination?? TASK
Level I
Elements:
1. Emissions Tracking “101” [Fire Categorization?? – “Anthropogenic”/”Natural”)
a. Build Annualized Inventory for visibility modeling purposes
--Annualized = Daily
--Specific Location Within 1 Mile
--Quantity of Emissions
b. Build your own, but with some minimum quality required: e.g., Fuel Type &
Loading
--ETT may supply some guidelines?
Note: Visibility Impact Assessment
Visibility Impact Assessment using emissions if technology/science is not there to do
monitored/modeled Visibility Impact Assessment.
* Separate group needs to address options (Evan, Pete, Mark F). TASK
2. Technical Tools
a. Modeling for Emissions
3. Info Tracking?
Level II
Elements:
1. All of the above plus
2. Emissions Tracking “201”
a. Adds Dissemination of emissions information
b. Adds Prediction [Contemporaneous/Current]
Predict / Estimate your potential emissions and let the public know.
Note: Include examples of ways to implement, e.g., Internet, phone.
* Incentive-ize emission reduction here (& back into BSMP)? TASK
*De minimus split Small Burners: Emission reduction encouraged
Large Burners: Emission reduction required – add tracking
moisture content & ignition time
***Emission Goals kick in here
Level III
Elements:
1. All of the above plus
2. Visibility Impact Reduction Utilization
Chronological Record II - 59
3. Emission Reduction Utilization
4. Information Tracking for both of the above
5. Burner Justification / Explanation
a. Smoke Management Program/Authority = Mandatory ($$$)
b. Burn Plan = Mandatory (Wildland already req’d under BSMP; Ag & Private kick
in here: may mean legislative change!)
* State can opt to develop a de minimus here? Based on tons? Acres? Different level for
different sources? TASK
Clarification: Smoke Management Program
• Mandatory, i.e., Regulatory vs. MOU, or…NO MORE VOLUNTARY
• NAAQS + Visibility, i.e. BSMP + ESMP
• May trigger statutory authority
• All Sources: Prescribed Fire Sources, All Land Ownerships (A/N?)
-- Use NBTT Definitions
• Centralized Regulatory Authority within State Boundaries
• Burn Authorization see BSMP
• Beginning of ACTIVE Inter-State Coordination
Clarification: Burn Plan
• Enough information to drive the decision (examples…)
• Is it Programmatic or By Burn? -- Need to decide
• Define “project” or whatever language is used – make sure language is very specific.
Reconcile Fed/Ag/Private terminology. TASK
Level IV
1.All of the above plus
2. Active Regional Decision-Making by a Multi-State Coordinator (e.g., 4 Corners,
Northern Tier, Inter-Mountain, etc.)
3. Participation Mandatory
Level V
1. All of the above plus
2. WRAP Region-Wide “Smoke Czar”
IMPLEMENTATION TIME FOR EACH LEVEL
Option:
Starting – 1.5 years to calculate contribution
Implementation:
Chronological Record II - 60
Level 1 to 2…3 years?
Group agreed to let the Writing Team develop a draft of implementation timetables for
each level for review in Tucson.
Send this to Brian Finneran for review before Tucson. TASK
II. ANNUAL EMISSION GOALS METHODOLOGY
Underlying Assumptions/Questions:
From RHR & GCVTC: “minimize emissions increases”:
1. Reduce emissions increases over some calculated baseline
2. Emissions will increase
3. Is a goal a number?
4. If using alternatives to burning increases, do emissions decrease?
Real question is: What is optimum level of control and where can it be applied?
Define: “Maximum Extent Feasible”
“Best Management Practice” -- uniformly defined array that qualifies (in
GCVTC?)
Haddow Proposal (see Annual Emissions Goal Paper)
Baseline: calculate over 3-year average (‘00, ‘01, ‘02 data)
[For what sources?]
If your projection DOES NOT exceed baseline, the goal is the baseline.
No reduction required.
If your projection DOES exceed baseline, state comes up with the goal.
Other Approaches to the Annual Emissions Goal
… that Measure the MEANS not the ENDS
1. Annually we intend to reduce emissions by x% by utilizing emission reduction
practices
[Need to define “Emission Reduction Practices”]
-OR-
2. Mandatory % Utilization of Best Management Practices to 2018: Maximum Extent
Feasible
Is the % Necessary?
Chronological Record II - 61
Stricter reporting?
Penalty? Not Necessary – get penalties through ESMP!
States enforce?
Tracking?
3. At 2018: If not enough techniques being used, increase to larger mandatory % -- NO
Underlying Assumption: If you utilize Best Management Practices, you are
demonstrating reasonable progress.
(Writing Team develop draft by 1/18; conference call to review with Pete/Frances/Gary
week of 1/21/02 – Remember to GCVTC Recs!) TASK
(Brief Dennis?) TASK
Pete will present in Tucson.
Cons of developing a number for the Annual Emissions Goal:
1. Too complex to calculate
2. Too inaccurate +/-
3. Hinges on a baseline that is difficult to establish
4. Too costly wrong placement of effort: we want to emphasize the means
(emissions reduction techniques) rather than the ends (quantifying emissions)
5. Tracking costly & more cumbersome
6. Difficult to find consensus about allowable increase over baseline
7. Cap or Goal issue
III. TRADING
Presentation based on Frances Bernards Paper
Trading Program Assumptions: (from EPA’s EIP Guidance)
1. Program would include a cap (level set on pollutants for a specific time period)
2. Only trade same pollutants, no trade of different pollutants
3. Has to be a declining of emissions overall
Trading Program Possible Parameters/Elements:
1. INTRA and/or INTER?
2. Voluntary or Mandatory?
3. No Intra-pollutant allowed; Not between different pollutants
4. Could address only visibility pollutants or could include a larger list of pollutants
5. Could be set up Regionally or Multi-State or ….
6. Could be 5-year or 1-year period
7. Could include Banking (EPA has strict guidelines on this)
8. Manage Banking with Flow/Control Provisions
Chronological Record II - 62
EPA Requirements:
1. Monitoring & Reporting
• Year-end Accounting of Emissions on an annual basis
• Auditing of Program every 3 Years
2. Appoint Authorized Account Representative per Source
3. Certification Requirements Impact on SMPs (tracking)
4. Environmental Benefit has to be proved
Backstop* Market Trading Program:
• Model that meets EPA regulations – there are others
• Voluntary to start, but could become mandatory if necessary
• *Only triggered if milestones aren’t met (2013, 2018, etc.)
Pros & Cons of Including a Trading Program:
+ Provides incentive for non-burning alternatives / emission reduction
+ Could dispel some equity issues for non-fire sources (if inter-source)
Also for fire sources (if intra)
+ Trading for conformity regulations
+ Brings everyone into the mix in re: quantifying emissions (if inter-source)
+ Economic benefit from bringing fuel into a controlled burning environment
– Complexity of design and implementation
– Costly – is it the most cost effective way to promote alternatives to burning?
– Seasonality of fire affects viability of program
– Sierra Club doesn’t support: REDUCE emissions, don’t trade them
CO2 = global warming
– If visibility impact oriented, potential for the program is reduced
– Forces everyone to Level III or higher right away
Questions:
1) If only visibility pollutants (between fire and non-fire sources), what sources would
participate?
2) If trading between burn/non-burn sources, the chemistry gets more complicated?
Need to Develop Straw-Man Trading Program:
• Structure to program
• Visibility Impact orientation
• Is it successful in other sectors? Point sources? Look in the East?
• Limits trades to emissions reduced due to use of alternatives?
(Frances will draft for Tucson Meeting, calling on Mike/Ann if need be) TASK
MEETING ADJOURNED
Chronological Record II - 63
Handouts for the Portland Meeting
Portland, Oregon
January 7 & 8, 2002
Enhanced Smoke Management Program
Document Outline (Draft)
I. Executive Summary
II. Introduction
A. Background (Regulatory Context, GCVTC/RHR, Other)
B. Treatment of BSMP/ESMP Explanation: Tiered Approach?
C. Suggested 308/309 Differences (if any) & ESMP Trigger
III. Guidance
Elements of the ESMP: What Are They (Elements Defined)
IV. Guidance Annotation
Elements (Explanation, Examples, Methods): Elements Explained
Emissions Tracking
Emissions Reduction
Impact Reduction
Alternatives to Burning
Information Tracking
Technical Tools
Regional Approach/Coordination
ESMP Program Administration
V. Appendices
A. Glossary of Terms
B. List of Software
C. Detailed lists of examples of Elements (e.g., Emissions Tracking)
D. Other
Chronological Record II - 64
Handouts for the Portland Meeting
Portland, Oregon
January 7 & 8, 2002
Annual Emission Goals
Document Outline (Draft)
I. Executive Summary
II. Introduction
Regulatory Context
Goal/Cap Explanation -- Visibility
III. Methodology
The Goal
Source Type
Spatial/Temporal Averaging
Accountability
Incentives
Trading (subset of incentives(?) if included)
IV. Appendices (?)
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ESMP Task Team Meetings
Denver, Colorado: January 16 & 17, 2002
Writing Sub-Group Meeting
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ESMPTT
Writing Sub-Group Meeting
Denver, Colorado
January 16 & 17, 2002
Participants: Ann Acheson, Pete Lahm, Scott Kuehn, Rebecca Reynolds.
Meeting Purpose: This meeting reviewed current work products and the ESMP document
outline to date, and began to develop a draft document in preparation for the next full
Task Team meeting.
Handout
Enhanced Smoke Management Program
Guidance Document (DRAFT)
I. Introduction/Preamble Points
1. Tiers equitably address smoke management across states with disparity in addressing
smoke management.
2. ESMP=BSMP + VIZ (impact to all Class 1 Areas Need to make distinction
between Colorado Plateau and Others?)
3. BSMP as basis for ESMP – Interim Policy & AAQTF; Keep NAAQA (and
Nuisance??) in ESMP – how? And where to put BSMP (appendix?)??
4. Mandatory for 309, but recommend universal application to all states (see NBTT). Will
there be a different implementation timeline for 308 and 309 states?
5. Visibility Impact Assessment and 1 Deciview as basis of ESMP
What does Visibility Impact mean?
Modeling is being done right now with an inventory. Will levels of emissions
indicate impact?
o Retrospective analysis on 20% worst days.
o Start with monitored data from a site… then model.
What is “significant” – ESMPTT defines starting point as 1 deciview for all
source sectors. [This may be challenged & we may need to re-define]
6. Define/Explain Trigger: 20 worst days, 1 deciview at any Class 1 Area, Continuous
contribution – not additive
If source sector contributes to impact on visibility (1 deciview or more)
Continued impact – 1 deciview or more
Who makes this determination??
Trend oriented
Does it need a NAAQS equivalent? How to link?
Criteria for a Visibility baseline RHR p.35766
Chronological Record II - 69
7. Uniform Methodology mandatory for equity – will evolve over time. Use the same
tools – uniform analysis.
8. Explain no backsliding, but that you can go up and down levels (??)
9. Explain that different sources/areas can have different levels
10. Various questions p. 4-5 Portland Notes (yellow highlight)
II. ESMP Levels
Level 1
Trigger
Elements
BSMP plus
1. Emissions Inventory (How? Transmissometer Reading / IMPROVE?) By 2004*
2. Visibility Impact Assessment** By 2005 or
[Alternative language: “Contribution to Visibility Impairment” (RHR p 35771)] 2006
Implementation Timeframe
SIPs must be committed to by the end 2003 SIP…so by the end of 2004?
(SIP Approval ranges from 6 months to10 years!?)
Will there be a different implementation timeline for 308 and 309 states?
Level 2
Trigger
Elements
All of the above PLUS
Real time Reporting Process “Passive Coordination”
Emissions Tracking “201”
a. Adds Dissemination of emissions information
b. Adds Prediction [Contemporaneous/Current]
Predict / Estimate your potential emissions and let the public know.
Note: Include examples of ways to implement, e.g., Internet, phone.
* Incentive-ize emission reduction here (& back into BSMP)? TASK
*De minimus split:
Small Burners: Emission reduction encouraged
Large Burners: Emission reduction required – add tracking moisture content
& ignition time
Implementation Timeframe
Chronological Record II - 70
Level 3
Trigger
Elements
All of the above PLUS
Visibility Impact Reduction Utilization
Emission Reduction Utilization
Information Tracking for both of the above
Burner Justification / Explanation
a. Smoke Management Program/Authority = Mandatory ($$$)
b. Burn Plan = Mandatory (Wildland already required under BSMP; Ag & Private
kick in here: may mean legislative change!)
* State can opt to develop a de minimus here? Based on tons? Acres? Different level for
different sources?
Implementation Timeframe
Level 4
Trigger
Elements
All of the above PLUS
Active Regional Decision-Making by a Multi-State Coordinator (e.g., 4 Corners, Northern
Tier, Inter-Mountain, etc.)
Participation Mandatory
Implementation Timeframe
Level 5
Trigger
Elements
All of the above PLUS
WRAP Region-Wide “Smoke Czar”
Implementation Timeframe
Chronological Record II - 71
Meeting Product
From the Denver, Colorado Meeting
January 16 & 17, 2002
Enhanced Smoke Management Program
Guidance Document (DRAFT) -- Revised
I. Introduction/Preamble Points (to be drafted by the assigned)
0. Context/Background (see NBTT intro, Bernards, Haddow, Barkmann)
Rebecca
1. Tier approach (levels) equitably address smoke management across states & source
types with current disparity in addressing smoke management. Explain that different
sources (define!)/areas can have different levels.
Rebecca
2. ESMP=BSMP + VIZ
309: 2003 SIP = 16 Class 1 (GCVTC)
308: SIP submittal date tied to PM2.5 designation 2005-08
309 Additional Class 1 areas: 2008 SIP
Question: deal with ESMP start date for Level 1 here or in Level 1??
However, each state has an obligation to account for its emissions in its own Class 1
areas and those outside its jurisdiction.
(impact to all Class 1 Areas Need to make distinction between Colorado Plateau and
Others?)
Pete
3. Basis for ESMP is the RHR, Interim Policy & AAQTF.
BSMP starts at Level 3 and integrates NAAQS, Nuisance & Regional Haze concerns.
Refer to our revised BSMP (in Appendix or?).
Scott
4. Mandatory for 309, but we recommend universal application to all states (see NBTT).
Level 1 ESMP is mandatory for all states.
There will be a different implementation timeline for 308 and 309 states.
Rebecca
5. Visibility Impact Assessment and 1 Deciview as basis of ESMP
What does Visibility Impact mean?
Modeling is being done right now with an inventory. Will levels of emissions
indicate impact?
o Retrospective analysis on 20% worst days.
o Start with monitored data from a site… then model.
What is “significant” – ESMPTT defines starting point as 1 deciview for all
source sectors. [This may be challenged & we may need to re-define]
Chronological Record II - 72
Reconstructed extinction from IMPROVE filters/data or other monitors (?) or
IMPROVE protocol
Pete
6. Define/Explain Trigger: 20 worst days, 1 deciview at any Class 1 Area, Continuous
contribution – not additive
If source sector contributes to impact on visibility (1 deciview or more)
Continued impact – 1 deciview or more
Who makes this determination??
Trend oriented
Does it need a NAAQS equivalent? How to link?
Criteria for a Visibility baseline RHR p.35766
Regional Impact – address thru modeling
Meteorology – factor in / modeling?
(How? Transmissometer Reading / IMPROVE?)
Wildfire impacts are not a trigger no matter where i.e., wildland or Ag
SEE RHR p. 35725, bottom of page, 1st column thru p 35727
Pete & Mark F.
7. Uniform Methodology mandatory for equity – will evolve over time. Use the same
tools – uniform analysis. In order for States and other entities to manage emissions from
fire for the purposes of improving visibility and protecting the health and welfare of the
public, a systematic approach to data management or information tracking is crucial.
[from M. Schmidt]
Ann (see NBTT or Ask Rebecca)
8. Explain no backsliding, but that you can go up and down levels (??)
--States must keep level of SMP they currently have
--If state’s viz impairment goes down (less than 1 deciview), this must be a three-
year (or 5-year) continuous average. If three years, then State can drop back down to
Level 1. Emissions levels during same three year period are adopted as a voluntary cap. If
volume cap is exceeded after the move to lower level that will be used to re-trigger more
stringent levels.
Scott
9. Burn Activity information is necessary to create accurate emission inventories required
by the RHR. [cit. ?] Accurate inventories of regulated pollutants emitted by burning on
wildlands [private & government] and other private lands [agriculture] will allow for
tracking progress in emission reductions, revising SIPS to reflect needed goal revisions,
and modeling at the local to the regional level to assess whether the reported emissions
are consistent with monitoring data. [from Komie’s paper]
Ann (see NBTT or ask RBR)
10. We are making a distinction between what Burners are responsible for tracking and
what Regulatory Authorities are responsible for. The agencies and private entities
engaged in prescriptive burning will be responsible for providing the critical information
necessary to the state or local regulatory agency’s who are creating the emissions
inventory. The actual calculations of emissions can be done by the regulatory agencies
based on the information supplied. It is recommended that the WRAP states adopt the
same emission factors and methodology for calculating emissions for regional
consistency. [from Komie’s]
Chronological Record II - 73
HOLD
11. State & Tribal planning for implementation for ESMP Levels; Funding;
Legislative Approvals; Capacity/Infrastructure – SIP revision issue?
Pete
12. Discuss Trading as an option for all states to consider – refer to Bernards’ Paper or
EPA’s EIP in Appendix
Ann
13. Regulatory Authority’s responsibility to develop the mechanisms for implementation
and oversight of all Levels of ESMP. State/Tribe responsible but can delegate to counties,
municipalities, organizations, agencies.
Ann
14. Emissions Reduction & Impact Reduction Techniques (also NAAQS, Nuisance)
-Emissions reduction techniques are encouraged everywhere.
Refer to Appendix on this and include: “Encourage burn planners to lay out units with
safe logical cut-off size polygons to be utilized when unexpected changes occur in
weather. Polygon size should be set at safe levels of acres, emissions production, or
impacts. (Part of a contingency plan.)”
Scott
15. Remember: Explicit tie to NBTT Policy (in particular: SCOPE ie backyard burning
vs. whatever) & PFPA (Prescribed Fire Program Assessment Recs)
Rebecca for NBTT Scope (& integration w/ NBTT Policy)
Pete for other NBTT & PFPA
II. ESMP Levels Section
Level 1
Rationale
Equity
Addresses current disparity among systems
Foundation of quantifying the impact on visibility
States/Tribes should assess the applicability of establishment of a BSMP.
Link to NBTT rationale on Emissions Tracking as applied to “A”/”N”
Statutory Authority
RHR says all 309 states will track emissions (cite??)
RHR says all 308 states need to determine sources of impairment and level of
contribution. (cite??)
Trigger – State determines
Elements
1. Burn Activity Inventory
Chronological Record II - 74
-Activity info needs to be available to the state on an annual basis, and needs to be
attributable to any given day.
-The activity info can be estimated or collected through direct methods (directly or
indirectly determined, e.g., remote sensing, survey, yearly log book). This might be
done at a State level or through individual burner tracking.
-Everyone needs to track, at minimum, the following activity info. De minimus level:
any burn 10 acres or less or 50 acres total in a year.
-The following represents the information making up the inventory:
Day of Burn
Location
Fuel Type
Tons per Acre Consumed (keep this in?)
Size of Burn (Acres)
Source Sector (define!)
Anthropogenic or Natural (define!)
(!define “maintenance” vs “restoration”! – put in Appendix)
2. Contribution to Visibility Impairment Assessment (cite: RHR p 35771)
-The level of specificity of the activity inventory above supports the development of
an emissions inventory needed for current visibility impairment modeling.
-Emissions info needs to be available on an annual basis, but able to be attributed to a
specific day. The conversion of the activity info to emissions is foreseen to be done by
the State or by the WRAP
[Note: Move all to Bob??]
Implementation Timeframe
309: SIPs submitted to EPA (including commitments to ESMP) by the end 2003, so
Level 1 in place for all states by the end of 2004.
308: 2004 holds – because they have to deal with Viz, i.e., do source attribution analysis
and implement control measures as part of their SIP submittal in 2008. Therefore,
completing Level 1 by 2004 facilitates them doing this and also equity across state
boundaries and source sectors.
[OR – only if we get pushed into a corner]
We suggest voluntary Level 1 prior to 2008 (Viz SIP in 2008) – mandatory at 2008
Level 2
Rationale: Level 2 is a “real time” reporting process by the burner that promotes the
possibility of voluntary coordination. Multi-state coordination paves the way for the
ability to address smoke intrusions from outside areas. If burns are located adjacent to
state/tribal boundaries coordination will occur appropriate to the smoke
Chronological Record II - 75
transport/emission path and quantity. Burns of significant magnitude can affect visibility
in adjacent jurisdictions.
Trigger
1 deciview or more of contribution to viz impairment – State determines.
1 year to Monitor (309: ’04 – ’05) [308: ‘08-‘09]
2 yrs minimum to determine impairment.
Move from Level 1 to Level 2 will only occur after determination of viz impairment
attributable to prescribed fire sources on ag or wildland.
Elements
All of the above PLUS – you still do everything you were doing in 1 PLUS….
Voluntary Coordination Information (Moniker: relate to Burn Activity Inventory?)
-Same activity info inventory required of the burner as in Level 1, but in Level 2 must be
made available on a daily basis prior to the burn and made available to cross
jurisdictional authorities. This could be done, for example, by posting on a regional or
local Farm Bureau website, or, if applicable, using a regulatory authority’s website or
phone-in.
-De-minimus level: tie to proximity to Class 1/sensitive receptors?*
Suggest 100 KM (tied to CAA – cite?)
Info Tracking
-State would need to have identified the following:
-Sensitive Receptors Location*
Names and locations of sensitive receptors
We want to suggest Reg. Auth. Make this additional info available….
-Sensitive receptors should include sensitive populations
-Locations of monitors, state, EPA or local
-Identification of airsheds or air administered units
Consider: per NBTT, include manage element for “N” i.e., addressing viz impacts of
wildfire and maintenance burns by …[create examples of specific management action
here!]
[Note: Think it is preposterous to have this Level without BSMP, i.e. NAAQS – but do
we have the authority to include it?? Consider putting BSMP here as shoulds, then they
become musts in Level 3.]
Implementation Timeframe
One year to implement from the date of determination of impairment
[Maximum implementation date: ‘08]
Chronological Record II - 76
Level 3
Rationale: Use of emissions reduction and impact reduction techniques* are both
mandatory at this level.
This requires that the State must now create a centralized authority or delegated authority
(clarify that this need NOT be the State/Tribe itself), if not already in place for BSMP, as
described under the BSMP Guidance [refer to Appendix]. This includes, but is not
limited to, the following: to approve and coordinate daily burning, to define minimum
burner qualifications, to review Burn Plans (TT needs to define**), to promote public
education and awareness, and to enforce all of the above. [Refer to BSMP: integrate
Barkmann’s Program Administration Section]
[*Ties to Annual Emissions Goal Methodology.]
** Burn Plan = Mandatory (?) -- Wildland already required under BSMP; Ag & Private
kick in here? – reference PFPA for recommendations on elements of a Burn Plan (cite)
Trigger
Same as above
Additional three years to discern impairment
Elements
All of the above PLUS
Everyone’s info going to the same place
Central authority go/no go
Emissions reduction techniques to max extent feasible, alt to burning, impact reduction
are all mandatory.
[Note: per NBTT: Explain “Control” for “A” see p. 11/ 3.1.2 NBTT]
[Consider difference between Ag AAQTF and Wildland BSMP – need separate tracks?]
[What is burner? Central Authority? What is Planning? Operations?]
[BACKSTOP?]
Emissions Reduction Tracking [Appropriate moniker? Relate to Burn Activity Inventory]
This annual report would also include the number of non-fire alternatives and emissions
reduction techniques employed that could be tracked and then allow for the calculation of
the amount of emissions saved. This tracking could be useful for demonstrating
reasonable progress toward emissions reduction goals and possible trading purposes.
(then refer to Appendix: Kuehn)
Smoke Management Program
Components of the central authority’s information database must be developed so that
new information can be added and tracked without duplication of time and effort.
Chronological Record II - 77
Planning Context: Actual Pre-burn information will include fuel loadings, consumption
expectations, if non-fire alternatives can be utilized and rationale for lack of use,
evaluation of potential smoke dispersion and visibility impacts, air quality monitoring
and public notification plans.
Implementation Timeframe
From the date of determination of continued contribution to viz impairment, maximum
two years to implement Level 3.
[Ann A, Co-Chair, says THREE years, ever so politely.]
[Maximum implementation date: 2013]
Level 4
Rationale
In order for States and Tribes and other entities to effectively coordinate regional haze
concerns*, both inter and intra state coordination is necessary.
[*alt. language: to address the continued viz impairment from fire sources.]
In order to regionally coordinate burning throughout the year, for a year, there will be
pre-season assessment of viz impairment from fire sources. Based on this assessment that
may use pre-established allowable modeled maximum emissions, the regional
coordination process may limit burning activity.
Trigger
If smoke from a state has impacts outside it, then Level 4 triggers.
In order to trigger Level 4, there are continued impacts by both (several) states on each
other, necessitating the creation of multi-state level coordination.
Elements
All of the above PLUS
Active Regional decision-making at a multi-state level (e.g., 4 Corners, Northern Tier,
Inter-Mountain, etc.)
Burner will provide to the multi-state coordination authority an annual estimation of burn
activity, including all “inventory” (moniker?) information from Levels 1–3.
Implementation Timeframe
From the date of determination of continued contribution to viz impairment, a maximum
of one year to implement Level 4.
Maximum implementation date: 2017
Chronological Record II - 78
Level 5
Rationale
Allows for greater coordination across a wider geographic area from a centralized
coordinating source in order to achieve reasonable progress. States that continue to
contribute to visibility impairment under Level 4 coordination, move to Level 5 and lose
oversight of their own smoke management programs.
This loss of oversight is analogous to EPA’s FIP that results from a state’s failure to
address a non-attainment area. ESMP Level 5 is parallel to a WRAP SIP.
Trigger
Continued inter-state impacts outside Level 4 multi-state centers result in potentially
expanding the multi-state domain to accomplish the objectives of reducing those impacts.
Once enough states are at Level 5, a WRAP region-wide coordinator would be
responsible for oversight. This coordinator would protect the interests of those states with
lower ESMP Levels that do not impact intra-state or inter-state Class 1 areas. [There’s a
new sheriff in town!]
Elements
All of the above PLUS
WRAP Region-Wide “Smoke Czar”
Under Level 5, it is possible that some states would not be a part of the region-wide
decision-making process.
Implementation Timeframe
From the date of determination of continued contribution to viz impairment, a maximum
of two years to implement Level 5.
Maximum implementation date: 2022
APPENDIX
Determining when multiple day burns can be carried out requires advanced
meteorological analysis and planning. (Multiple day emissions evaluation.) [from GZ]
Komie’s Purpose of Burn list, etc.
Emissions Reductions (Kuehn)
Special Events: Collect information within each airshed pertaining to recurring special
events and specifically planned events, e.g., annual marathon races, community parades
and special events, county fairs, opening hunting season, state holidays, etc. Whether or
not there was a concern during the actual burn would depend on a number of factors such
as: weather, public acceptance, public education efforts, news releases, etc. Information
should be collected for display in a GIS (Lat/Long, UTM) for rapid lookup. (GZ)
Chronological Record II - 79
Smoke Management Program Examples
In an ESMP, annual fire reporting would go into more detail to include information on
Wildfire, Prescribed (including agriculture burning) and Fire Use Fires, Ceremonial fire
use, etc.
Inform coordination center of anticipated burns for the year including the earliest ignition
date. This would initiate the burn sequencing process. This is the pre-season burn list.
Develop enhanced smoke notification lists for various pre-established climatologically
airflow patterns scenarios. [sic] Draw upon lists for preburn notification and advanced
warning should wind directions aloft change to outside of the forecast.
Address Smoke Dispersion Evaluation – who does it, for what purpose – include RHR –
our philosophy about it. Modeling, Monitoring? Ensure that this is included in BSMP –
see GZ’s paper
Require regional approval and real-time tracking of burns. With the regional tracking
concept, the regional coordination center should coordinate multiple burns across the
western region and multi-states to avoid multiple-layering impacts on airsheds and across
state boundaries. This would permit for informed last minute decisions so that airshed
optimization can occur.
Utilize gamed smoke flow paths from the Modeling Section to determine the level of
notifications required.
Technical Tools
Modeling
-Regulatory Authority use information derived from the Modeling and Interpretation
Section. Game anticipated airflow patterns based on climatological data, utilizing
advanced modeling techniques for determining smoke dispersion.
-Regulatory Authority model/game the year’s set of planned burns using the latest
multiple burn assessment tool. This would allow for optimizing annual airsheds and
reduce multi-layering of transport smoke paths.
-Question: Will Burner need to do Modeling and if so, what? When?
Specific models, types of models, and the complexity and refinement of modeling
inputs will vary with the objective of smoke impact analyses. Less refined total
emission analyses may be used for less complex projects. More complex projects
may utilize qualitative meteorological analyses; while, even more complex projects
will require quantitative dispersion modeling. Once dispersion modeling is triggered,
appropriate modeling may range from simplistic Gaussian (Define) to complex
photochemical models. The criteria for assessing the complexity of projects should
Chronological Record II - 80
include an analysis of emissions, terrain, meteorology, severity of air quality
problems, proximate to population, and governmental regulations. The selection of
models will consider all local, state, and federal requirements. Spatial and
jurisdictional coverage of potential impacts will also be considered. Models may be
applied to both regional and local planning scales. (Ahuja, et al)
Monitoring
-Use of real-time PM monitoring equipment in smoke sensitive areas and for visibility
concerns. Preferred use of 2.5 µm monitors. Establish thresholds for mandatory and
recommended use of monitors. Use to educate public in PM levels and for public and
media notification triggers. Use as a tool to sensitize the public to various PM levels.
Post the information on the smoke home page and in local media sources. Utilize such
models as WinHaze* (PM level comparison tool) to build public awareness of PM levels.
*Include in Software appendix?
-Access real-time high-resolution satellite data for verifying and tracking smoke. Use
this data to better improve regional scheduling of burns in future
On-Site Meteorology
-Utilize pilot balloons near sensitive receptors prior to ignition to check for proper
transport winds. This would ensure that transport winds were as predicted and that
appropriate downwind receptors were notified accordingly.
-Utilize portable weather stations in areas with known unusual wind patterns. Familiarize
meteorologist if needed with a site visit prior to burning. In extremely difficult areas
utilize IMET on site during the burn.
Technical Tools (Level 4)
Climatology/Meteorology
-Climatological analysis is needed to determine when multiple day projects can be carried
out.
-Conduct analysis of regional airflow patterns so that statistically safe opportunities for
burning throughout the year can be taken advantage of, spreading the smoke over a
broader time period.
-Use meteorological data for gaming smoke situations and scheduling multi-day projects.
Software
Trading – EPA’s EIP reference or Bernards’ paper?
Glossary
BSMP -- streamline this to deal with MUSTs for NAAQS/Nuisance plus some basic
steps for RHR Viz.
Then Other Appendices to address details of aspects of ESMP that need further
clarification e.g., Level 4 Regional Coordination, A/N, etc.
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ESMP Task Team Meetings
Tucson, Arizona: February 5–7, 2002
FEJF Meeting and ESMP TT Meeting & Breakout
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ESMPTT Meeting
Tucson, Arizona
February 5-7, 2002
Agenda
Tuesday, February 5, 2002
8:00 am – 5:00 pm
Purpose of Meeting: To review the FEJF Briefings, developed for the Task Team as
representative of the workgroup products and meeting progress to date. Finalize decisions
and major issues as the basis for further development of the ESMP and Annual Emissions
Goal documents.
Tuesday, February 5, 2002 8:00 am – 5:00 pm
I. Welcome & Task Team Update Reynolds (8:00 am)
II. Presentation of FEJF Briefing 1 Acheson/Ziolko
RHR & Assumptions (8:15 – 10:00 am)
ESMP Levels, Elements & Timeframe
Clarifying Questions/Comments
III. Break (10:00- 10:15 am)
IV. Group Review & Comment All (10:15 am– Noon)
V. Lunch (Noon – 1:00 pm)
VI. Continue ESMP Discussion All (1:00 – 2:00 pm)
VII. Presentation of FEJF Briefing 2
Annual Emissions Goal Bernards (2:00 – 3:00 pm)
VIII. Group Review & Comment All (3:00 – 4:30 pm)
15 min Break as needed
IX. Next Steps Reynolds (4:30 – 5:00 pm)
Wednesday, February 6 & 7, 2002
Purpose of Meeting: To brief the FEJF on the ESMP TT progress to date, to receive
comments from FEJF members, and to report back to the FEJF on the ESMP TT work
plan and ESMP/AEG Documents based on FEJF input.
Chronological Record II - 85
ESMPTT Meeting
Tucson, Arizona
February 5-7, 2002
Meeting Record
Attendees (For some or all parts of the three-day session)
Ann Acheson, USFS R1/R4, ESMPTT Co-Chair; Mike Ziolko, OR Dept. of Forestry,
ESMPTT Co-Chair; Suraj Ahuja, USFS R5; Gretchen Barkmann, USFS R3; Frances
Bernards, UT DEQ; Jim Brown, SCAT/San Carlos Tribe; Mark Fitch, AZ DEQ; Mike
George, AZ DEQ; Dennis Haddow, USFWS; Vicky Komie, NMED-AQB; Pete Lahm,
USFS R3, FEJF Chair; Dennis Logan, SCAT San Carlos Tribe; Mike Main, USFWS R2;
William C. Malone, WMAT/White Mountain Apache Tribe; Amy Mignella,
WMAT/White Mountain Apache Tribe; Bob Palzer, Sierra Club; Molly Pitts,
WMAT/White Mountain Apache Tribe; David Randall, Air Sciences Inc.; James
Scarborough, Air Sciences Inc.; Jeff Schmidt, NRCS/BLM; Marcus Schmidt,
BLM/USFS R2; Evan Shipp, San Joaquin Valley APCD; Pete Stewart, USFS SW
Region; Al Stover, SD Dept of Ag; Dennis Thompson, SCAT/San Carlos Agency; Mark
Wagoner, farmer; Greg Zschaechner, BLM Interagency Smoke; Rebecca Reynolds,
Rebecca Reynolds Consulting, ESMPTT Facilitator
ESMPTT Schedule
Mid-June: WRAP Meeting: Final Approval of ESMP
June 1st ESMP Final to WRAP
May IOC/TOC Review/Approval
April 29 Special FEJF Meeting (if needed for Approval) Location TBD
April 22 FEJF Conf Call Review/Approval
April 2 ESMP to FEJF
March 18/19 ESMPTT Meeting (Phoenix)
March 13 ESMP Draft to Task Team
March 8 NAAQS group response due (if needed)
March 5 Draft to NAAQS group, if needed
Feb 28-Mar 1 Drafting Team Mtg. (Boise)
Feb 21 NAAQS – Levels draft
February Drafting by individuals
Chronological Record II - 86
Meeting Summary
The Task Team met for a full day on the 5th to review two briefings prepared for the
FEJF (one on ESMP and the other on the Annual Emissions Goal Methodology). On the
6th, the Task Team representatives presented to the FEJF both briefings (revised based on
TT comment) and recorded comment. On the 7th, the FEJF met in plenary session with
the Task Team to further discuss the ESMP briefing, after which the Task Team
reconvened for a 2-hour breakout session to determine next steps.
ESMP Task Team Meeting (2/05/02)
Task Team members had extensive comment on the FEJF briefing. First, the group re-
confirmed that the multi-level approach was the best method for developing an equitable
ESMP, and that visibility impact based on an assessment would be one criteria for
determining Level of ESMP. However, there was a concern that using only the visibility
impact would be too reactive. The group agreed that using a balance of proactive criteria
and reactive ones would be preferred.
The group discussed the integration of the ESMP with NAAQS, and concluded that it
would be preferred to find a way to integrate the two. This was further discussed in the
FEJF sessions over the next two days.
The group also wanted to make sure that smoke management and control techniques
would be encouraged at all levels of ESMP, and that the Task Team be able to strike a
balance between a flexible approach that would facilitate currently unregulated sources’
involvement, and a predictable approach that would address visibility impairment in a
consistent and effective manner for all sources.
The group expressed the desire to have the ESMP compatible with the current smoke
management regulatory framework, i.e., SIP/TIP submittal/review schedules.
From these and other comments, the FEJF briefing was revised for presentation the next
day.
Following the FEJF Briefing of ESMP review, the group then heard a presentation from
Frances Bernards on the Annual Emissions Goal Methodology (Emissions Reduction
Tracking Program). The group made comment that Frances used to revise the Briefing to
give the FEJF the following day.
Emphasis of the group’s comments were:
--Put the benefits of ERT up front:
a) difficult to calculate goal
b) better use of time/$ to focus on emission reduction
c) through emission reduction techniques, emissions really will be reduced
--Wildfire vs. Prescribed Fire activity within same year
--Consider all emissions – wildfire, agriculture, prescribed, etc.
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--RHR – what were they really after? If it was a number (cap) for emissions, this proposal
may have difficulty. Regardless, there need to be numbers set in the ERT Program -e.g.
net usage of emission, % of activities that use ERTs, etc.
--Establish link from ERT to ESMP
--Stationary Sources may not like this when it gets to the WRAP – it was
originally about equity. Focus on % of emissions reduction/averted/tons of
emissions reduced; emphasize emissions reductions achieved
--Implementation date?
--Remember to consider “Natural” vs. “Anthropogenic”
FEJF Comments on the ESMP TT Briefing (2/06/02)
FEJF comments included endorsement of the multi-level approach as predictable and
equitable. Caution about the ESMP being too prescriptive was voiced; TT needs to stay
within the purview of the RHR and to keep in mind WRAP’s role: to provide tools and
resources to aid states/tribes in implementing the Rule. WRAP is not regulatory and does
not sit between states/tribes and EPA; rather, WRAP sits outside that relationship
providing assistance to states/tribes in addressing their particular circumstances vis-à-vis
the Rule.
Other concerns included the fine line between “predictable” and “prescriptive” that
ESMP would need to be aware of; the need for the TT to be clear that more information
from a burn does not necessarily equate to more controls (and the relationship between all
elements of the ESMP, for that matter); the need for the TT to link to the Natural
Background TT’s work and the resulting policy on categorizing fire emissions (i.e.,
inclusion of wildfire in the emissions inventory but not necessarily in control measures);
and the difference between “guidance” and “policy” in the TT’s work.
FEJF Comments on the ESMP TT Briefing cont’d. (2/07/02)
The briefing outlined several fundamental issues that would provide the basis for the
TT’s ESMP approach. The group reviewed these toward gaining clarity and consensus as
well as to garner FEJF input. The following represent the issue s that the group addressed
during the timeframe.
1. ESMP to include Exempt Sources and to maintain/increase control of Currently
Regulated Sources
The group agreed that the ESMP would need to balance both of these objectives with the
overarching goal of:
Protecting visibility in Class I areas
Bringing all states/tribes/sources into the process
This enables us to assess the equitability and to access information not currently
available
2. Proactive and Responsive Approach
The group agreed they wanted an ESMP approach that was both proactive and reactive,
and that this was in line with the National Visibility Goal language*. The goal here is:
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To prevent visibility impairment from continuing or occurring.
Assumption: Being proactive is more efficient → correcting a problem is more
costly than preventing one.
*National Visibility Goal states: “prevent future impairment” and “remedy the existing
impairment.”
3. “Policy” or “Guidance”
The group had a lengthy discussion of the meanings of guidance and policy, the
implications for states/tribes as well as for WRAP, and the associated time necessary to
developing/gaining approval on each. The group agreed that the goal of the ESMP is to:
1. Provide a tool kit and a recommended structure to assist states/tribes in the SIP/TIP
process.
2. To offer options within each Level that will provide states with choice.
3. Develop a recommendation for WRAP to states/tribes that they could use in whole or
part.
Guidance gives options. Policy takes more time for Task Team, but has more teeth?
Offers preferred path and/or template. Much of this will be handled by the language used,
e.g., “should consider” as opposed to “must do”. Clarify in the Introduction the Role of
the ESMP document, whether guidance or policy.
Decision: Working Title of TT document will be “ESMP DRAFT”
4. Visibility/NAAQS
The dominant operating thinking of the TT is as follows:
First charge/priority is visibility.
Timeframe is short so the TT needs to focus its efforts on visibility.
Acknowledge the importance of NAAQS and that it is being addressed through
existing means. Provide guidance on NAAQS smoke management in ESMP
Appendix.
There are several TT members with strong feelings that a link to NAAQS should and can
be made. The TT agreed to add this NAAQS linkage if it is possible within the time
frame, and will entertain concrete ideas/suggestions. A small work group made up of
Evan Shipp, Bob Palzer, Suraj Ahuja, Diane Riley, and Scott Kuehn(?) will work on this
and provide a specific narrative for consideration by the TT for use in the document (see
schedule above for timeframe).
ESMPTT Breakout Session (2/07/02)
The group reviewed the existing TT timeframe predicated on seeking WRAP approval at
its June meeting (see schedule detailed above). Following this discussion, the group
reviewed its progress during the past few days, noting areas of agreement and areas that
still need work.
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The TT agrees that a Multi-Level Approach makes sense. However, there are still
outstanding questions as to how many levels there should be, what management/control
techniques should be at each level, and how rigid the levels should be, i.e., can the levels
include various scenarios/options? (see options list below**)
The 1-deciview-visibility impact assessment makes sense, but is too reactive if used as
the only ESMP criteria. The group wants to see proactive criteria added that would
indicate a state’s/tribe’s appropriate start Level (jump start the ESMP). Some other
concerns regarding the 1-deciview-visibility impairment assessment include: may be too
prescriptive, may be cumbersome to calculate, and may not be equitable for different
areas depending upon the impacts.
There was also agreement that the most serious Level of ESMP as proposed might trigger
EPA intervention (SIP/TIP Call), that is something the ESMP is designed to help
states/tribes avoid, but that ESMP does not have any control over that taking place (i.e., it
is EPA’s call).
The TT is also in agreement that the ESMP should “cycle” with the SIP/TIP cycle, i.e.,
review and calculate every 5 years and the determined level holds for the five year
period, until the next SIP/Tip is due. It is agreed that Level I ESMP is a minimum for
everyone, so as to achieve equity and to enable access to currently unavailable
information. However, states/tribes will start their SMPs where they are, i.e., if they have
a more advanced program, they will keep it – no “backsliding”.
**Possible options for proactive criteria:
Location: If a fire is in a non-maintenance/attainment area (4-levels)
Proximity to Class I: Physical space
Impact: inter-jurisdictional transport
SMP in place
Projection of future impact
Matrix of 2: Source and Size (acreage and/or tonnage) of burn
There are others that with this list will be considered in re-drafting the ESMP.
Adjourn
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ESMP Task Team Meetings
Boise, Idaho: February 28 – March 1, 2002
Writing Sub-Group Meeting
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ESMPTT
Writing Sub-Group Meeting
Boise, Idaho
February 28 – March 1, 2002
Meeting Attendees: Ann Acheson (ESMPTT Co-Chair), Pete Lahm (FEJF Chair), Bob
Palzer (Sierra Club), Jeff Schmidt (NRCS), Mike Ziolko (ESMPTT Co-Chair), Rebecca
Reynolds (Facilitator).
Meeting Purpose: A concept paper was developed after the Tucson meeting to reflect the
major decisions reached at that meeting. The writing group met to review and to revise
the concept paper, which would provide the basis for the draft document submitted in
advance of the next ESMP TT meeting. The blue text and yellow highlight represents the
work accomplished at this meeting.
Meeting Product:
Enhanced Smoke Management Program
Multi-Level Approach
Concept Paper drafted 2/24/02
Revised 3/1/02
Introduction
Proactive: prevention – timing, stringency
Reactive: rectifying problem – timing, stringency
Describe Challenge: incomplete data, inaccurate science (for viz attribution)
Interpretation of National Visibility Goal vis-à-vis RHR? NVG states: “prevent future
impairment” and “remedy the existing impairment.” Pete says RHR interpreted this thru
20 % best/worst days. This MUST be proven with some evidence of impairment. Ergo,
viz impact assessment is the trigger for ESMP levels (above 1).
The Enhanced Smoke Management Program (ESMP) (explain ESMP as viz added)
recommendations are being developed to assist WRAP states/tribes meet the
requirements of the Regional Haze Rule. Should the requirements of the RHR not be met,
EPA could intervene (FIP). The ESMP has been developed to assist states/tribes in
implementing the RHR and preventing EPA intervention. The approach described in this
paper is the result of ESMP Task Teamwork and discussions at Team meetings.
All states/tribes will track, at a minimum, burn activity information to promote the
capability to quantify smoke emissions and their visibility effects in the WRAP region.
The ESMP is being developed with this as its base requirement. [Policy]
Smoke Management Programs (SMPs) are a proven and effective tool for reducing
impacts to public health. As such, the ESMP strongly encourages states/tribes to utilize,
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wherever possible, smoke management and control practices as standard operating
procedure and best management practice. Per the RHR, the ESMP is being developed to
add visibility to states/tribes SIPs/TIPs, SMPs and smoke management efforts.
The intent of the ESMP is to address direct visibility impacts and regional haze in
mandatory federal Class I areas so as to improve visibility on the worst days and maintain
visibility on clean days. Worst days are defined as those days which fall in the lowest
20th percentile for visibility measurements from IMPROVE monitoring and the best days
are those days which are in the highest 20th percentile on an annual basis.
Assumptions
Certain assumptions have been made in developing this multi-level approach and the
associated ESMP elements. They have been discussed and agreed to at ESMP Task
Team meetings. The assumptions are:
--States/Tribes are currently addressing NAAQS and/or nuisance to the extent they deem
appropriate through current smoke management efforts or programs for fire sources.
--States/Tribes are using the available EPA guidance to address the public health priority
(Interim Policy, AAQTF, RACM/BACM).
--ESMP does not erode states/tribes’ current smoke management efforts; ESMP strongly
encourages that states/tribes maintain their current smoke management efforts and/or
SMP.
--As directed by the RHR, visibility considerations are being added to whatever the
state/tribe is currently doing.
--If there are no other state/tribe smoke management efforts, ESMP will still apply.
--ESMP provides a framework for visibility; states/tribes may do more to protect
NAAQS, prevent nuisance and/or address visibility.
--ESMP is aimed at addressing visibility impacts of all fire sources: wildfire, agricultural
burning, prescribed fire on wildlands, wildland fire use; regardless of land ownership.
(see NBTT scope).
--ESMP will address emissions tracking, management and control of fire emissions
where appropriate as determined by the approach.
--Fire sources are currently regulated at various levels from: rigorous to regulation with
exemption applied, to no regulation.
The Approach
The approach described in this paper is based on the discussion and agreements reached
at the ESMPTT meeting in Tucson, February 2002. Previous meeting work wherein
criteria were described is also incorporated in this document. Key working principles
are:
• ESMPs would be multi-level, designed to promote equity and flexibility so that
the level of effort corresponds to the level of impact.
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• A balance of proactive and reactive measures is incorporated. A state/tribe can
use a menu of criteria to identify their situation thus determining their appropriate
ESMP Level. The validity of that level is tested by assessing visibility
impairment, on the SIP/TIP schedule (at a minimum), using >1 deciview as a
threshold.
• ESMPs provide a predictable framework (i.e., the levels determined by
established criteria) and the tools (i.e., the Actions/Infrastructure associated with
each level) to help states/tribes address their particular local situation.
• States/tribes following both sections 308/309 would use the structure established
in this approach.
• Currently exempt, or minimally regulated, and regulated sources are included.
• Impacts to Class I Areas from within a state/tribe and across state/tribal
boundaries are mitigated (i.e., inter/intra).
• Links to NAAQS are established.
• States’ autonomy/tribal sovereignty is acknowledged.
• A state/tribe may adopt the ESMP framework in its entirety or selectively (with
ESMP level 1 the minimum requirement for all).
How the Approach Works
Level Determination
States/tribes use the proactive criteria to determine their ESMP level. Using these criteria
means that a state/tribe/other jurisdiction (e.g., air district, county, etc.) will infer their
contribution to visibility impairment rather than waiting for an impact assessment, and
then immediately begin to take action to rectify/prevent it.
One or more matched criteria in a level determine the level. If criteria are matched in
multiple levels, then the highest level matched applies, unless the state/tribe’s current
SMP is already at a more advanced stage. In that case, the state/tribe maintains the SMP
in existence.
States/tribes may determine different ESMP levels for different sources/geographical
areas, based on their relative impact [i.e., state/tribe can have a “mixed bag” ESMP]. This
means, for example, that if one area of a state/tribe has less burning and/or is farther away
from a Class I area, it may have a lower ESMP level than another area with more burning
and/or closer proximity to a Class I. Or, that if a source (e.g., wildland) is planning
increased burning, it may have a higher ESMP level than a source that is projecting the
same and/or minimal burning.
States/tribes for whom their determined level is not currently economically feasible
and/or legislatively possible will implement the closest level possible to that determined,
with level 1 the minimum (to promote equity and an accurate total emissions inventory).
In such cases, though, states/tribes will use their next (i.e., 2nd) SIP submittal as the
deadline to reach their appropriate level (i.e., to raise funds, change legislation, establish
infrastructure, etc.)
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Validating Levels
Visibility impairment will be assessed to indicate whether additional efforts (i.e.,
changing levels) are necessary. Visibility impairment will be assessed on the SIP/TIP
schedule (i.e., every five years) to determine whether there is an impact of > 1 deciview
(based primarily on IMPROVE data). If there is a contribution to visibility impairment in
a Class I area of > 1 deciview, the state/tribe (or area/source) will move up one ESMP
level to address its continued impacts.
For those states/tribes unable to start at their determined level, the visibility impact
assessment will not be conducted until the third SIP submittal, i.e., the first SIP/TIP after
their appropriate ESMP level is in place. This is based on the assumption that the
visibility impact assessment would show >1 deciview impact since the state/tribe has
been unable to implement its appropriate level to protect visibility. If after the third
SIP/TIP, when the state/tribe has had its appropriate ESMP level in place for five years,
the visibility impact assessment shows >1 deciview, then at that time the state/tribe will
move up one ESMP level.
Four Major Elements of this Approach
There are four major elements to this ESMP multi-level approach that include:
1) Criteria: what determines the level
2) State/Tribe Action: Information collection, Visibility Impact Assessment
(verifies Level), Smoke Management, Smoke Control, Coordination, etc.
3) Oversight Authority
4) Program Infrastructure: Technical tools, funding, etc.
Elements at each ESMP level include all elements determined necessary for lower levels
(i.e., ESMP levels are additive).
Criteria
The criteria determine the ESMP level. They are developed to describe specific situations
within states/tribes that states/tribes can easily recognize. From the criteria “menu” a
state/tribe/other jurisdiction can select the one(s) that describe(s) their situation, which
will then indicate what action to take, and the oversight and infrastructure required.
It is only necessary for one criterion to be met for the ESMP level to apply. However, the
highest level matched is the determined level, remembering that states/tribes may choose
to have different ESMP levels for different sources/areas.
Criteria are created to establish a predictable, additive framework within which
states/tribes may operate. There are four categories of criteria, as follow:
a) Visibility at a Class I Area
b) Proximity of a Source/Non-Attainment Area to a Class I Area
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c) Overall Emissions Produced
d) Non-Attainment Status
The criteria categories for each ESMP level are the same; the amount or intensity of the
criteria is what changes from level to level. These criteria categories have been chosen as
indicators of visibility impairment based on the following rationale:
a) Visibility at a Class I Area (Visual Range)
Visibility distance is a clear indicator of impairment. If a Class I area has "x" km
of visibility, that distance determines an ESMP level: the greater the visibility, the
lower the ESMP level. The IMPROVE monitoring network has calculated
visibility for each Class I area. This metric is simply a determination of visibility,
not attribution information. States/tribes would apply these criteria to Class I areas
within their jurisdiction (e.g., state/tribe/air district, county, etc).
IMPROVE data: viz impact – how? Persistence: organic carbon contribution
duration & magnitude, trend on 20% best/worst days – develop a relatively simple
way for states/tribes to use IMPROVE data to indicate ESMP level (Pete & Mark)
b) Proximity of a Source/Non-Attainment Area to a Class I Area
Proximity (i.e., distance) of a Class I area to visibility impairing sources and/or
non-attainment (specify type, e.g. not lead) areas is enough to elevate the ESMP
levels. The closer a Class I area is to visibility-impairing sources, the more smoke
management/control will be needed. This criterion applies to all Class I areas
within a specified distance regardless of regulatory jurisdiction. In this way, this
criterion addresses inter/intra-jurisdiction transport.
c) Overall Emissions Produced
The assumption is that there is some threshold of burning beyond which regional
haze will be affected in Class I Areas. Whether this criterion is expressed by
acreage, tons or both, and/or by fire source, and what the specific amounts are is
to be determined [by the Task Team], but the assumption is that increasingly
significant amounts of burning, no matter where it occurs within a state or tribal
jurisdiction, would indicate a higher level of smoke management/control (i.e.,
ESMP level).
By virtue of the fact that this metric will be calculated based on information
collected by broad landowner category (private, federal, state or local public
land), this criterion would allow for different levels of ESMP based upon
landowner activity in a geographic area. Those landowner classes that are
conducting more burning may need a higher level of ESMP than those classes
burning in similar geographic regions with less activity.
d) Non-Attainment Status
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This criterion assumes that non-attainment status is an overall indicator of
visibility as well as public health concerns. Where meeting NAAQS is a serious
problem, the pollutants are visible and contribute to regional haze.
[While it may be sufficient to address non-attainment areas as in Criterion (b)
above, it may also be helpful to specify the number of non-attainment areas in a
jurisdiction and/or the severity of them (e.g., maintenance, serious, severe,
extreme) as an added criterion. Doing the latter may be especially helpful to those
jurisdictions already familiar with/accustomed to NAAQS issues and mitigation
procedures. This will need to be determined by the TT.]
Cross-jurisdictional transport is applicable in all of the below, i.e., these criteria
are not constrained by political boundaries.
The criteria describe situations that will indicate consideration of a higher level of
ESMP. They are functionally equivalent to each other.
If state/tribe has any one or more of the below, then this indicates an ESMP level
above 1
Level 1 is the minimum. At least Level 2 is indicated by the criteria below.
State/tribe encouraged to implement Level 2 (which will involve voluntary smoke
management & controls) so as to avoid the need for a higher level program. Level
3 will involve a central authority to oversee smoke management & control
methods and tracking. This will be costly and decrease burners ability to burn at
will –need to express the incentive(s) to implementing level 2. Level 3 and above
is triggered by the viz impact assessment (1 deciview?).
What is level 4, level 5? Are they both necessary?
Does Level 2 look just like Level 3, except without the central authority? Will
Level 2 result in decreased impact?
What is the cycle for viz impact assessment and ratcheting up levels? (SIP, i.e., 5-
yr? Or??)
What is “policy” and what is “guidance”?
Must determine a clear and consistent methodology to determine viz impact. –
(WRAP does, not nec. TT – ref RHR)
Clarify in the doc that the criteria may take the state/tribe up to 2 years to
determine (based on coming data), but that ind. burner will be able to determine
immediately based on his/her knowledge.
Major – Minor Fire Sources (coming from PSD criteria)
Footnote: (at Level 2)
Tons (PM10) Acres
Wildland (Forest: 20 tons/acre) Ag (4 tons/acre)
Consumed consumed
250 833 12,500
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100 333 5,000
70 233 3,500
50 167 2,500
States/Tribes can divide up the tonnage based on fire source to facilitate
determining different ESMP levels for different sources based on impact.
>50 tons/yr PM10 total for all anthropogenic fire sources (define!) per year
No NAAs
W/in and near (i.e., <50 km) of Class 1 (“near” – per RHR)
>250 tons/yr PM10 total for all anthropogenic fire sources per year
No NAAs
w/in 100 km of Class 1
>100 tons/yr PM10 total for all anthropogenic fire sources per year
w/ moderate NAA/Maintenance Area
w/in 100 km of Class 1
>70 tons PM 10 total for all anthropogenic fire sources per year
Serious NAA
w/in 100 km Class 1
Any amount of projected WFU
Ozone NAA
W/in the ozone season
W/in 100 km of Class 1 (?)
For >100 km criterion: consider CRB (AA)
e.g., Sensitive Areas/Receptors
Topographically/meteorologically susceptible
e.g., for larger sources slightly beyond the boundary
Action [This section to be written upon approval of above.]
*Note: consider tying specific actions to specific criteria, e.g., “known impacts to down-
wind Class I areas” with “ Multi-state/tribe burn decisions”
Oversight Authority [This section to be written upon approval of above.]
Program Infrastructure [This section to be written upon approval of above.]
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Enhanced Smoke Management Program Levels
DISCLAIMER: the levels below are intended to give ESMPTT members an idea of how
this approach would construct this section. All content and metrics are to be determined
by the TT.
Level 1 (No longer Level 1 – base requirements for SMP)
Criteria: Everyone is here.
Action
1. Burn Activity Inventory (same as we have been using)
2. Projection Estimates (1-yr, 5-yr)
3. Visibility Impact Assessment with SIP/TIP submittal to verify Level (to determine
appropriate level), based on >1-deciview impact
Oversight Authority
State/Tribe is responsible, and can delegate to local authorities or entities. Responsible
for transmitting information/files electronically to central repository (WRAP).
Infrastructure
Minimal: Standardized Burn Activity Inventory requirements and annual
repository/compilation.
Level 2 (Voluntary/Elementary SMP for Viz?)
This level has state/tribe in a support function to the burner community.
Proactive Criteria Menu
IMPROVE data one… (Pete)
>50 tons/yr PM10 total for all anthropogenic fire sources (define!) per year
No NAAs
W/in and near (i.e., <50 km) of Class 1 (“near” – per RHR)
>250 tons/yr PM10 total for all anthropogenic fire sources per year
No NAAs
w/in 100 km of Class 1
>100 tons/yr PM10 total for all anthropogenic fire sources per year
w/ moderate NAA/Maintenance Area
w/in 100 km of Class 1
>70 tons PM 10 total for all anthropogenic fire sources per year
Serious NAA
w/in 100 km Class 1
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Ozone, >100km --??
Action – Burner Community
Burn Activity Inventory and Projected Estimates submitted to state/tribe
Provide projected daily burn activity for use by other burners
Smoke management practices that lead to impact reduction & emission reduction (add
detail…e.g., alts to burning)
If x-jurisdictional (state/tribe) transport, then multi-state/tribe info sharing
Are there others like this?
Oversight Authority
State/Tribe through local authorities, e.g., counties, etc.
Must do Visibility Impact Assessment with SIP/TIP submittal to verify Level, based on
>1-deciview(?)
Must receive emission inventory info & projections
Infrastructure (state/tribe)
Moderate:
Standardized Burn Activity Inventory requirements and annual repository/compilation
(must)
(Guidance) State/tribe can provide (or find ways to provide) the following support to the
burn community to assist in impact reduction, and to avoid the need for a centralized
authority.
Website or other to post the pre-burn activity info for burners/regulators to promote
voluntary coordination
Website or other to make available info for smoke management practices (moisture,
weather, ventilation index, etc.)
Make WRAP guidance on emissions reduction techniques available (e.g., alts to burning
doc)
Provide burner qualifications and training
In re: “BSMP” – tools and techs available outlined in a docs appended to assist in
developing an SMP (“BSMP”, Int. Guidance, AAQTF). – RR see BSMP intro language
for purpose.
Level 3 (Centralized Authority)
Criteria
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Visibility Impact Assessment of >1 deciview by a fire source category in a state/tribe on
a Class 1 area (any Class 1, regardless of jurisdiction) – whenever determined. At
minimum this assessment MUST be done by ________? (Policy)
Action (Burner Community to Centralized Authority)
Burn Activity Inventory and Projected Estimates submitted to state/tribe
Provide real-time daily burn activity to Central Authority
Smoke management practices that lead to impact reduction & emission reduction (add
detail…e.g., alts to burning)
Oversight Authority
State/Tribe central authority (state/tribe determines what structure works for them)
If x-jurisdictional (state/tribe) transport, then multi-state/tribe coordination: go/no go
decision needs to consider transport issues.
Infrastructure
Significant:
Standardized Burn Activity Inventory forms and annual repository/compilation
Website or other to post burn activity info for burners/regulators to promote voluntary
coordination
Website or other to make available info for smoke management practices (moisture,
weather, ventilation index, etc.
Go/No-go Criteria
Emissions reduction tracking
Etc.
Level 4 (Reasonable Progress)
State/Tribe may be risking a SIP/TIP call and worst-case, loss of SMP oversight as well
as possible law suits.
Criteria
Reasonable progress not being made:
Visibility impact assessment of >1 at a Class I Area of three consecutive years (?)
Action
Oversight Authority
State/Tribe central authority….
If x-jurisdictional impacts (state/tribe boundaries), then involved jurisdictions elect multi-
state/tribe authority to coordinate burning (e.g., burn authorization, criteria, info sharing,
etc.)
Chronological Record II - 102
If, impacts are within a state/tribe, the whole state/tribe moves to full Level 4 – all
burners are included! –No mixed bag ESMP.
Infrastructure
Significant:
Standardized Burn Activity Inventory forms and annual repository/compilation
Website or other to post burn activity info for burners/regulators to promote voluntary
coordination
Website or other to make available info for smoke management practices (moisture,
weather, ventilation index, etc.
Go/No-go Criteria
Etc.
Timeline
SIP 12/03: commit to ESMP (Min. Level 1) – for those states that have viz or emissions
data, use surrogate criteria to determine Level 2 or viz assess to determine Level 3. For
no data, start Level 1.
12/04: Level 1 must be implemented – for no data states; level 2 encouraged (so as to
prevent level 3)
12/05: 1st yr of emissions data avail for states that had nothing; apply emissions criteria
and if applicable, start Level 2
12/08 SIP: for states with data, do viz impact assess to validate existing/determine Level
3. for new data, no viz impact assess possible – keep level determined by criteria
12/13 SIP: ALL do viz impact assessment in enough time to determine Level for this SIP:
Level 3 or 4.
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ESMP Task Team Meetings
Phoenix, Arizona: March 18 & 19, 2002
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ESMPTT Meeting
Phoenix, Arizona
March 18 & 19, 2002
Agenda
Purpose of Meeting: To review the 3/12/02 ESMP Draft. Finalize decisions and major
issues as the basis for revision of the ESMP Document.
Day 1
Monday, March 18 1:00 – 5:00 p.m.
I. Welcome Ziolko (1:00 p.m.)
II. Task Team Update Reynolds (1:10 pm)
III. Presentation of ESMP Draft Acheson/Ziolko
RHR & Assumptions (1:10 – 1:45 p.m.)
ESMP Levels, Elements & Timeframe
Clarifying Questions/Comments
IV. Group Review & Comment All (1:45 am– 2:30 p.m.)
V. Break (2:30 – 3:00 p.m.)
VI. Continue ESMP Discussion All (3:00 – 4:30 pm)
VII. Review/Revise Agenda Day 2 Reynolds (4:30 – 5:00 pm)
Day 2
Tuesday, March 19 8:00 a.m. – 5:00 p.m.
I. Welcome/Review Day 1 Reynolds (8:00 – 8:15 a.m.)
II. Group Review & Comment on ESMP All (8:15 – 10:00 a.m.)
III. Break (10:00 – 10:30 a.m.)
IV. Group Review/Comment cont’d. All (10:30 – Noon)
V. Lunch (Noon – 1:00 p.m.)
VI. Group Review/Comment cont’d. All (1:00 – 3:00 p.m.)
VII. Break (3:00 – 3:30 p.m.)
VIII. ESMPTT Schedule Review & Next Steps Reynolds (3:30 – 5:00 p.m.)
Chronological Record II - 107
ESMPTT Meeting
Phoenix, Arizona
March 18 & 19, 2002
Meeting Record
Participants: Ann Acheson, USDA FS R1 R4, ESMPTT Co-Chair; Mike Ziolko, ODF,
ESMPTT Co-Chair; Suraj Ahuja, USDA FS R5; Frances Bernards, UT DEQ; Mark
Fitch, AZ DEQ; Mike George, AZ DEQ; Vicky Komie, NMED-AQB; Scott Kuehn,
Plum Creek Timber; Pete Lahm, USDA FS, FEJF Chair; Gary Neuroth, Arizona DEQ;
Bob Palzer, Sierra Club; David Randall, Air Sciences/Small business; Evan Shipp, San
Joaquin Valley APCD; Pete Stewart, USFS SW Region; Rebecca Reynolds, Rebecca
Reynolds Consulting, ESMPTT Facilitator
Task Team assignments noted in italics throughout.
Priority Issues
I. Issues Identified & Discussed Day 1
A. Replace Levels with Options:
i. 2 ESMP “Options”: Voluntary and Enforced; otherwise the same.
B. Criteria change to Guidance. Give states/tribes optional ways to
determine adequacy of their ESMP:
i. Situational metrics: add/develop a situational criteria metric for
>100km.
ii. Visibility Impact Assessment
1 deciview: explain strategy for both 20% best and for 20% worst
days.
iii. NSPS – slash from logging
iv. Modeling Analyses to do projections, like BART
C. NBTT: Define & Integrate “anthropogenic” = Manage and Control
“natural” = Manage
D. ESMP “Policy” or?
E. In the ESMP Options, tie more to SIP elements/deadlines
F. Clean Air Corridor
i. Keep in Glossary; mention in Criteria section for how to possibly
use
G. Transport: Cumulative effects; do de minimus?
II. Reasonable Progress
III. 308/309 Issues
IV. Regional Haze/Transport
V. Open Comments
VI. ESMP “Policy” or?
VII. Document Review and Task Assignments
ESMP Document
Revised Table of Contents per the ESMPTT’s Decisions
Chronological Record II - 108
I. Introduction
GCVTC
WRAP
RHR ESMP
308/309 Pathway to ESMP
II. RHR Info Tracking (cite RHR)
Ramifications for ESMP
Baseline requirement language
Link to Annual Emission Goal (reference Doc/FEJF work)
III. ESMP
RHR – SMP Mandatory Elements
Chain to ESMP
Add-ons: Coordination and Burn Authorization
IV. Implementation (Tie to SIP Process)
Options – based on various criteria
SIP timeline?
V. Appendix
Glossary (Pete Stewart will do draft and send to RR)
ESMP Annotated Elements – providing more detail, examples
Bibliography/Website
RHR
GCVTC*
Interim Policy*
AAQTF*
NBTT*
BSMP Draft*
IMPROVE Annual Summary (Ann A. locate & get to RR)
FEJF Work Products:
Annual Emissions Goal Paper
Alts to Burning Paper: Wildland, Agricultural Land
PFPA Paper
Note: If above three docs are not ready, reference that FEJF is
preparing them.
*Include copies of Executive Summaries/Abstracts in addition to the
website listing
308/309 Path Way to ESMP
The Task Team reviewed the RHR to determine the exact language used to arrive at the
ESMP in both sections 308 and 309. The following represents that review:
RHR: “Attain natural background visibility conditions at Class I areas in 2064”
Chronological Record II - 109
Fire plays a role in natural background (GCVTC; RHR)
For 309 states:
SMP defined (seven elements), then:
“Evaluate degree of visibility impairment from smoke”
ESMP: “consider visibility effects” therefore ESMP = SMP for Visibility
Considerations: (all off-ramps,) pg. 35771 (6.iv)
Efficiency
Economics
Law
Land management objectives
Etc.
Emission reduction opportunities
Reduction of visibility impacts -- if reduction of visibility impact won’t be
accomplished, don’t do what won’t work
ESMPTT Needs to Explain: if you have barriers ($, law, etc) then you may not be able to
implement ESMP in the 309 SIP timeframe & therefore may not be able to go 309 – must
go 308. If you want to change those barriers to enable ESMP, then there is no problem
going 309.
For 308 states:
“Reasonable Further Progress” RHR, p.35766-67 (d)
Calculate baseline of all sources
Compare baseline visibility conditions w/ natural conditions
Assess contribution to this of different sources (of which smoke is one)
Considerations in developing long term strategies:
(E) Smoke mgt techniques including current SMPs that exist
If not adequate, consider enforceable emissions limitations and compliance schedules and
other measures as necessary
At this point: ESMP is a tool for 308!
SMP “Mandatory” Elements
RHR pg. 35771 6(i)
The ESMPTT discussed at length the meaning of the Rule in this section, and decided
that the seven elements were meant to be mandatory, meaning a state/tribe was under
obligation to include all seven in its SIP. These elements would, of course, be subject to
the “considerations” the Rule outlines for the ESMP, as discussed above.
“Documentation of all Fed, State, and Private prescribed fire programs evaluate and
address the degree of visibility impairment from smoke in their planning and
application.”
SIP must include SMPs:
“All necessary components including but not limited to…” see pg. 35771 6(i)
Elements:
1) Actions to minimize emissions
Chronological Record II - 110
2) Evaluation of smoke dispersion
3) Alts to fire
4) Public notification
5) Air Quality monitoring
6) Surveillance/Enforcement
7) Program Evaluation
Note: these are not identical to those in EPA’s Interim Policy!
In keeping with the SIP process, that is familiar to state/tribes through the NAAQS
process, states/tribes have the discretion as to how they implement the elements: less
stringent for minimal visibility problems to more stringent for substantial visibility issues.
How could a state/tribe use a voluntary program to demonstrate Reasonable Further
Progress? Use a voluntary program and then demonstrate that they don’t need anything
more. This would be provable through monitoring data, etc.
ESMP Document recommends adding two more elements, as follow:
8) Burn Authority (from EPA’s Interim Policy)
Explain the possible consequences of not having an enforceable burn authority:
e.g. everyone burns at one time, cumulative effects contributes to regional
haze, which could result in SIP non-approval/disapproval
This burn authority would apply to all fire EXCEPT wildfire
Example: Agricultural Burn Manager (from the AAQTF – cite), etc.
9) Coordination (ESMPTT)
Multi-state coordination mandated by RHR for the Visibility SIP. (Cite)
Note that there will be conflicts between smoke management efforts for
visibility/regional haze and for public health (NAAQS). This is the reality.
Explain that if state/tribe does not make this possible, regional haze (i.e.,
transport) cannot be addressed, again leading to a possible (likely) SIP problem.
Advise states/tribes to coordinate with other state/tribes to address all visibility
impacts in Class I areas, from all sources and sectors. (Fire as one source sector
including state, fed, private lands). Explain that this coordination can be
accomplished in a number of ways depending on the state/tribe’s individual
needs/circumstances, e.g., website, Idaho/Montana Burn Authority, NIFC-type
regional level burn authority.
Add sentence to remind about significant sources beyond 100K for impacts.
Remember “within/near” concept from GCVTC.
All Criteria (Implementation Options?) – Not prescriptive
The WRAP-approved ESMP includes nine elements to be included in the SIP. If a
state/tribe wants to do less than a jurisdiction-wide ESMP, then they can use the
Chronological Record II - 111
following criteria to determine what areas/sources will need what measures (under the
nine elements) to address their visibility issues. The criteria are not prescriptive, but just
meant to help states/tribes allocate resources.
1) Source Sector Thresholds
Use to determine to which sources (because they are “reasonably expected to contribute”)
ESMP is applied. Like the BART model (Dave R. can explain)
And/or
2) Situational Criteria (this is re: location)
Tells states/tribes physically where, at a minimum, to apply ESMP
Remind states/tribes that, within those geographic areas, make sure you have an
enforcement, go/n-go, and coordination or else!!!!!
Remind states/tribes about significant sources beyond 100K.
Remember also to mention “within and near” concept from GCVTC.
Add coordination and notification parallel to PSD
Options to proximity radius: Clean Air Corridor (Pete L. can explain)
And/or
3) Impact based: what kind of sources when and where based on attributable impacts.
Use visibility impact assessment based on IMPROVE and emissions inventory or WRAP
modeling analysis for 2018.
1 deciview / 20% best: 5 yr average / 20 % worst: 1 deciview on any one day of the 20%
worst (Pete L. will write)
Incorporate Clean Air Corridor here too also (Pete L.)
Definition of Clean Air Corridor: due to x circumstances (meteorological
conditions) an area is a source of clean air for downwind areas. Note: these have
only been established for Colorado Plateau.
Information Tracking
RHR, Sect 309 pg. 35771 6(ii)
“Statewide inventory and emissions tracking system (spatial and temporal) of VOC,
NOx, elemental carbon, Organic Carbon, PM 2.5”
This is a baseline requirement of RHR that is critical/important for the implementation of
ESMP. The ESMP document recommends as a minimum the following tracking
requirements… (Use our current baseline requirement language, including blackened
acreage, fuel type, location, etc., and projections*** of same)
Because the Rule says “Controls” and ERTs, then ESMP also recommends as important
in the tracking capability/process: real-time tracking and tracking of impact and ERTs.
***Reference PFPA for projections
Trading/Incentives
The ESMPTT decided to delete the current section on Trading from the ESMP document
– instead, change “trading” to “incentives” and add as a strategy recommendation under
Chronological Record II - 112
the Alts to Burning element. Footnote trading as an example and reference EPA’s
guidance on such. And include other examples. (Bob Palzer will get to RR)
ESMP as “Policy” or “Guidance”
The group discussed the merits of the ESMP document being “Policy” or being
“Guidance”. During this discussion, the definition of “policy” was broadened to mean a
WRAP sanctioned or approved approach to ESMP that would include interpretation,
guidance, recommendations, and some requirements, as well as options for implementing
them. In keeping with WRAP’s role and the wide range of situations among states/tribes
in the WRAP region, flexibility is the hallmark of the WRAP Policy on ESMP. The TT
will consider presenting the ESMP document in this way.
RHR Seven Components – Replace Levels Description with a Section on the
Elements
1) Actions to minimize emissions
All Fire (A/N)
Trading?
2) Evaluation of Smoke Dispersion
All Fire (A/N)
3) Alts to Fire
A only
Trading (?) – Incentives
4) Public Information
All Fire (A/N)
VZ effects on Air Quality in Class I
5) Air Quality Monitoring
All Fire (A/N)
6) Surveillance/Enforcement
Enforces whatever the ESMP elements are
Explain pitfall of voluntary program, vis-à-vis reasonable progress: risk SIP
disapproval/non-approval
(A/N)
7) Program Evaluation (plus development and planning)
(A/N)
RHR SIP cycle
Check criteria (for Evaluation: Impact based only)
8) ADD: Burn Authority (from the Interim Policy)
9) ADD: Coordination (comes from ESMPTT)
Miscellaneous Additions/Edits to ESMP Document
Add information on funding mechanisms – section 105, grant money, WRAP. (Pete L.
get info to RR on this) WRAP will do the emissions inventory to assist states.
Also: ERT and other products coming from WRAP.
Chronological Record II - 113
Flesh out Transport as a concept and add Coordination aspect in the ESMP approach.
Regional Haze vs. Plume Blight; Cumulative Effects; >100 km for many small areas.
Intro/Background: Rule says ESMP for 309, WRAP is responding with this. Due to
states autonomy, the following represents guidance and recommendations for how to do
this. Use this to fit your needs.
Emphasis on Source/Sector
Link NBTT: A/N. Address in “Manage/Control” section under Context ESMP. In
Appendices: give examples of Manage and Control strategies. ESMP = smoke
management and control.
ESMP emphasis on emission reduction tied to NBTT policy and GCVTC
recommendations and Rule 309 (“minimize emissions increases”)
Clean Air Corridor: due to circumstances (meteorological conditions) an area is a source
of clean air for downwind areas. Only have identified for Colorado Plateau
Chronological Record II - 114
1 Handouts
2 Phoenix, Arizona
3 March 18 & 19, 2002
4
5 Recommendations for the Establishment of
6 Enhanced Smoke Management Programs
7 (ESMP)
8 DRAFT: 3/12/02
9
10 Recommendations for the Establishment of
11 Enhanced Smoke Management Programs
12 (ESMP)
13 DRAFT: 3/12/02
14
15 CONTENTS
16
17 I. Introduction page 2
18
19 Background
20 Context
21 SMP
22 ESMP
23 Purpose
24 Scope/Applicability
25 308/09
26 Class I Areas
27 Fire Type
28 ESMP Approach
29 Multi-level Approach
30 Regulatory Authority’s Responsibility
31 Criteria: Determining Levels
32 Impact-Based Criteria
33 Situational Criteria
34 Transport
35 Implementation
36 Legislative Barriers
37 Timeline
38 Trading Option (Keep in here or move to Appendices?)
39
40 II. ESMP Level Description page 19
41
42 Level 1 - 4
43 Rationale
44 Criteria
45 Action
ESMP Document Draft A, 3/12/02 II - A - 1
1 Oversight Authority
2 Program Infrastructure
3
4 III. Appendices page 25
5
6 Glossary
7 BSMP Guidance doc, AAQTF doc, EPA’s Interim Policy, NBTT Policy
8 Additional ESMP Information
ESMP Document Draft A, 3/12/02 II - A - 2
1 Recommendations for the Establishment of
2 Enhanced Smoke Management Programs
3 (ESMP)
4 Draft: 3/12/02
5
6
7 Key: Yellow highlight = Comments/questions to Task Team
8 Pink highlight = Need to research
9
10 I. Introduction
11
12 Background
13 In 1990, Congress amended the Clean Air Act, and as part of these amendments created
14 the Grand Canyon Visibility Transport Commission1 (GCVTC). The GCVTC was
15 charged with assessing the current scientific information on visibility impacts and making
16 recommendations for addressing regional haze in the western United States. The GCVTC
17 signed and submitted more than 70 Recommendations to the Environmental Protection
18 Agency (EPA) in a report dated June 1996 that indicated that visibility impairment was
19 caused by a wide variety of sources and pollutants, and that a comprehensive strategy
20 was needed to remedy regional haze. Fire sources were among those specifically
21 acknowledged as contributors to visibility impairment, and one recommendation to
22 address this included the implementation of smoke management programs to minimize
23 effects of all fire activities on visibility.2
24
25 The Western Regional Air Partnership (WRAP) was established in 1997 as the successor
26 organization to the GCVTC. The WRAP is a voluntary organization comprised of
27 western governors, tribal leaders and Federal agencies,3 and is charged with
28 implementing the GCVTC Recommendations, as well as addressing broader air quality
29 issues, such as the Regional Haze Rule (Rule). The WRAP is designed as a stakeholder-
30 based organization, which uses consensus for development of policy and technical tools
31 to assist states and tribes in the WRAP region. WRAP participants include state air
32 quality agencies, tribes, Federal/state/private land managers, the EPA, environmental
33 groups, industry, academia and other interested parties.
1
The GCVTC was composed of the governors of eight western states (AZ, CA, CO, NM, NV, OR, UT,
WY), four tribes (Acoma Pueblo, Hopi, Hualapai, and Navajo), four Federal land management agencies
(Bureau of Land Management, U.S. Fish and Wildlife Service, U.S. Forest Service, National Park Service),
the Columbia River Inter-Tribal Fish Commission, and the Environmental Protection Agency.
2
RHR, IV, A, p. 35748
3
The WRAP members include the governors of thirteen western states (AK, AZ, CA, CO, ID, MT, ND,
NM, OR, SD, UT, WA, and WY). Tribal nations selected as WRAP members to represent the 247 tribes
within the WRAP region include Pueblo of Acoma, Campo Band of Kumeyaay Indians, Cortina Indian
Rancheria, Hopi Tribe, Hualapai Nation of the Grand Canyon, Nez Perce Tribe, Northern Cheyenne Tribe,
Salish and Kootenai Confederated Tribes, Pueblo of San Felipe, and Shoshone-Bannock Tribes of Fort
Hall. Federal WRAP members are the Department of the Interior, the Department of Agriculture, and the
Environmental Protection Agency.
ESMP Document Draft A, 3/12/02 II - A - 3
1
2 Following the issuance of the GCVTC Recommendations, the EPA issued the Regional
3 Haze Rule (Rule)4 in July 1999 to improve visibility in 156 national parks and wilderness
4 areas across the country. The Rule outlines the requirements for states and tribes to
5 address regional haze in Federal Class I areas. EPA incorporated all of the GCVTC
6 Recommendations into Section 309 of the Rule, which may be used by some of the
7 WRAP states. The remaining WRAP states must utilize the nationally applicable Section
8 308 provisions of the Rule.
9
10 Progress toward the national [visibility] goal will require regional programs that
11 operate over large geographic areas and limit emissions of pollutants that can
12 cause regional haze. (RHR, II, D, 2. p. 35718)
13
14 EPA recognizes the WRAP as the Regional Planning Organization that is developing the
15 necessary policy and technical tools to implement the Regional Haze Rule in the WRAP
16 region.
17
18 Context
19
20 Current Smoke Management Programs
21 Most current smoke management programs to date in the WRAP region have been
22 developed to address public health and nuisance concerns. Generally, they do not
23 address all the potential visibility-impacting fire sources (prescribed fire on wildlands,
24 wildland fire use, wildfire and agricultural burning), nor do they have procedures to
25 specifically address minimization of visibility impacts. The EPA’s Interim Air Quality
26 Policy on Wildland and Prescribed Fires (Interim Policy) and the AAQTF Air Quality
27 Policy on Agricultural Burning (AAQTF) were developed to guide states/tribes in
28 addressing, primarily, public health (NAAQS) impacts of smoke as well as to help guide
29 land managers in reduction of impacts from burning operations.
30
31 In its Interim Policy on smoke management programs, the EPA lists seven basic
32 components that it requires for a smoke management program to be certifiable, including:
33 A) Authorization to Burn, B) Minimizing Air Pollution Emissions, C) Smoke
34 Management Components of a Burn Plan, D) Public Education and Awareness, E)
35 Surveillance and Enforcement, F) Program Evaluation and G) Optional Air Quality
36 Protection.5
37
38 The AAQTF sets up a two-tiered voluntary program, in which the first tier is based on a
39 predetermined set of burn conditions. The second tier is designed for areas where
40 agricultural burning would be expected to contribute to NAAQS violations or to visibility
41 impairment in mandatory Federal Class I areas. In this second tier, many of the same
42 elements as the EPA requires in its Interim Policy are involved, including burn
4
Published in the Federal Register on July 1, 1999 (64 FR 35714).
5
EPA Interim Policy cite, pp. 17-23.
ESMP Document Draft A, 3/12/02 II - A - 4
1 authorization, air quality monitoring, emissions reductions techniques, public
2 notification, and enforcement requirements.6
3
4 The ESMP recommendations are based on the assumption that states/tribes are currently
5 addressing NAAQS and/or nuisance to the extent they deem appropriate through existing
6 smoke management efforts or programs, and further, that states/tribes are using the
7 available EPA guidance to address this public health priority. Even so, there is
8 considerable disparity among current smoke management efforts of the states and tribes
9 in the WRAP region.7
10
11 Some states/tribes do not have smoke management programs at all, some have legislative
12 barriers that impede or prohibit their ability to address all fire emissions, while others
13 have substantial programs that regulate one or more fire sources in PM-10 non-attainment
14 areas. Additionally, most states/tribes address fire source sectors differently, as does EPA
15 in its guidance documents. Consequently, fire sources in the WRAP region are currently
16 regulated at various and inconsistent levels, from rigorous regulation to regulation with
17 exemption applied, to no regulation. This variability creates a significant challenge for
18 development of consistent and universal ESMP recommendations for the WRAP region.
19
20 Enhanced Smoke Management Programs for Visibility/Regional Haze (ESMP)
21 The GCVTC Recommendations acknowledged the role of fire across the region and
22 noted that the use of fire would increase in the future. Several of the GCVTC
23 Recommendations addressed the need for minimizing the visibility impacts from such
24 increases in order to achieve reasonable progress. However, the GCVTC
25 Recommendations as well as Section 309 of the Rule do not require a reduction of total
26 fire emissions as a demonstration of reasonable progress and further, support the need for
27 the increased use of fire to address the current fuels crisis on the country’s wildlands.
28 Both the GCVTC Recommendations and Section 309 specifically cite the establishment
29 of enhanced smoke management programs as the means to ensure that reasonable
30 progress toward the National Visibility Goal is made. [Cite necessary?]
31
32 An integral part of the existing EPA policy on SMPs is the clear guidance to consider the
33 visibility effects of burning when planning burning operations and to consider
34 alternatives to burning as well as the of use of other emission reduction practices.
35 However the policy does not provide specific mechanisms for the development of a
36 visibility/regional haze smoke management program. EPA’s Interim Policy states:
6
AAQTF, p.2
7
Very few states/tribes have smoke management programs that address all fire sources in one unified
program. As a result some fire sources may have little or no regulation while other fire sources in the same
area may have a stringent centralized authority deciding which burns may be conducted and when. Based
on the FEJF Reports [cite], prescribed fire on public wildlands is the most regulated fire source sector, with
a daily centralized authority decision-making type smoke management programs existent in a majority of
WRAP states (AZ, CA, OR, WA, ID, MT, UT). Only three states (CA, OR, WA) in the WRAP Region
actively regulate and track agricultural fire sources, and smoke management programs for private rangeland
burning are less common than agricultural smoke management programs.
ESMP Document Draft A, 3/12/02 II - A - 5
1 After the regional haze rules become final, states[tribes] will need to address the
2 impacts of fires and other contributing sources on meeting reasonable progress in
3 their control strategy analyses, as well as during periodic progress assessments.
4 The EPA will revisit this section of the Air Quality Policy on Wildland and
5 Prescribed Fires after the final rules for implementing the regional haze program
6 have been promulgated.8
7
8 To date, the EPA has not revisited the Interim Policy to integrate regional haze
9 considerations outlined in the Rule.
10
11 The AAQTF, in its Policy published after the EPA’s Interim Policy, addresses regional
12 haze as follows:
13
14 [The Regional Haze Rule] establishes a program to facilitate the integration of
15 emission management strategies for regional haze with SIP[TIP] components that
16 address emissions of NOx, SO2, VOCs and PM2.5. The Rule strongly encourages
17 multi-state planning efforts to address the haze issue and Air Quality Agencies are
18 moving forward with this effort.9
19
20 The Regional Haze Rule refers to smoke management programs (SMPs) as a means to
21 protect public health, prevent NAAQS violations, mitigate nuisance smoke, as well as
22 address visibility impacts in Class I areas. Per the Rule, visibility concerns must be
23 included in smoke management programs, which must include actions to minimize
24 emissions, evaluate smoke dispersion, consider alternatives to burning, notify the public,
25 monitor air quality, coordinate regionally, conduct surveillance and enforcement
26 activities, and periodically evaluate the program.10 These categories of smoke
27 management efforts are those found in EPA’s Interim Policy and the AAQTF
28 Recommendations. In addition, a system to inventory and track emissions must be
29 developed and maintained.
30
31 In section 308, the Rule states:
32
33 (v) The state must consider, at a minimum, the following factors in developing its long-
34 term strategy [for regional haze]:
35 (E) Smoke management techniques for agricultural and forestry management purposes
36 including plans as currently exist within the states for these purposes.11
37
38 And:
39 The State must identify all anthropogenic sources of visibility impairment considered by
40 the State in developing its long-term strategy. The State should consider major and minor
41 stationary sources, mobile sources, and area sources.12
8
EPA’s Interim Policy, p. 31
9
AAQTF, Section E, p. 10
10
Cite RHR, p. ?
11
RHR, section ?, p. 35767
ESMP Document Draft A, 3/12/02 II - A - 6
1
2 In section 309, the Rule states:
3
4 (6) Programs related to fire. The plan must provide for
5 (iv) Enhanced smoke management programs for fire that consider visibility effects, not
6 only health and nuisance objectives, and that are based on the criteria of efficiency,
7 economics, law, emission reduction opportunities, land management objectives, and
8 reduction of visibility impact.13
9
10 Visibility impacts are to be mitigated through smoke management programs that also
11 address public health (NAAQS) and nuisance smoke. In this way, the smoke management
12 program is enhanced to add visibility/regional haze considerations to existing smoke
13 management efforts that address NAAQS and nuisance. Although the ESMP is based on
14 the assumption that the respective state/tribe has addressed their public health and
15 nuisance concerns associated with smoke in their current smoke management efforts, the
16 ESMP approach is structured to integrate visibility protection with NAAQS and nuisance
17 protection.
18
19 The regional haze program is being promulgated in a manner that facilitates
20 integration of emission management strategies for regional haze with the
21 implementation of programs for new NAAQS for ozone and PM.14
22
23 It is clear that fire emissions contribute to regional haze and that they should be managed
24 and controlled to the maximum extent feasible. The WRAP Policy on Categorizing Fire
25 Emissions states:
26
27 A. All fires must be managed to minimize visibility impacts.
28 B. All emissions from fire classified as an “anthropogenic” source will be
29 controlled to maximum extent feasible, subject to economic, safety, technical and
30 environmental considerations.
31 C. Emissions from all fires will be tracked.15
32
33 The implementation of the cited guidance is crucial to a state’s/tribe’s capability to
34 manage all the potential smoke impacts from burning operations. Use of alternatives to
35 burning as well as impact and emission reduction practices should be employed where
36 possible regardless of the adoption of this ESMP.
37
38 However, there exists the practical reality of putting in place an ESMP that fully
39 regulates (i.e., go/no go decisions) all fire sources for a state/tribe that currently has no
40 smoke management program infrastructure and/or legislative barriers to one. Further, the
41 assumption that all states/tribes should have identical smoke management programs
42 ignores the wide variety of circumstances among geographical areas and source sectors in
12
RHR, section ?, p. 35767
13
RHR, section ?, p. 35771
14
RHR, section ?, p. 35719, emphasis added.
15
WRAP Policy on Categorizing Fire Emissions, Section 2.1., p. 8
ESMP Document Draft A, 3/12/02 II - A - 7
1 the WRAP region, and could prove unduly onerous for some states/tribes. Therefore,
2 these ESMP recommendations have been developed to provide a mechanism by which
3 states/tribes can develop smoke management programs that relate to their specific
4 circumstances, which can be further refined with more localized solutions and
5 approaches.
6
7 These recommendations outline a framework for adding visibility considerations to
8 existing smoke management programs and, where no smoke management programs exist,
9 the establishment of new programs that integrate visibility concerns with those of public
10 health and nuisance. ESMP does not erode states/tribes’ current smoke management
11 efforts, but rather, assumes that states/tribes will maintain their current smoke
12 management efforts and/or smoke management programs for NAAQS/nuisance.
13
14 If there are no other state/tribe smoke management efforts, ESMP will still apply, thus
15 addressing the Regional Haze Rule requirements. While ESMP provides a framework for
16 visibility/regional haze, states/tribes may choose to do more to protect NAAQS, prevent
17 nuisance and/or address visibility. The ESMP recommendations strongly encourage
18 states/tribes to utilize, wherever possible, smoke management and control practices as
19 standard operating procedure and best management practice.
20
21 Purpose
22 The purpose of the Recommendations for the Establishment of an Enhanced Smoke
23 Management Program (ESMP) is to address direct visibility impacts and regional haze in
24 mandatory Federal Class I areas so as to improve visibility on the worst days and
25 maintain visibility on clean days. Worst days are defined as those days that fall in the
26 lowest 20th percentile for visibility measurements from IMPROVE monitoring, and the
27 best days are those days that are in the highest 20th percentile on an annual basis.
28
29 These recommendations address impacts to visibility impairment in Class I areas from
30 sources within a state/tribal jurisdiction and also impacts to those Class I areas beyond a
31 state’s/tribe’s jurisdictional boundaries. In keeping with EPA policy and the Rule, these
32 recommendations are the result of WRAP region-wide multi-state planning and
33 coordination efforts focused on addressing the development of smoke management
34 programs that address visibility and regional haze.
35
36 …progress toward the national [visibility] goal will require regional programs that
37 operate over large geographic areas and limit emissions of pollutants that can
38 cause regional haze…16
39
40 The ESMP recommendations have been developed to assist WRAP states/tribes meet the
41 requirements of the Regional Haze Rule, and are based on equitability, predictability, and
42 feasibility. These ESMP recommendations use the existing policy on smoke management
43 programs provided by EPA for both wildland and agricultural burning. The ESMP
44 approach goes beyond the existing policy in addressing mandatory steps, required by the
16
RHR, Section D, 2, p. 35718
ESMP Document Draft A, 3/12/02 II - A - 8
1 Rule, such as emissions tracking, management and control of fire emissions, that are also
2 addressed in the WRAP Policy for Categorizing Fire Emissions.
3
4 States and tribes in the WRAP region are anticipated to incorporate the ESMP
5 recommendations into the SIP/TIP submitted to EPA in order to meet the requirements of
6 the Rule. This document takes into consideration the differences among WRAP
7 states/tribes with regard to air quality issues, emissions information, fire source sectors,
8 and state legislative or tribal governmental barriers in its proposed ESMP and
9 implementation timeframe. As the SIPs/TIPs will be revisited and revised, per the
10 schedule specified in the Rule, there will be opportunities to refine the ESMP to reflect
11 scientific advances and policy changes.
12
13 Should the requirements of the Rule not be met by states/tribes, EPA could intervene
14 (e.g., FIP). The ESMP has been developed to assist states/tribes in implementing the Rule
15 and preventing EPA intervention.
16
17 Scope/Applicability
18
19 Sections 308 and 309
20 States/tribes complying with either Section 308 or 309 of the Regional Haze Rule will
21 need a program to develop and track reasonable progress toward the natural visibility
22 goal, calculate baseline and natural visibility conditions, develop a long-term strategy for
23 management of emissions, establish a monitoring strategy, prepare periodic reports
24 demonstrating progress, and develop or update SIPs/TIPs. Further, emissions from all
25 fire (wildland and agricultural) are to be accounted for in both Sections 308 and 309 of
26 the Rule [cite].
27
28 Section 118(a) of the Clean Air Act requires that all entities, federal and non-federal, be
29 subject to the same requirements, authorities and processes, and the Rule is clear that all
30 sources, facilities, and property are to be treated equitably [cite]. Additionally,
31 stakeholder input garnered in the categorization of fire emissions process supported
32 consistent consideration of fire between Sections 308 and 309 of the Rule. Therefore, this
33 document recommends that the ESMP will be universally applied among the states and
34 tribes in the WRAP region.
35
36 It is anticipated that the establishment of enhanced smoke management programs will be
37 incorporated into the State or Tribal Implementation Plans (SIP/TIP) submitted to EPA in
38 order to meet the requirements of the Rule. States/tribes complying with Section 308
39 must have incorporated Regional Haze requirements into their SIPs/TIPs within 12
40 months of designation as PM2.5 attainment, or within three years after designation as
41 PM2.5 non-attainment, but no later than December 31, 2008. States complying with
42 Section 309 of the Regional Haze Rule will need to have a Regional Haze SIP submitted
43 by December 31, 2003, with implementation of cited control measures, such as the use of
44 an enhanced smoke management program, by the following year.
45
46 Class I Areas
ESMP Document Draft A, 3/12/02 II - A - 9
1 These recommendations apply to impacts on mandatory Federal Class I areas in the
2 WRAP region. Each state/tribe has an obligation to account for the emissions in its own
3 Class I areas, as well as for those emissions it produces that have impacts outside its
4 jurisdiction. The ESMP recommendations lay the groundwork for allowing this to occur.
5
6 Section 309 of the Rule specifies that the Class I areas of the Colorado Plateau be
7 addressed in the 2003 SIP submittal, and all Class I areas that were not included initially
8 by states opting for the 309 pathway will be included by the 2008 SIP deadline. For
9 WRAP states not opting for Section 309, Section 308 stipulates all Class I areas be
10 addressed in a SIP submittal tied to the PM2.5 designation (2005 – 08).
11
12 Fire Source Type
13 Fire sources are currently regulated at various levels, from rigorous regulation to
14 regulation with exemption applied, to no regulation. This approach to ESMP has been
15 designed to accommodate these differences, and in so doing, applies to both wildland and
16 agricultural lands regardless of ownership (i.e., Federal, state, tribal, public, private),
17 cause of ignition (e.g., lightning, arson, accidental human, land management practices) or
18 purpose of the fire (e.g., vegetative residue disposal, hazard reduction, maintain
19 ecosystem health).17 It is the intent that the ESMP be applied equitably across all land
20 types and sources.
21
22 In accordance with the Rule and the subsequent WRAP Policy for Categorizing Fire
23 Emissions, the fire emissions classifications of “natural” and “anthropogenic”18 are
24 incorporated into the different levels of smoke management and control in an ESMP. For
25 example, those fire sources that are classified as “natural” will be managed, and
26 “anthropogenic” sources can have varying degrees of control based on the Policy’s
27 feasibility criteria.19 This will facilitate the demonstration of reasonable progress in
28 SIPs/TIPs that takes into account natural background condition values as outlined in the
29 Rule.
30
31 The EPA also recognizes that fire of all kinds (wildfire, prescribed fire, etc.)
32 contributes to regional haze, and that there is a complex relationship between
33 what is considered a natural source of fire versus a human-caused source of fire.20
34
35 The smoke management plans [that consider visibility effects] must address all
36 sources of fire used for land management purposes.21
37
38 These recommendations do not apply to other open burning activities on residential,
39 commercial, or industrial property (e.g., backyard burning, garbage incineration,
40 residential wood combustion, construction debris). These recommendations do not apply
17
WRAP Policy on Categorizing Fire Emissions, Section 1.4., p. 7
18
For more information about fire source classification, see the WRAP Policy on Categorizing Fire
Emissions. [cite website?]
19
WRAP Policy for Categorizing Fire Emissions, Section 3.1.2., p.11
20
64 FR 35735.
21
RHR, IV, C, 6, p. 35753
ESMP Document Draft A, 3/12/02 II - A - 10
1 to Native American cultural non-vegetative burning for traditional, religious or
2 ceremonial purposes (e.g., cremation, sweat lodge fires).22
3
4 Enhanced Smoke Management Programs for Visibility: Approach
5
6 Multi-level Approach
7 The multi-level approach to the ESMP as outlined here provides an equitable and
8 practical method to managing smoke emissions for visibility. The multi-level approach
9 takes into account the current differences among states/tribes in the WRAP region as to
10 source sector burning practices, air quality issues and current smoke management efforts.
11 This ESMP framework provides for the systematic development of smoke management
12 programs across the WRAP region that address visibility impairment in Class I areas and
13 are compatible with current smoke management efforts for NAAQS and nuisance.
14
15 The ESMP is made up of four additive levels, i.e., each level adds a new and higher level
16 of controls and accountability based on visibility impacts. These additive levels provide
17 for economic efficiency by preventing over-regulation of a fire source that is not a
18 contributor to visibility impairment and regional haze. The multi-level approach also
19 assists those states/tribes currently without smoke management programs and the related
20 infrastructure to feasibly begin addressing smoke management for visibility. At the same
21 time, these ESMP recommendations will enable those states/tribes with more advanced
22 programs to expeditiously address their visibility concerns.
23
24 To further address the variability of current smoke management efforts that exist between
25 sectors (agricultural lands and wildlands) and geographic or political regions
26 (states/tribes, counties, airsheds), different levels of ESMP may be applied to these
27 categories. For example, if wildland burning is projected to increase in a given area and
28 there is minimal agricultural burning there, the state/tribe could choose to adopt a higher
29 level ESMP for the wildland fires than for the agricultural burning. This approach is
30 especially useful where there is currently little smoke management effort being applied.
31
32 The Policy for Categorizing Fire Emissions creates the concept of management and
33 control of fire emissions wherever possible, subject to economic, safety, technical and
34 environmental considerations. Those considerations will vary from state to state, fire
35 source sector to fire source sector, resulting in the potential patchwork of ESMPs across
36 the WRAP region. In recognition of this, the ESMP recommendations allow a multi-level
37 approach that is sensitive to the difference among the states/tribes and so can be utilized
38 to develop ESMPs that address these specific circumstances.
39
40 The multi-level approach is intended to complement existing smoke management efforts
41 and smoke management programs, where they currently exist. This approach is not
42 intended to erode any current efforts to address smoke effects on public health, nuisance
43 or visibility. In accordance with this, a state/tribe’s current smoke management efforts
22
WRAP Policy on Categorizing Fire Emissions, Section 1.4., p. 7
ESMP Document Draft A, 3/12/02 II - A - 11
1 are the starting point for that sector and/or geographic area and are subject to the
2 thresholds for movement to a more stringent ESMP level as outlined below.
3
4 Regulatory Authority’s Responsibility
5 The multi-level approach identifies the minimum responsibilities incumbent on the
6 burners/burn community and on the regulators. Throughout all the levels it is assumed
7 that the regulatory authority (state/tribe) has the oversight for the enhanced smoke
8 management program through its SIP/TIP,23 although it may choose to delegate
9 implementation to another entity, e.g., county or municipality. Therefore, it is the
10 regulatory authority’s responsibility to ensure that the mechanisms and infrastructure are
11 in place to implement the particular ESMP level. In most cases this will mean a system
12 such as consistent forms, databases or websites, or on-site mechanisms by which the
13 needed information will be obtained from the burner. It will also be the responsibility of
14 the regulatory authority to track and determine the amount of the contribution to visibility
15 impairment in Class I areas.
16
17 With each higher level of ESMP, the responsibilities of the regulatory authority increase,
18 as does the infrastructure necessary to implement the level and authority. For example, at
19 level 3 ESMP, burn authority (go/no-go decision-making) is added to the regulatory
20 authority’s responsibilities, as is tracking and enforcement of use of emissions reductions
21 techniques. In some cases, states/tribes will choose to institute a centralized authority
22 (e.g., agricultural burn manager) to handle the various responsibilities involved with
23 implementing and maintaining its ESMP.
24
25 It is the burner’s responsibility to ensure that data and information submitted to the
26 regulatory authority are accurate, timely, and complete. At level 1 this may be no more
27 onerous than a form faxed by the burner to the regulatory authority’s office at the end of
28 the year. At level 3, it requires extensive information on a daily basis regarding planned
29 and accomplished burning.
30
31 Baseline Requirement
32 [Tie to Annual Emissions Goal for 309 reasonable progress demonstration thru 2018]
33 In keeping with the GCVTC Recommendations, the Rule, and the WRAP Policy on
34 Categorizing Fire Emissions, all emissions from fire sources in the WRAP region,
35 regardless of ownership, land use type or cause of ignition, need to be tracked. Therefore,
36 the baseline ESMP requirement is the tracking of all fire source emissions. 24
37
38 According to the WRAP Policy on Categorizing Fire Emissions:
39
40 Emissions from all fires will be tracked for two purposes, to classify the fire as
41 “natural” or “anthropogenic”, and, if “anthropogenic”, to facilitate the
42 demonstration of reasonable progress….[Further,] the use of alternatives and
23
22 64 FS 35767, Regional haze program requirements 51.308(d)(3)(v)(E).
24
[Cite GCVTC – Rec #2 re: Fire – “Implement an emissions tracking system for all fire activities.” p.48]
ESMP Document Draft A, 3/12/02 II - A - 12
1 emission reduction practices needs to be in a fire emissions tracking system for
2 the demonstration of reasonable progress….”25
3
4 The Rule also requires that there be evaluation of visibility impairment from smoke for
5 both planning and operational purposes.26 In order to facilitate planning, the baseline
6 requirement includes the assimilation of projection information for the various fire source
7 sectors. To facilitate the operational aspect, and in keeping with the WRAP Policy for
8 Categorizing Fire Emissions on management of fire emissions, a part of the ESMP
9 baseline requirement will be basic considerations of transport issues and for timing of
10 ignitions for better dispersion.27
11
12 Level 1 ESMP is not only a baseline requirement for the program, but may also be all that
13 is necessary for a state/tribe. This is due to the fact that, since air quality problems have
14 common precursor pollutants, what a state/tribe is doing to address NAAQS may be
15 sufficient to meet reasonable progress goals.28 This being said, a state/tribe should not
16 assume that this is the case, and is encouraged to review the ESMP Criteria: Determining
17 Levels to ascertain its appropriate ESMP level.
18
19 The baseline requirement of emissions tracking is achieved through burn activity
20 information, e.g., day of burn, burn location, fuel type, tons per acre consumed, etc.). The
21 burn activity information is required of the wildland or agricultural burner regardless of
22 land ownership, cause of ignition, or purpose of the fire29. This burn activity information
23 will be used by the regulator(s) responsible for creating the emissions inventory.
24
25 Accurate inventories of regulated pollutants emitted by burning on wildlands and other
26 private lands will allow for tracking progress in emission reductions, revising SIPS to
27 reflect needed reasonable progress goal revisions, and modeling at the local to the
28 regional level to assess whether the reported emissions are consistent with monitoring
29 data.
30
31 In each ESMP level, additional information over the baseline requirement is identified
32 that the burner must provide to the state/tribe. The required information is proportionate
33 to the level being imposed, i.e., level 3 requires more information than level 2. However,
34 these recommendations do not prevent a burner or state from providing or collecting
35 more information to meet their individual needs at the different levels.
36
37 Whatever the level of the ESMP, it is important that information can be compared
38 between/within states or tribes in order to assess impacts to regional haze. By collecting
39 the seminal burn activity information uniformly, the emissions can then be calculated in a
40 consistent fashion across the WRAP region. This still allows for individual approaches to
25
WRAP Policy for Categorizing Fire Emissions, 3.1.3., p. 12
26
RHR, Section (d), 6, i. P. 35771
27
WRAP Policy on Categorizing Fire Emissions, Section 3.1.1., p. 10
28
RHR, II, E., p.35721
29
As required under the Policy for Categorizing Fire Emissions, page 8.
ESMP Document Draft A, 3/12/02 II - A - 13
1 emissions estimation at the state or tribal level while creating the opportunity for WRAP
2 states/tribes to create a consistent emissions calculation process.
3
4 Certainly, these methods will evolve over time, but it is their uniformity in application
5 that is critical. As the SIPs/TIPs will be revisited and revised, per the schedule specified
6 in the Rule, there will be opportunities to refine these recommendations to reflect
7 scientific advances and/or policy changes.
8
9 Criteria: Determining ESMP Levels
10
11 Impact-Based Criteria
12 The determination of a state/tribe’s ESMP level should be based on the relative
13 contribution to visibility impairment in Class I areas of its fire source sectors.
14
15 Since the national goal is expressed in terms of air quality (i.e., visibility) rather
16 than emissions, we believe that it is very important to require the quantitative
17 tracking of visibility impairment as an integral element in measuring reasonable
18 progress.30
19
20 Therefore, in general, the ESMP is impact based rather than emissions based so as to
21 emphasize the charge in the Rule of reducing visibility impact. This impact will be
22 measured in deciviews, with a > 1 deciview impact being the determining threshold that
23 triggers movement to a higher ESMP level.
24
25 From the point of implementation of ESMP level 1 (i.e., December 31, 2004), if a source
26 sector contributes to a ≥1 deciview impact on any one of the 20 percent worst days in a
27 calendar year, it will be required to move up one ESMP level. In order to determine this
28 impact, a visibility impact assessment will be required using IMPROVE Class I
29 monitored data, the ESMP fire activity data and contemporary visibility modeling
30 techniques. The IMPROVE data has a lag time, as does the visibility impact assessment,
31 and there must be full implementation of the prescribed ESMP level. Therefore this will
32 impact the time period that will occur before there is movement to a more stringent
33 ESMP level. The increasing stringency that occurs with the movement from the ESMP
34 baseline requirement to higher levels reflects a source sector’s continued contribution to
35 visibility impairment and regional haze for any Class I area.
36
37 The 1-deciview-impact metric is commonly associated with visibility analyses and is also
38 used within the PSD permitting process. In order to prevent degradation of the best
39 visibility days, the sector must move up a level in the ESMP if there is an increasing
40 contribution of fire sources/pollutants (excluding wildfire) present with a decline in
41 visibility of the 20 percent best days over the five year EPA averaging period, i.e., failure
42 to meet reasonable progress.
43
30
RHR, p. 35726
ESMP Document Draft A, 3/12/02 II - A - 14
1 In general, the movement from one level to a more stringent level can only occur as a
2 result of a visibility impact assessment that shows exceedance of the 1-deciview
3 threshold attributable to anthropogenic fire sources after full implementation of a level of
4 the ESMP. A new ESMP level cannot be required until full implementation of the
5 previous level shows exceedance of one of the above visibility thresholds. The 1-
6 deciview threshold is not cumulative and is calculated for a specific worst 20 percent day.
7
8 Wildfire on either agricultural lands or wildlands is not a fire source sector that can
9 trigger movement to a more stringent level. Prescribed fire on agricultural lands and
10 wildlands as well as wildland fire use/prescribed natural fire can trigger the movement to
11 a more stringent level. In other words, should fire source sectors be unable to manage
12 their emissions to avoid visibility impairment, more stringent ESMP levels will be
13 triggered.
14
15 As areas and sources that contribute to the regional haze problem may be from specific
16 geographic areas, the partitioning of a geographic area may be utilized under this
17 approach in a fashion similar to an area that becomes non-attainment for a criteria
18 pollutant. In this way, an entire state/tribe and/or source sector will not be penalized
19 unnecessarily. This partitioning of a sector would be at the discretion of the state or tribal
20 regulatory authority.
21
22 If the state/tribe demonstrates reasonable progress, it is up to its discretion as to whether
23 or not to allow movement from a more stringent ESMP to a less stringent ESMP level, as
24 long as the ESMP level 1 requirement is met.
25
26
27 Situational Criteria
28 Some stakeholders expressed concern that using the visibility impact assessment would,
29 in some cases, take too long and could in fact delay a state’s/tribe’s implementation of
30 smoke management efforts that were clearly indicated. For example, significant amounts
31 of burning directly adjacent to or within a Class I area would certainly have an impact on
32 visibility conditions in that Class I, and in this case, a visibility impact assessment would
33 be redundant. Therefore, the concept of criteria to proactively determine ESMP levels
34 was developed.
35
36 Criteria to describe certain circumstances that, if true, would indicate the need for an
37 ESMP above the baseline requirement of level 1 were added to the ESMP. These criteria
38 are based on Prevention of Significant Deterioration (PSD) permitting criteria so as to be
39 familiar to state/tribes in their application. If true, these criteria indicate that a level 3
40 ESMP, as described below, is indicated.
41
42 However, for those states/tribes for whom it would not be feasible to implement a level 3
43 program due to lack of infrastructure and/or legislative barriers, it is suggested that the
44 state/tribe use the level 2 elements as a guide for developing its ESMP.
45
ESMP Document Draft A, 3/12/02 II - A - 15
1 Level 2 ESMP recommends all of the same management and control measures as level 3
2 ESMP, but does not involve a centralized authority to regulate and enforce them. In other
3 words, level 2 ESMP is a burner-oriented program that depends on the state’s/tribe’s
4 provision of information to the burn community that enables burners to time their burns
5 for impact reduction and to implement best management practices. The intent of level 2
6 ESMP is to assist states/tribes in developing an ESMP that encourages and supports
7 burners to utilize smoke management and control measures wherever possible.
8
9 Level 3 ESMP (a mandatory program, enforced by a central authority) is determined
10 either by a confirmed contribution to visibility impairment in Class I areas through the
11 visibility impact assessment, or by the situational criteria. For those states/tribes that
12 already have centralized authority capability and/or no legislative barriers, it is suggested
13 that level 3 elements are used in the development of their ESMP.
14
15 States/tribes with fire source sectors that have impacts of >1 deciview to visibility
16 impairment of a Class I area will need to develop a level 3 ESMP. The situational criteria
17 will aid states/tribes, who are currently headed toward ESMP level 3 due to their
18 visibility impacts, to determine this fact in advance of the visibility impact assessment. In
19 this way, states/tribes who know they will need a level 3 program but that currently do
20 not have the capability to implement one, may use level 2 to prepare for a level 3
21 program. More importantly, developing a level 2 program could, through the
22 implementation of burner-driven smoke management and controls, prevent the state/tribe
23 from reaching the > 1 deciview threshold, and thus avoid the need to implement the more
24 costly level 3 program.
25
26 Level 4 ESMP can only be triggered by a state’s/tribe’s (or fire source sector’s) continued
27 contribution to visibility impairment in a Class I area, determined by the visibility impact
28 assessment.
29
30 Transport
31
32 In determining ESMP level, it will be important for the state/tribe to remember that
33 visibility impacts to any Class I area need to be considered, regardless of jurisdiction.
34
35 In developing each reasonable progress goal, the state[/tribe] must consult with
36 those states[/tribes], which may reasonably be anticipated to cause or contribute to
37 visibility impairment in the mandatory Class I Federal area.31
38
39 Therefore, it is possible that a state/tribe could trigger a higher level ESMP based only on
40 contributions to visibility impairment in Class I areas located in other state/tribe
41 jurisdictions.
42
43
44 Implementation
45
31
RHR, Section 51.308 (d), (1), (B), (iv), p. 35766
ESMP Document Draft A, 3/12/02 II - A - 16
1 Legislative Barriers
2 The ability of the state/tribe to implement the ESMP may require legislative changes to
3 existing rules or removal of exemptions from regulation of specific fire sources. Under
4 Section 309 there is a SIP submittal and subsequent commitment made by the appropriate
5 state or tribal regulatory authority to implement the ESMP. The multi-level process tied
6 to visibility thresholds within the ESMP is similar in nature to standard contingency
7 measures that are commonly used for non-attainment area SIPs. The timelines for the
8 visibility impact assessment continuously applied at each level of the ESMP will help
9 allow such legislative initiatives where needed. The development of these WRAP
10 recommendations may allow for direct citation in legislation that authorizes
11 establishment of an ESMP to address visibility impacts to regional haze. The concept of
12 moving to more stringent ESMP levels as a result of visibility impacts on Class I areas
13 outside of the regulatory agency’s jurisdiction from sources within their provenance
14 should also be included in enabling legislation.
15
16 Timeline
17
18 SIP 12/03
19 All states/tribes commit to ESMP (minimum level 1). For those states that have visibility
20 or emissions data, use situational criteria to determine level 2 or use visibility assessment
21 to determine level 3. For states/tribes with no data, start at level 1.
22
23 12/04
24 ESMP level 1 must be implemented. For states/tribes with no data, level 2 is encouraged
25 (incentive: possible prevention of need for ESMP level 3).
26
27 12/05
28 The first year of emissions data is available for those states/tribes that had none. In this
29 case, apply situational criteria and if applicable, start ESMP level 2.
30
31 SIP 12/08
32 IMPROVE data as well as emissions data should exist for all states/tribes to conduct a
33 visibility impact assessment to validate existing ESMP level or to determine ESMP level.
34 If the visibility impact assessment is inconclusive, the situational criteria could be used.
35
36 SIP 12/13
37 ALL states/tribes do visibility impact assessment in enough time to determine ESMP
38 level for this SIP. If impact of >1 deciview, ESMP level 3 or 4 is indicated.
39
40 Trading Option [Does this section still belong here or move to Appendices?]
41 An emission cap and trade program for fire sources could be used as a compliance option
42 under the annual emission goal requirements of Section 309 of the Regional Haze Rule.
43 In January 2001, the EPA issued a policy document entitled Improving Air Quality with
44 Economic Incentive Programs that provides information on discretionary economic
45 incentive programs (EIPs), including required elements of an EIP program. The EIP
ESMP Document Draft A, 3/12/02 II - A - 17
1 Guidance is designed to assist States or Tribes with meeting the requirements of EPA’s
2 Regional Haze Rule.
3
4 The EIP Guidance lists several EIP types such as Emission Averaging Programs, Source
5 Specific Emissions Caps, Multi-Source Emission Cap-and-Trade, and Open Market
6 Trading. Emission Averaging Programs and Source Specific Emission Caps are designed
7 for stationary sources that are subject to a rate-based regulatory limit. Emission Cap-and-
8 Trade and Open Market Trading EIPs allow sources flexibility in complying with
9 emission limits through emission reductions on a mass basis, not a rate-based system.32
10
11 The ESMP Policy does not recommend a uniform Trading Program at levels 1 – 3.
12 However, at level 4 it may be beneficial to establish a trading program for fire due to the
13 following:
14 • It may provide a valuable incentive for land managers to actively pursue non-burning
15 and emission reduction alternatives.
16 • It may dispel any perceived inequities among fire sources and other sources of air
17 pollution.
18 • [Need another advantage here to be equal to disadvantages]
19
20 The disadvantages of a program may be:
21 • The expense related to the reductions. The current EIP program is primarily
22 structured for stationary sources (which emit well quantified and monitored
23 pollutants) and contain rigid administrative requirements. A less rigid structure may
24 be needed to accommodate fire sources to reduce the costs.
25 • The seasonality of fire emissions may affect the success of an inter-source cap-and-
26 trade program.
27 • If the cap-and-trade program is limited to visibility impairing aerosols, there may not
28 be a pool of non-fire sources that would choose to participate.
29 None of the above precludes a state or regulatory entity from further pursuing the
30 viability of an emissions trading program at any ESMP level.
31 [Note: RHR addresses trading under 309 on p.35757 – need to include quote?]
32
32
Frances Bernards’ White Paper
ESMP Document Draft A, 3/12/02 II - A - 18
1 II. ESMP Level Description
2
3 The multi-level approach is additive, i.e., each level adds a new and higher level of
4 tracking/reporting to the level before. In other words, level 3 elements will include all of
5 those in levels 1 and 2, plus the new level 3 elements.
6
7 Level 1: Baseline Requirement
8 Rationale
9 The ESMP baseline requirement provides the foundation for quantifying the impact of
10 fire emissions on visibility by requiring, in accordance with the Regional Haze Rule33,
11 that all states/tribes begin a basic emissions inventory. In this way, ESMP commences the
12 inclusion of visibility concerns in states’ and tribes’ smoke management programs, and
13 provides an equitable starting point for those states that currently do not have smoke
14 management programs. This is a mandatory requirement for all states/tribes at all times.
15
16 It is possible that a state/tribe may not have a smoke management program, but will still
17 need to institute the baseline requirement of ESMP. For states/tribes in this position,
18 although not required, these recommendations do encourage them to assess the
19 applicability of establishing a smoke management program to address NAAQS and
20 nuisance, and guidance for doing so is included in the Appendix (see Basic Smoke
21 Management Program Guidance doc, EPA’s Interim Policy, AAQTF, etc.)
22
23 Action
24
25 1. Burn Activity Inventory
26
27 The Burn Activity information needs to be available to the state/tribe on an annual basis,
28 and needs to be attributable to any given day. This information can be estimated or
29 collected through direct methods (directly or indirectly determined, e.g., remote sensing,
30 survey, yearly log book). This might be done at a state/tribe level or through individual
31 burner tracking. States/tribes will have to implement their emissions tracking programs
32 by December 2004. It is anticipated that the conversion of the burn activity information
33 to an emissions inventory will be done by the state/tribe, or by the WRAP on behalf of
34 the states/tribes [?*]. All burners [who tracks wildfire?] need to track, at a minimum, the
35 following activity information, with the exception of de minimus burning levels of 10
36 acres or less per burn, or 50 acres total in a year. [Need consensus on de minimus levels
37 for cumulative totals]
38
39 Burn Activity Inventory:
40 Day of Burn Size of Burn (Acres)
41 Location Fire Source Sector
42 Fuel Type Anthropogenic or Natural
43 Tons per Acre Consumed
33
RHR states all 309 states will track emissions and all 308 states need to determine sources of impairment
and level of contribution. [Cite.]
ESMP Document Draft A, 3/12/02 II - A - 19
1 2. Projection Estimates (both 1-yr and 5-yr)
2 3. Burner utilizes state/tribe information to time ignitions for better dispersion and
3 consider transport issues
4 4. Visibility Impact Assessment with SIP/TIP submittal to determine appropriate level,
5 based on >1-deciview impact
6
7 Oversight Authority
8 State/Tribe is responsible, and may delegate to local authorities or entities, for
9 transmitting information/files electronically to central repository [WRAP on behalf of
10 states/tribes?*]. The state/tribe will provide information to the burn community to allow
11 for timing of ignitions for better dispersion and transport considerations.
12
13 Infrastructure
14 Minimal: Standardized Burn Activity Inventory requirements and annual
15 repository/compilation. Pamphlet outlining methods and conditions for better dispersion
16 and identification of downwind sensitive Class I areas.
17
18
19 Level 2: Smoke Management Program for Visibility (Burner-Driven)
20 Rationale
21 This level has the state/tribe in a support function to the burner community, assisting
22 burners to voluntarily utilize smoke management and control practices. This level
23 increases all aspects of a smoke management program for visibility, except for the
24 functions of a centralized authority, i.e., accountability, emissions control tracking, and
25 enforcement. In this way, states/tribes who know they will need a level 3 program may
26 start at level 2 as they prepare for level 3 infrastructure. Alternatively, this level may be
27 used by a state/tribe in advance of level 3 being triggered as a preventative measure, i.e.,
28 to avoid having to implement a level 3 program.
29
30 Criteria
31 Level 2 can be triggered in either of two ways. First, the state/tribe can use the situational
32 criteria below, which provide a description of scenarios under which a state/tribe can be
33 reasonably certain that an ESMP more stringent than the baseline requirement will be
34 necessary, i.e., if no smoke management efforts are employed, visibility will be impaired.
35
36 Alternatively, level 2 may be triggered by a state’s/tribe’s visibility impact assessment of
37 >1 deciview.
38
39 Situational Criteria (based on PSD criteria)
40 For each of the scenarios below, each of the indicators must be true. The scenarios are
41 functional equivalents of each other.
42
43 1) >50 tons/yr PM10 total for all anthropogenic fire sources per year
44 No PM-10 NAAs
45 Within and near (i.e., <50 km) of Class I (“near” – per RHR)
46
ESMP Document Draft A, 3/12/02 II - A - 20
1 2) >250 tons/yr PM10 total for all anthropogenic fire sources per year
2 No PM-10 NAAs
3 Within 100 km of Class I
4
5 3) >100 tons/yr PM10 total for all anthropogenic fire sources per year
6 With moderate PM-10 NAA/Maintenance Area
7 Within 100 km of Class I
8
9 4) >70 tons PM 10 total for all anthropogenic fire sources per year
10 Serious PM-10 NAA
11 Within 100 km Class I
12
13 [Ozone & >100km: Develop situational criteria for these??]
14
15 States/tribes can divide up the tonnage based on fire source to facilitate determining
16 different ESMP levels for different sources based on impact. 34:
17
18 Action
19 Level 2 will continue to require the Burn Activity Inventory, and will add a “real time”
20 reporting element. The same burn activity information inventory is required of the burner,
21 but in level 2 the information must be made available on a daily basis prior to the burn
22 and made available to cross-jurisdictional authorities. This could be done, for example,
23 by the burner submitting projected burning estimates to a regional or local entity that
24 would post the information on its website, or, if applicable, using a regulatory authority’s
25 website or phone-in.
26
27 If the burner is contributing to cross-jurisdictional (state/tribe) transport, then multi-
28 state/tribe information sharing will be included in this level. This added level of reporting
29 promotes the possibility of voluntary smoke management coordination. Multi-state
30 coordination paves the way for the ability to address smoke intrusions from outside areas.
31
32 Additionally, at level 2 all burners would voluntarily utilize smoke management and
33 control practices that lead to impact reduction & emission reduction (add detail…e.g.,
34 alts to burning).
35
36 Oversight Authority
37 The state/tribe has oversight authority, which it can delegate to local authorities, e.g.,
38 counties, etc. The state/tribe must conduct the Visibility Impact Assessment with its
34
Tons (PM10) Acres
Wildland (Forest: 20 tons/acre) Ag (4 tons/acre)
Consumed consumed
250 833 12,500
100 333 5,000
70 233 3,500
50 167 2,500
ESMP Document Draft A, 3/12/02 II - A - 21
1 SIP/TIP submittal to verify/determine its ESMP level, based on >1-deciview impact to a
2 Class I area. Further, the state/tribe is responsible for receiving the emissions inventory
3 information and projections, and then providing that information to WRAP.
4
5 Infrastructure (State/Tribe)
6 Moderate:
7 Standardized Burn Activity Inventory requirements and annual repository/compilation
8
9 In addition to above requirement, the state/tribe may provide (or find ways to provide)
10 the following support to the burn community to assist in impact reduction, and to avoid
11 the need for a centralized authority.
12
13 Website or other to post the pre-burn activity info for burners/regulators to
14 promote voluntary coordination
15 Website or other to make available info for smoke management practices
16 (moisture, weather, ventilation index, etc.)
17 Make WRAP guidance on emissions reduction techniques available (e.g., alts to
18 burning doc)
19 Provide burner qualifications and training
20
21
22 [Consider: per NBTT, include manage element for “N” i.e., addressing viz impacts of
23 wildfire and maintenance burns by …create examples of specific management action
24 here!]
25
26 Level 3: Smoke Management Program for Visibility (Mandatory/Enforced)
27 Rationale
28 Level 3 includes all of the elements at level 2, but adds a centralized authority to make
29 burn decisions and to track and enforce the required use of emissions and impact
30 reduction techniques.
31
32 In order for this mandatory implementation of emissions reduction and impact reduction
33 techniques to occur, the state/tribe must now create a centralized authority or delegated
34 authority (i.e., this need NOT be the state/tribe itself), if not already in place. This
35 centralized authority’s responsibilities include, but are not limited to, the following: the
36 approval and coordination of daily burning, the definition of minimum burner
37 qualifications, the review of Burn Plans [TT needs to define**], the promotion of public
38 education and awareness, and the enforcement of all of the above.
39
40 ** Burn Plan = Mandatory (?) -- Wildland already req’d under BSMP; Ag & Private kick
41 in here? – reference PFPA for recs on elements of a Burn Plan (cite)
42
43 Criteria
44
45 Visibility Impact Assessment of >1 deciview by a fire source category in a state/tribe on
46 a Class I area (any Class I, regardless of jurisdiction). At minimum, this visibility impact
ESMP Document Draft A, 3/12/02 II - A - 22
1 assessment MUST be done as soon as the state/tribe has the necessary data: IMPROVE
2 data and emissions inventory, but no later than the December 2013 SIP.
3
4
5 Action
6 Level 3 will continue to require the Burn Activity Inventory and Projected Estimates as
7 well as the Voluntary Coordination Information and smoke management and control
8 measures to the maximum extent feasible. The difference in level 3 is that now all of this
9 will be regulated by a central authority that will enforce these requirements.
10
11 Oversight Authority
12 State/tribe central authority (state/tribe determines what structure works for them). The
13 central authority will determine burn go/no go, and will enforce the mandatory use of
14 emissions reduction techniques, alternatives to burning, and impact reduction techniques,
15 to the maximum extent feasible. If cross-jurisdictional (state/tribe) transport is involved,
16 then multi-state/tribe coordination will be required: go/no go decision will need to
17 consider transport issues.
18
19 An annual report will now be needed and will include the number of non-fire alternatives
20 and emissions reduction techniques employed that could be tracked, and then allow for
21 the calculation of the amount of emissions saved. This tracking could be useful for
22 demonstrating reasonable progress toward emissions reduction goals and possible trading
23 purposes.
24
25 Components of the central authority’s information database must be developed so that
26 new information can be added and tracked without duplication of time and effort.
27
28 For planning purposes, the actual pre-burn information will need to include fuel loadings,
29 consumption expectations, if non-fire alternatives can be utilized and rationale for lack of
30 use, evaluation of potential smoke dispersion and visibility impacts, air quality
31 monitoring and public notification plans.
32
33 Infrastructure [this will be developed as narrative based on the below]
34 Significant:
35 Standardized Burn Activity Inventory forms and annual repository/compilation
36 Website or other to post burn activity info for burners/regulators to promote voluntary
37 coordination
38 Website or other to make available info for smoke management practices (moisture,
39 weather, ventilation index, etc.
40 Go/No-go Criteria
41 Emissions reduction tracking
42 Etc.
43
44 [Note: per NBTT: Explain “Control” for “A” see p. 11/ 3.1.2 NBTT]
45
46 [Consider difference between Ag AAQTF and Wildland BSMP – need separate tracks?]
ESMP Document Draft A, 3/12/02 II - A - 23
1 Level 4: Smoke Management Program for Visibility (Compulsory/Punitive?)
2 Rationale
3 Level 4 provides the framework for those states/tribes with continued contribution to
4 visibility impairment. In cases where level 4 applies, the state/tribe may be risking a
5 SIP/TIP call and worst-case, a FIP and loss of SMP oversight as well as possible law
6 suits.
7
8 Criteria
9
10 Reasonable progress is not being made, i.e., the visibility impact assessment of >1
11 deciview at a Class I area of three (?) consecutive years.
12
13 Action
14 If impacts continue within state/tribe boundaries, then the entire jurisdiction (state/tribe)
15 moves to level 4 ESMP.
16
17 If multi-state/tribe transport issues are involved, the burn decision-making should be at a
18 multi-state level (e.g., 4 Corners, Northern Tier, Inter-Mountain, etc.) Recommend that
19 the states/tribes involved, institute a multi-state/tribe burn authority to collect information
20 and make decisions. The burner would provide an annual estimation of burn activity,
21 including all inventory information from levels 1-3 to this multi-state coordination
22 authority.
23
24 The regulatory authority could consider possible special protection zones around the
25 affected Class I areas, possible burn curtailment, and possible emissions trading
26 programs.
27
28 Oversight Authority
29 State/tribe central authority, or, if level 4 is triggered by cross-jurisdictional impacts
30 (across state/tribe boundaries), then it is suggested that the involved jurisdictions elect a
31 multi-state/tribe authority to coordinate burning (e.g., burn authorization, criteria, info
32 sharing, etc.)
33
34 Infrastructure [this will be written in narrative form based on the below]
35 Significant:
36 Standardized Burn Activity Inventory forms and annual repository/compilation
37 Website or other to post burn activity info for burners/regulators to promote voluntary
38 coordination
39 Website or other to make available info for smoke management practices (moisture,
40 weather, ventilation index, etc.
41 Go/No-go Criteria & decision-making (if cross-jurisdictional transport: regional
42 authority)
43
ESMP Document Draft A, 3/12/02 II - A - 24
1 APPENDICES
2 [Note: Contents still TBD. Glossary, Copies or Bibliography of Relevant Docs, and
3 Additional Resources (see list of things to consider that mostly come from the ESMPTT
4 work product papers.)]
5
ESMP Document Draft A, 3/12/02 II - A - 25
1 ENHANCED SMOKE MANAGEMENT PROGRAM
2 Glossary of Terms & Acronyms
3 (DRAFT)
4
5 2064 Natural Conditions Goal - The ultimate goal of the regional haze program is the
6 absence of visibility impairment due to human-caused emissions.
7
8 Agricultural Air Quality Task Force (AAQTF) - A task force to address agricultural air
9 quality issues established by the Chief of the Natural Resources Conservation Service.
10
11 Absorption cross section - the amount of light absorbed by a particle divided by its
12 physical cross section.
13
14 Accidental Human Ignition - An unintentional random event. (E.g., Fire ignited by a
15 cigarette butt, an escaped campfire, or a combine.)
16
17 Activity Fuels - Fuels resulting from, or altered by, forestry practices such as timber harvest
18 or thinning, as opposed to naturally created fuels.
19
20 Actual Emissions - The actual rate of emissions of a pollutant from an emissions unit
21 calculated using the unit's actual operating hours, production rates, and types of materials
22 processed, stored, or combusted during the selected time period.
23
24 Aerial Ignition - Ignition of fuels by dropping incendiary devices or materials from aircraft.
25
26 Aerosol - a dispersion of microscopic solid or liquid particles in a gaseous medium, such as
27 smoke and fog.
28
29 Agricultural Fire/Burning - Any fire ignited by management actions to meet specific
30 objectives (i.e., managed to achieve resource benefits) on agricultural land.
31
32 Agricultural Land - Agricultural land includes croplands, pasture, and other lands on which
33 crops or livestock are produced (PL 104-127, Section 1240A). Rangeland will be included
34 with wildland for the purposes of the Fire Emissions Joint Forum work.
35
36 Allowable Emissions - The emissions rate that represents a limit on the emissions that can
37 occur from an emissions unit. This limit may be based on a federal, state, or local
38 regulatory emission limit determined from state or local regulations and/or 40 Code of
39 Federal Regulations (CFR) Parts 60, 61, and 63.
40
41 Alternatives To Burning (see Non-burning Alternatives) - no prescribed fire, no ignition
42 source.
43
44 Ambient Air Monitoring and Reporting Forum (AMRF) - The Ambient Air Monitoring and
45 Reporting Forum was established to make recommendations to the Western Regional Air
46 Partnership with regard to appropriate approaches for collection, use, and reporting of
ESMP Document Draft A, 3/12/02 II - A - 26
1 ambient air quality and meteorological monitoring data as needed to further the overall
2 goals of the Western Regional Air Partnership.
3
4 Annual Emissions - Actual emissions for a plant, point, or process, either measured or
5 calculated.
6
7 Anthropogenic - produced by human activities.
8
9 Anthropogenic Emissions Source Classification (“anthropogenic”) - A categorization that
10 designates which fire emissions contribute to visibility impairment in a Federal Class I area.
11 “Anthropogenic” emissions must be controlled to achieve progress toward the 2064 natural
12 conditions goal for each Federal Class I area in the WRAP region. This classification
13 includes natural and human-caused ignitions.
14
15 Apportionment - to distribute or divide and assign proportionately.
16
17 Area Source - A source category of air pollution that generally extends over a large area.
18 Prescribed burning, field burning, home heating, and open burning are examples of area
19 sources.
20
21 Area Sources - Smaller sources that do not qualify as point sources under the relevant
22 emissions cutoffs. Area sources encompass more widespread sources that may be abundant,
23 but that, individually, release small amounts of a given pollutant. These are sources for
24 which emissions are estimated as a group rather than individually. Examples typically
25 include dry cleaners, residential wood heating, auto body painting, and consumer solvent
26 use. Area sources generally are not required to submit individual emissions estimates.
27
28 Arson - The intentional, malicious or fraudulent ignition of a fire or explosion that damages
29 property of the arsonist or another. (E.g., A fire intentionally ignited to accrue ill-gotten
30 gains, such as from an insurance settlement, or a fire intentionally ignited as retribution
31 against a land manager.)
32
33 Attainment Area - an area considered to have air quality as good as or better than the
34 National Ambient Air Quality Standards (NAAQS) as defined in the CAA. Note that an
35 area may be in attainment for one or more pollutants but be a non-attainment area for one or
36 more other pollutants.
37
38 Avoidance - A smoke emission control strategy that considers meteorological conditions
39 when scheduling prescribed fires in order to avoid incursions into smoke sensitive areas.
40
41 Back Trajectory - a trace backwards in time showing where an air mass has been.
42
43 Basic Smoke Management Plan (BSMP) – the seven elements that make up an EPA
44 certifiable smoke management program for NAAQS/nuisance.
45
ESMP Document Draft A, 3/12/02 II - A - 27
1 Best Available Control Measures (BACM) - Control measures to be developed by
2 Environmental Protection Agency (EPA) which apply to residential wood combustion,
3 fugitive dust, and prescribed and silvicultural burning in "serious" PM-10 non-attainment
4 areas. BACM is more stringent than RACM. Final guidance on BACM is still being
5 developed.—is this true?
6
7 Best Management Practices –
8
9 Class I Area --
10
11 Clean Air Corridor --
12
13 Combustion Efficiency - The relative amount of time a fire burns in the flaming phase of
14 combustion, as compared to smoldering combustion. A ratio of the amount of fuel that is
15 consumed in flaming combustion compared to the amount of fuel consumed during the
16 smoldering phase, in which more of the fuel material is emitted as smoke particles because
17 it is not turned into carbon dioxide and water.
18
19 Control of Fire - The controllability of a fire is dictated by a variety of considerations such
20 as firefighter and public safety, risk to property and resources, fire fighting resources
21 available, land management objectives, and environmental, social, economic, and political
22 constraints. The environmental and social constraints include, among other things, how air
23 quality and/or visibility will be affected at sensitive receptors. Control of fire is analogous
24 to full suppression by management action.
25
26 Control of Fire Emissions - Actions may be taken to control fire emissions by utilizing best
27 management practices such as the use of alternatives, biomass utilization, and other
28 emission reduction techniques.
29
30 Criteria Pollutants - Carbon monoxide (CO), lead (Pb), nitrogen oxides (NO ), sulfur x
31 dioxide (SO ), Ozone (O ), particulate matter of aerodynamic diameter less than or equal to
32 2 3 10 micrometers (PM ) and particulate matter of aerodynamic diameter less than or equal
33 to 10 2.5 micrometers (PM ).
34
35 Cumulative Effects --
36
37 Deciview - a unit of visibility proportional to the logarithm of the atmospheric extinction.
38 Under many circumstances a change in one deciview will be perceived to be the same on
39 clear and hazy days.
40
41 De Minimus Levels --
42
43 Drift Smoke - Smoke that has drifted from its point of origin and is no longer dominated by
44 convective motion. May give false impression of a fire in the general area where the smoke
45 has drifted.
46
ESMP Document Draft A, 3/12/02 II - A - 28
1 Ecosystem Maintenance - A prescribed fire or wildfire managed for resource benefits, in an
2 ecosystem that is currently in an ecologically functional and fire resilient condition, that is
3 utilized to mimic the natural role of fire.
4
5 Ecosystem Restoration - The re-establishment of natural vegetation that may be
6 accomplished through the reduction of unwanted and/or unnatural levels of biomass, which
7 may have accumulated due to management action. Prescribed fires, wildfires managed for
8 resource benefits and mechanical treatments may be utilized to restore an ecosystem to an
9 ecologically functional and fire resilient condition.
10
11 Emission - pollution discharged into the atmosphere from smokestacks, other vents, and
12 surface areas of commercial or industrial facilities; from residential chimneys; and from
13 motor vehicle, locomotive, aircraft, or other non-road engines.
14
15 Emission Factor (EFp) - The mass of particulate matter produced per unit mass of fuel
16 consumed (pounds per ton, grams per kilogram).
17
18 Emission Factors - Ratios that relate emissions of a pollutant to an activity level at a plant
19 that can be easily measured, such as an amount of material processed, or an amount of fuel
20 used. Given an emission factor and a known activity level, a simple multiplication yields an
21 estimate of the emissions. Emission factors are developed from separate facilities within
22 an.8-3 industry category, so they represent typical values for an industry, but do not
23 necessarily represent a specific source. Published emission factors are available in
24 numerous sources.
25
26 Emission Inventory - A listing, by source, of the amount of air pollutants discharged into
27 the atmosphere of a community.
28
29 Emission Rate - The amount of smoke produced per unit of time (lb./min). Emission Rate
30 = Available Fuel x Burning Rate x Emission Factor.
31
32 Emission Reduction - A strategy for controlling smoke from prescribed fires that minimizes
33 the amount of smoke output per unit area treated.
34
35 Emission Standards - a general type of standard that limit the mass of a pollutant that may
36 be emitted by a source. The most straightforward emissions standard is a simple limitation
37 on mass of pollutant per unit time (e.g., pounds of pollutant per hour).
38
39 Emissions Goal/Cap
40
41 Emission Reduction (see Control)
42
43 Enhanced Smoke Management Plan (ESMP)
44
45 Entity --
46
ESMP Document Draft A, 3/12/02 II - A - 29
1 Escaped Prescribed Fire - Any fire ignited by management actions on wildland or
2 agricultural land to meet specific objectives that goes out of prescription (e.g., fire intensity
3 greater than specified in a pre-set fire plan, pre-set wind speeds exceeded, fire jumps pre-
4 established boundaries, etc.) in a predefined geographic area.
5
6 ESMP Criteria –
7
8 ESMP Elements – See ESMP Criteria above.
9
10 ESMP Task Team –
11
12 Federal Class I area - In 1977, Congress identified 156 national parks, wilderness areas,
13 international parks and other areas that were to receive the most stringent protection from
14 increases in air pollution. It also set a visibility goal for these areas to protect them from
15 future human-caused haze, and to eliminate existing human-caused haze, and required
16 reasonable progress toward that goal.
17
18 Fire Emissions Joint Forum (FEJF) - The Fire Emissions Joint Forum’s mission is to
19 address both policy and technical issues while developing programs and tools relating to
20 prescribed fire and air quality for the Western Regional Air Partnership and related Western
21 Regional Air Partnership forums.
22
23 Fine Fuel Moisture - The probable moisture content of fast-drying fuels which have a time
24 lag constant of 1 hour or less; such as, grass, leaves, ferns, tree moss, pine needles, and
25 small twigs (0-1/4").
26
27 Fire - When this term appears, it refers inclusively to wildfire, prescribed natural
28 fire/wildland fire managed for resource benefits, prescribed fire, rangeland fire, and
29 agricultural fire.
30
31 Fire Interval - Time (in years) between two successive fires in a designated area (i.e., the
32 interval between two successive fire occurrences); the size of the area must be clearly
33 specified.
34
35 Fire Regime - Periodicity and pattern of naturally-occurring fires in a particular area or
36 vegetative type, described in terms of frequency, biological severity, and area extent.
37
38 Fire Return Interval --
39
40 Fire Source –
41
42 Fire Use –
43
44 Flaming Combustion Phase - Luminous oxidation of gases evolved from the rapid
45 decomposition of fuel. This phase follows the pre-ignition phase and precedes the
46 smoldering combustion phase, which has a much slower combustion rate. Water vapor,
ESMP Document Draft A, 3/12/02 II - A - 30
1 soot, and tar comprise the visible smoke. Relatively efficient combustion produces minimal
2 soot and tar and white smoke; high moisture content also produces white smoke.
3
4 FLM Burn Plan --
5
6 Forest Residue - Accumulation in the forest of living or dead (mostly woody) material that
7 is added to and rearranged by human activities such as harvest, cultural operations, and land
8 clearing.
9
10 Fuel Loading - The amount of fuel present expressed quantitatively in terms of weight of
11 fuel per unit area. This may be available fuel (consumable fuel) or total fuel and is usually
12 dry weight.
13
14 Fuel Moisture Content - The quantity of moisture in fuel expressed as a percentage of the
15 weight when thoroughly dried at 212 degrees F
16
17 Fuel Reduction - Manipulation, including combustion, or removal of fuels to reduce the
18 likelihood of ignition and/or to lessen potential damage and resistance to control.
19
20 Fuel Size Class - A category used to describe the diameter of down dead woody fuels.
21 Fuels within the same size class are assumed to have similar wetting and drying properties,
22 and to preheat and ignite at similar rates during the combustion process.
23
24 Fuel Treatment - Manipulation or removal of fuels to reduce the likelihood of ignition
25 and/or to lessen potential damage and resistance to control (e.g., lopping, chipping,
26 crushing, piling and burning). (Syn. FUEL MODIFICATION)
27
28 Fuel Type - An identifiable association of fuel elements of distinctive species, form, size,
29 arrangement, or other characteristics that will cause a predictable rate of spread or
30 resistance to control under specified weather conditions.
31
32 Grand Canyon Visibility Transport Commission (GCVTC). - The GCVTC was authorized
33 under Section 169B(f) of the Clean Air Act and composed of the governors of eight western
34 states (AZ, CA, CO, NM, NV, OR, UT, WY), four tribes (Acoma Pueblo, Hopi, Hualapai,
35 and Navajo), four Federal land management agencies (Bureau of Land Management, U.S.
36 Fish and Wildlife Service, U.S. Forest Service, National Park Service), the Columbia River
37 Inter-Tribal Fish Commission, and the Environmental Protection Agency. The Commission
38 was established to recommend methods to preserve and improve visibility on the Colorado
39 Plateau, and submitted Recommendations to EPA in June 1996.
40
41 Hazard Reduction - Burning of accumulated wildland fuels to reduce the risk of wildfire.
42 (E.g., Wildland/urban interface burning or burning in areas of especially combustible fuels.)
43
44 Hydrocarbons - compounds containing only hydrogen and carbon. Examples
45
46 Hygroscopic - Readily absorbing moisture, as from the atmosphere.
ESMP Document Draft A, 3/12/02 II - A - 31
1
2 Impact Reduction -- see Manage.
3
4 Interagency Monitoring of Protected Visual Environments (IMPROVE) -- A cooperative
5 visibility monitoring effort, using a common set of standards across the United States,
6 between the EPA, Federal land management agencies, and state air agencies.
7
8 Jurisdiction --
9
10 Land Managers - When this term appears, it refers inclusively to Federal, state, tribal, and
11 private land managers.
12
13 Light Extinction - The net effect on the amount of light from a scene that reaches an
14 observer of particles that absorb light and particles that scatter light.
15
16 Maintenance Burning -- Prescribed burning (regardless of ignition), which emulates the
17 natural role that fire had on the ecosystem. This includes burning the same vegetation type,
18 similar fuel loading, seasonality and fire interval. Any use of prescribed fire that does not
19 conform to all of the above, is not considered maintenance burning. [Proposed by SK]
20
21 Manage Fire Emissions - Actions may be taken to manage fire emissions to minimize
22 impacts on visibility, public health, and nuisance concerns. Some management actions
23 include concepts such as the timing of ignitions for better dispersion and consideration of
24 downwind air quality and visibility. It may also include consideration of factors related to
25 the area to be burned such as the fuel moisture condition and other physical parameters.
26 Manage fire emissions is analogous to smoke management.
27
28 Modeling –
29
30 Monitoring - Periodic or continuous surveillance or testing to determine the level of
31 compliance with statutory requirements and/or pollutant levels in various media or in
32 humans, animals, and other living things.
33
34 National Ambient Air Quality Standards (NAAQS) - the main ambient standards for the
35 following criteria pollutants: carbon monoxide, lead, nitrogen oxides, sulfur oxides, ozone,
36 particulate matter of aerodynamic diameter less than or equal to 10 micrometers and
37 particulate matter of aerodynamic diameter less than or equal to 2.5 micrometers.
38
39 Natural Background Condition - An estimate of the visibility conditions at each Federal
40 Class I area that would exist in the absence of human-caused impairment.
41
42 Natural Emissions Source Classification (“natural”) - A categorization that designates
43 which fire emissions can result in a natural reduction of visibility for each Federal Class I
44 area in the WRAP region. This classification includes natural and human-caused ignitions.
45
ESMP Document Draft A, 3/12/02 II - A - 32
1 Natural Ignition - Fire/Burn ignited due to a natural (i.e., non-human-caused) event. (E.g.,
2 Fire ignited by lightning or volcanic eruption.)
3
4 Natural Background Task Team (NBTT) - A task team of the Fire Emissions Joint Forum
5 working on determining the classification of fire emissions as either “natural” or
6 “anthropogenic”. Team members include Forum and non-Forum members with special
7 expertise.
8
9 Non-Attainment Area – An area identified by an air quality regulatory agency through
10 ambient air monitoring (and designated by the Environmental Protection Agency), that
11 presently exceeds federal ambient air standards.
12
13 Non-Vegetative Burning - Burning of fuel that is not composed of vegetation (i.e., plants or
14 plant growth). (E.g., Cremation or sweat lodge fires.)
15
16 Nuisance - see, taste, smell, e.g., soiling of clothes on clothesline
17
18 Organic Carbon - Complex carbon-containing compounds often emitted by plants and from
19 many human activities.
20
21 Particulate Matter - Any liquid or solid particles. "Total suspended particulates" as used in
22 air quality are those particles suspended in or falling through the atmosphere. They
23 generally range in size from 0.1 to 100 microns.
24
25 Pasture Land - Grazing lands comprised of introduced or domesticated native forage
26 species that are used primarily for the production of livestock. They receive periodic
27 renovation and/or cultural treatments such as tillage, fertilization, mowing, weed control,
28 and may be irrigated. They are not in rotation with crops (Natural Resources Conservation
29 Service National Range and Pasture Handbook, 1997.)
30
31 Plume Blight - Visual impairment of air quality that manifests itself as a coherent plume.
32
33 Particulate matter of aerodynamic diameter less than or equal to 10 micrometers (PM10 ) --
34 A measure of small solid matter suspended in the atmosphere that can penetrate deeply into
35 the lung where they can cause respiratory problems. Emissions of PM10 are significant from
36 fugitive dust, power plants, commercial boilers, metallurgical industries, mineral industries,
37 forest and residential fires, and motor vehicles.
38
39 PM2.5 - Particulate Matter of aerodynamic diameter less than or equal to 2.5 micrometers A
40 measure of fine particles of particulate matter that come from fuel combustion, agricultural
41 burning, woodstoves, etc.
42
43 Point Source - a source of pollution that is point-like in nature. An example is the smoke
44 stack of a coal-fired power plant or smelter. See source.
45
ESMP Document Draft A, 3/12/02 II - A - 33
1 Point Sources - Large, stationary, identifiable sources of emissions that release pollutants
2 into the atmosphere. Sources are often defined by state or local air regulatory agencies as
3 point sources when they annually emit more than a specified amount of a given pollutant,
4 and how state and local agencies define point sources can vary.
5
6 Prescribed Fire - Any fire ignited by management actions to meet specific objectives (i.e.,
7 managed to achieve resource benefits).
8
9 Prescription - A written statement defining the objectives to be attained as well as the
10 conditions of temperature, humidity, wind direction and speed, fuel moisture, and soil
11 moisture, under which a fire will be allowed to burn. A prescription is generally expressed
12 as acceptable ranges of the prescription elements, and the limit of the geographic area to be
13 covered.
14
15 Prevention of Significant Deterioration (PSD) -- A program identified by the Clean Air Act
16 to prevent air quality and visibility degradation and to remedy existing visibility problems.
17 Areas of the country are grouped into 3 classes that are allowed certain degrees of pollution
18 depending on their uses. National Parks and Wilderness Areas meeting certain criteria are
19 "Class I" or "clean area" in that they have the smallest allowable increment of degradation.
20
21 Rangeland - Land on which the historic climax plant community is predominantly grasses,
22 grass-like plants, forbs, or shrubs. Includes lands re-vegetated naturally or artificially when
23 routine management of that vegetation is accomplished mainly through manipulation of
24 ecological principles. Rangeland includes natural grasslands, savannas, shrublands, most
25 deserts, tundra, alpine communities, coastal marshes and wet meadows (Natural Resources
26 Conservation Service National Range and Pasture Handbook, 1997.)
27
28 Reasonably Available Control Measures (RACM) - Control measures developed by EPA
29 which apply to residential wood combustion, fugitive dust, and prescribed and silvicultural
30 burning in and around "moderate" PM-10 non-attainment areas. RACM is designed to
31 bring an area back into attainment and uses a smoke management program that relies on
32 weather forecasts for burn/no-burn days.
33
34 Regional Haze - visibility impairment caused by the cumulative air pollutant emissions
35 from numerous sources over a wide geographic area.
36
37 Regional Planning Organization - An organization that will first evaluate technical
38 information on regional haze and related issues to better understand how their states and
39 tribes impact national park and wilderness areas (Federal Class I areas) across the country.
40 The organization will then pursue the development of regional strategies to reduce
41 emissions of particulate matter and other pollutants leading to regional haze. The five
42 Regional Planning Organizations that receive funding from EPA to address regional haze
43 and related issues are: Central States Regional Air Partnership (CENRAP) for the central
44 states, Midwest Regional Planning Organization for the mid-western states, Ozone
45 Transport Commission (OTC) for the northeastern states, Southeast States Air Resource
ESMP Document Draft A, 3/12/02 II - A - 34
1 Managers (SESARM) for the southeastern states, and Western Regional Air
2 Partnership(WRAP) for the western states.
3
4 Regional Haze Rule (Rule) -- Regulations published in the Federal Register on July 1, 1999
5 (64 FR 35714) that require states to establish goals for improving visibility and to develop
6 long-term strategies for reducing emissions of pollutants that cause visibility impairment.
7
8 Restoration Burning A type of prescribed burning that strives to become Maintenance
9 Burning. Many types of prescribed burning can be under the auspices of Restoration
10 Burning, but can have different objectives. An example could be burning for wildlife
11 restoration. The goal is to burn away unwanted vegetation and stimulate growth of desired
12 vegetation. This type of burning could be classified as Restoration Burning. After many
13 successful “Wildlife Burns,” these burns could be “Maintenance Burns” if performed under
14 the guidelines of Maintenance Burning. [Proposed by SK]
15
16 Silviculture - The theory and practice of controlling forest establishment, composition, and
17 growth. The art of producing and tending a forest.
18
19 Smoke Effects - The effects on visibility (both plume blight and regional haze), public
20 nuisance, and the health-based NAAQS due to emissions from fire.
21
22 Smoke Intrusion - Smoke from prescribed fire entering a designated area at unacceptable
23 levels.
24
25 Smoke Management Program (SMP) - The objectives of a basic or enhanced smoke
26 management program are to ensure: 1) no health-based NAAQS are exceeded; 2) nuisance
27 smoke is mitigated; and 3) smoke impacts on visibility are minimized in Class I areas and
28 meet the Grand Canyon Visibility Transport Commission Recommendations.
29
30 Smoke Sensitive Area –
31
32 Source - in atmospheric chemistry, the place, places, group of sites, or areas where a
33 substance is injected into the atmosphere. Can include point sources, elevated sources, area
34 sources, regional sources, multiple sources, etc.
35
36 Source – See Area/Fire/Point above.
37
38 State Implementation Plan (SIP) - a state plan approved by EPA for the establishment,
39 regulation, and enforcement of air pollution standards. (See also Tribal Implementation
40 Plan -- TIP)
41
42 Tribal Implementation Plan (TIP) -- Plans devised by tribes to carry out their
43 responsibilities under the Clean Air Act. TIPs must be approved by the U.S. Environmental
44 Protection Agency and include public review.
45
ESMP Document Draft A, 3/12/02 II - A - 35
1 Vegetative Burning - Burning of vegetation (i.e., plants or plant growth). (E.g., Burning of
2 grasslands or forestlands.)
3
4 Vegetative Residue Disposal --
5
6 Wildfire - Any unwanted, non-structural fire.
7
8 Wildfire Managed for Resource Objectives - The management of naturally ignited fires,
9 regardless of land type or ownership, to accomplish specific, pre-stated resource
10 management objectives in predefined geographic areas with or without a plan in place. This
11 term is considered to be analogous with the terms Wildland Fire Managed for Resource
12 Benefits and Prescribed Natural Fire that are used in regulations and policies regarding
13 Federal wildlands.
14
15 Wildland - An area where development is generally limited to roads, railroads, power lines,
16 and widely scattered structures. The land is not cultivated (i.e., the soil is disturbed less
17 frequently than once in 10 years), is not fallow, and is not in the USDA Conservation
18 Reserve Program (CRP). The land may be neglected altogether or managed for such
19 purposes as wood or forage production, wildlife, recreation, wetlands, or protective plant
20 cover (EPA Interim Air Quality Policy on Wildlands and Prescribed Fires). The land is not
21 “agricultural land” as operationally defined above. Silvicultural land and rangelands (per
22 the FEJF charge), woodlots, and private timberlands will be included with wildlands for the
23 purposes of the FEJF work.
24
25 Wildland Fire - All types of fire (see definition of fire above), except fire on agricultural
26 land.
27
28 Wildland Fire Managed for Resource Benefits/Prescribed Natural Fire - These terms both
29 have current use in regulations and policies. They are considered to be synonymous and are
30 used interchangeably in this work plan. These terms refer to the management of naturally
31 ignited fires to accomplish specific, pre-stated resource management objectives in
32 predefined geographic areas outlined in the fire management plan.
33
34 Wildland Fire Use - Any fire occurring on the wildlands, regardless of ignition source,
35 damages or benefits.
36
37 Western Regional Air Partnership (WRAP) - The WRAP is a collaborative effort of tribal
38 governments, state governments and Federal agencies to promote and monitor
39 implementation of Recommendations from the GCVTC. The WRAP may also address
40 other common western regional air quality issues as raised by its membership. The
41 activities of the WRAP are conducted by a network of committees and forums, composed
42 of WRAP members and stakeholders who represent a wide range of social, cultural,
43 economic, geographic and technical viewpoints. The WRAP members include the
44 governors of thirteen western states (AK, AZ,CA, CO, ID, MT, ND, NM, OR, SD, UT,
45 WA, and WY). Tribal nations selected as WRAP members to represent the 247 tribes
46 within the WRAP region include Pueblo of Acoma, Campo Band of Kumeyaay Indians,
ESMP Document Draft A, 3/12/02 II - A - 36
1 Cortina Indian Rancheria, Hopi Tribe, Hualapai Nation of the Grand Canyon, Nez Perce
2 Tribe, Northern Cheyenne Tribe, Salishand Kootenai Confederated Tribes, Pueblo of San
3 Felipe, and Shoshone-Bannock Tribes of Fort Hall. Federal WRAP members are the
4 Department of the Interior, the Department of Agriculture, and the Environmental
5 Protection Agency. The National Tribal Environmental Council and the Western
6 Governors’ Association administer the WRAP.
7
8 WRAP Region - The WRAP region is the area covering all of the 247 member tribes and
9 the 13 member states.
10
11 Yield Improvement - Burning that improves growing conditions for subsequent crops (i.e.,
12 by adding nutrients or available water to the soil) or burning that stimulates new growth.
13 (E.g., Field burning on seed production fields.)
14
15 Visibility - Plume blight and regional haze.
ESMP Document Draft A, 3/12/02 II - A - 37
1 Other Documents to Consider Appending
2
3 1) BSMP Guidance Document [streamline this to deal with SK’s “Musts” for
4 NAAQS/Nuisance plus some basic steps for RHR Viz. – or leave as is?]
5
6 2) AAQTF doc
7
8 3) EPA Interim Policy
9
10 4) Trading [EPA’s EIP reference or Bernards’ paper or both?]
11
12 5) WRAP Policy on Categorizing Fire Emissions [or just the Classification Policy
13 statements below?]
14
15 2.1. CLASSIFICATION PROGRAM MANAGEMENT
16
17 A. All fires must be managed to minimize visibility impacts.
18 B. All emissions from fires classified as an “anthropogenic” source will be
19 controlled to the maximum extent feasible subject to economic, safety, technical
20 and environmental considerations.
21 C. Emissions from all fire will be tracked.
22
23 2.2. CLASSIFICATION CRITERIA
24
25 A. Prescribed Fire is an “anthropogenic” source, except where it is utilized to
26 maintain an ecosystem that is currently in an ecologically functional and fire
27 resilient condition, which is classified as a “natural” source.
28 B. Wildfire that is suppressed by management action is a “natural” source. Wildfire,
29 when suppression is limited for safety, economic, or resource limitations, remains
30 a “natural” source. Wildfires managed for resource objectives are classified the
31 same as prescribed fires.
32 C. Native American cultural burning for traditional, religious, and ceremonial
33 purposes is a “natural” source.
34
35 More Detail on ESMP Levels from TT Work Products
36
37 Determining when multiple day burns can be carried out requires advanced
38 meteorological analysis and planning. (Multiple day emissions evaluation.) [from GZ]
39
40 Komie’s Purpose of Burn list, etc.
41
42 Emissions Reductions (Kuehn)
43
44 Special Events: Collect information within each airshed pertaining to recurring special
45 events and specifically planned events, e.g. annual marathon races, community parades
46 and special events, county fairs, opening hunting season, state holidays, etc. Whether or
ESMP Document Draft A, 3/12/02 II - A - 38
1 not there was a concern during the actual burn would depend on a number of factors such
2 as: weather, public acceptance, public education efforts, news releases, etc. Information
3 should be collected for display in a GIS (Lat/Long, UTM) for rapid lookup. (GZ)
4
5 Smoke Management Program Examples
6
7 In an ESMP, annual fire reporting would go into more detail to include information on
8 Wildfire, Prescribed (including agriculture burning) and Fire Use Fires, Ceremonial fire
9 use, etc.
10
11 Inform coordination center of anticipated burns for the year including the earliest ignition
12 date. This would initiate the burn sequencing process. This is the pre-season burn list.
13
14 Develop enhanced smoke notification lists for various pre-established climatologically
15 airflow patterns scenarios. [sic] Draw upon lists for preburn notification and advanced
16 warning should wind directions aloft change to outside of the forecast.
17
18 Address Smoke Dispersion Evaluation – who does it, for what purpose – include RHR –
19 our philosophy about it. Modeling, Monitoring? Ensure that this is included in BSMP –
20 see GZ’s paper
21
22 Require regional approval and real-time tracking of burns. With the regional tracking
23 concept, the regional coordination center should coordinate multiple burns across the
24 western region and multi-states to avoid multiple-layering impacts on airsheds and across
25 state boundaries. This would permit for informed last minute decisions so that airshed
26 optimization can occur.
27
28 Utilize gamed smoke flow paths from the Modeling Section to determine the level of
29 notifications required.
30
31 Technical Tools:
32
33 Modeling
34 -Regulatory Authority use information derived from the Modeling and Interpretation
35 Section. Game anticipated airflow patterns based on climatological data, utilizing
36 advanced modeling techniques for determining smoke dispersion.
37 -Regulatory Authority model/game the year’s set of planned burns using the latest
38 multiple burn assessment tool. This would allow for optimizing annual airsheds and
39 reduce multi-layering of transport smoke paths.
40 -Question: Will Burner need to do Modeling and if so, what? When?
41 Specific models, types of models, and the complexity and refinement of modeling
42 inputs will vary with the objective of smoke impact analyses. Less refined total
43 emission analyses may be used for less complex projects. More complex projects
44 may utilize qualitative meteorological analyses; while, even more complex projects
45 will require quantitative dispersion modeling. Once dispersion modeling is triggered,
46 appropriate modeling may range from simplistic Gaussian (Define) to complex
ESMP Document Draft A, 3/12/02 II - A - 39
1 photochemical models. The criteria for assessing the complexity of projects should
2 include an analysis of emissions, terrain, meteorology, severity of air quality
3 problems, proximate to population, and governmental regulations. The selection of
4 models will consider all local, state, and federal requirements. Spatial and
5 jurisdictional coverage of potential impacts will also be considered. Models may be
6 applied to both regional and local planning scales. (Ahuja, et al)
7
8 Monitoring
9
10 -Use of real-time PM monitoring equipment in smoke sensitive areas and for visibility
11 concerns. Preferred use of 2.5 µm monitors. Establish thresholds for mandatory and
12 recommended use of monitors. Use to educate public in PM levels and for public and
13 media notification triggers. Use as a tool to sensitize the public to various PM levels.
14 Post the information on the smoke home page and in local media sources. Utilize such
15 models as WinHaze* (PM level comparison tool) to build public awareness of PM levels.
16 *Include in Software appendix?
17 -Access real-time high-resolution satellite data for verifying and tracking smoke. Use
18 this data to better improve regional scheduling of burns in future
19
20 On-Site Meteorology
21
22 -Utilize pilot balloons near sensitive receptors prior to ignition to check for proper
23 transport winds. This would ensure that transport winds were as predicted and that
24 appropriate downwind receptors were notified accordingly.
25 -Utilize portable weather stations in areas with known unusual wind patterns. Familiarize
26 meteorologist if needed with a site visit prior to burning. In extremely difficult areas
27 utilize IMET on site during the burn.
28
29 Technical Tools
30
31 Climatology/Meteorology
32 -Climatological analysis is needed to determine when multiple day projects can be carried
33 out.
34 -Conduct analysis of regional airflow patterns so that statistically safe opportunities for
35 burning throughout the year can be taken advantage of, spreading the smoke over a
36 broader time period.
37 -Use meteorological data for gaming smoke situations and scheduling multi-day projects.
38
39 Software List
40
41 Other Appendices to address details of aspects of ESMP that need further clarification
42 e.g., Level 4 Regional Coordination, A/N, etc.
ESMP Document Draft A, 3/12/02 II - A - 40
ESMPTT Co-Chairs Conference Call
March 22, 2002
Chronological Record II - 155
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Chronological Record II - 156
ESMPTT Co-Chairs Conference Call
March 22, 2002
Participants: Ann Acheson, USDA FS, ESMPTT Co-Chair; Mike Ziolko, ODF,
ESMPTT Co-Chair; Pete Lahm, USDA FS, FEJF Chair; Rebecca Reynolds, Rebecca
Reynolds Consulting, ESMPTT Facilitator.
Conference Call Record
I. IOC Briefing on ESMP
On March 21, 2002 Pete Lahm briefed the IOC on ESMPTT progress to date. The
biggest question was on the TT’s interpretation of the RHR’s “mandatory” seven ESMP
elements (see RHR , p. 35771). The IOC wanted to get EPA’s input as to this issue. Pete
agreed to consult the Office of Air Quality Planning & Standards (OAQPS) to see if he
could get their read. This will be initiated through John Kennedy, EPA representative to
the FEJF. A key issue to this for the IOC was flexibility in how states/tribes apply the
ESMP elements across jurisdiction and source type, regardless of whether or not they are
mandatory.
Other IOC comments/questions included:
1) Perhaps use level of emissions to trigger how stringent the measures used in
each of the seven elements are. Develop low and high bar for each? Or
minimums?
2) How does Mandatory/Voluntary fit in, i.e., do the seven mandatory elements
preclude a voluntary program?
3) Agreed that a state’s/tribe’s ability to implement an ESMP was key to that
state’s/tribe’s decision to go 309, although there was some concern over this
due to legislative barriers.
4) Emissions tracking may not be possible now (due to legislative barriers) for
some states – will there be graduated steps for this as well? Pete responded
yes: estimations would come first, then graduated – similar to the approach
taken by NBTT.
Finally, the IOC positively received the Annual Emission Goals concept. See the attached
briefing below.
II. Revised ESMP TT Schedule
July/Aug Document ESMP Development Process
Mid-July WRAP Meeting: Final Approval of ESMP
July 1st ESMP Final to WRAP
June IOC/TOC Approval
Chronological Record II - 157
May 14-16 FEJF Mtg.: ESMP Review/Approval (Location TBD)
May 7th ESMP Document to FEJF
May Circulate ESMP Document to Outreach List for Comment
(ESMPTT will develop a list representative of the stakeholder
groups, and solicit comment from each)
April 29 Special ESMPTT Conference Call: Finalize Document (Tentative)
April 12 Revised ESMP Document to ESMPTT
April 4-5 ESMP Drafting Team Mtg. in Denver: Review & Modify Changes
to Document from Phoenix Mtg.
III. Facilitator Budget
Due to several additional Task Team and drafting meetings, as well as the facilitator’s
time being used for writing, the original amount contracted will not cover the remaining
needs of the ESMPTT. Pete will pursue options with the WGA to address this.
IV. ESMPTT Outreach
The WRAP Communications Committee had outlined a plan for garnering input on the
ESMP that included public meetings in all the WRAP states to be held during the months
of April and May. Due to the TT’s current progress, it was decided that the outreach
strategy would be a more directed one. Public meetings will not be held, instead, the TT
will develop a list of stakeholder representatives who will be asked to be reviewers of the
ESMP document. The stakeholders would be assembled from participants in the Natural
Background/Categorizing Fire Emissions meetings and other interested parties as
determined by the FEJF and ESMP TT. Formal comment will be received from these
stakeholders, and officially recorded. This comment will be integrated into the final draft
of the ESMP and addressed by the FEJF. This approach to outreach on ESMP was
approved by the IOC.
Chronological Record II - 158
ESMP Task Team Meetings
Denver, Colorado: April 4 & 5, 2002
Writing Sub-Group Meeting
Chronological Record II - 159
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Chronological Record II - 160
1 ESMP TT Meeting
2 Writing Sub-Group Meeting
3 Denver, Colorado
4 April 4 & 5, 2002
5
6 Attendees: Bob Palzer (Sierra Club), Dave Randall (Air Sciences, Inc.), Ann Acheson
7 (ESMPTT Co-Chair), Pete Lahm (FEJF Chair), Mike Ziolko (ESMPTT Co-Chair) -- via
8 phone, Rebecca Reynolds (ESMPTT Facilitator)
9
10 Meeting Purpose: To review the ESMP Draft and make revisions based on the ESMPTT
11 meeting in Phoenix.
12
13 Handouts
14 ESMP Document Draft 4/2/02
15
16
17
18 Recommendations for the Establishment of
19 Enhanced Smoke Management Programs
20 (ESMP)
21
22 DRAFT: 4/02/02
23
24
25
26
27
28
29
30
31
32
33
34
35 Prepared by the Enhanced Smoke Management Task Team for the Fire
36 Emissions Joint Forum
ESMP Document Draft B, 4/2/02 II - B - 1
1 Recommendations for the Establishment of
2 Enhanced Smoke Management Programs
3 (ESMP)
4 DRAFT: 4/02/02
5
6 CONTENTS
7
8
9 I. Executive Summary page i - ?
10
11 II. Introduction page 3
12
13 Background
14 Context
15 Current SMPs
16 Regional Haze Rule: ESMP
17 ESMP & NAAQS
18 Purpose
19 Scope/Applicability
20 308/309
21 Fire Source Type
22 Class I Areas
23
24 III. Elements of an ESMP for States/Tribes in the WRAP Region page 12
25
26 Elements [Note: Maybe it takes too long to get to this – move up?]
27 Rationale
28 Implementation (order of these?)
29 ESMP Considerations (Off-Ramps)
30 Emissions Tracking
31 Implementation Options (Criteria)
32 Legislative Barriers
33 Regulatory Authority’s Responsibility
34 Timeline
35
36 IV. ESMP Elements: Guidance & Options page 20
37 Elements 1-9
38
39 V. Appendices page 24
40
41 Glossary
42 BSMP Guidance doc, AAQTF doc, EPA’s Interim Policy, NBTT Policy
43 Additional ESMP Information -- e.g., Trading Option
ESMP Document Draft B, 4/2/02 II - B - 2
1 Recommendations for the Establishment of
2 Enhanced Smoke Management Programs
3 (ESMP)
4 DRAFT: 4/02/02
5
6 Key: Yellow highlight = Comments/questions
7 Pink highlight = need to research
8 Green highlight = new concepts from Phoenix that need to be incorporated
9 Blue highlight = old copy in question; glossary questions
10
11
12 I. Introduction
13
14 Background
15 In 1990, Congress amended the Clean Air Act, and as part of these amendments created
16 the Grand Canyon Visibility Transport Commission1 (GCVTC). The GCVTC was
17 charged with assessing the current scientific information on visibility impacts and making
18 recommendations for addressing regional haze in the western United States. The GCVTC
19 signed and submitted more than 70 Recommendations to the Environmental Protection
20 Agency (EPA) in a report dated June 1996 that indicated that visibility impairment was
21 caused by a wide variety of sources and pollutants, and that a comprehensive strategy
22 was needed to remedy regional haze [cite?].
23
24 Fire sources were among those specifically acknowledged as contributors to visibility
25 impairment, and the GCVTC Recommendations recognized the likelihood that the use of
26 fire would need to increase to address the current fuels crisis on the country’s wildlands.
27 Although the GCVTC Recommendations do not require a reduction of total fire
28 emissions as a demonstration of reasonable progress toward the National Visibility Goal,
29 several of the Recommendations cited the need for minimizing the visibility impacts from
30 such increases in order to achieve reasonable progress. One of these Recommendations
31 called for the implementation of smoke management programs to minimize effects of all
32 fire activities on visibility.2
33
34 The Western Regional Air Partnership (WRAP) was established in 1997 as the successor
35 organization to the GCVTC. The WRAP is a voluntary organization comprised of
36 western governors, tribal leaders and Federal agencies,3 and is charged with
1
The GCVTC was composed of the governors of eight western states (AZ, CA, CO, NM, NV, OR, UT,
WY), four tribes (Acoma Pueblo, Hopi, Hualapai, and Navajo), four Federal land management agencies
(Bureau of Land Management, U.S. Fish and Wildlife Service, U.S. Forest Service, National Park Service),
the Columbia River Inter-Tribal Fish Commission, and the Environmental Protection Agency.
2
RHR, IV, A, p. 35748
3
The WRAP members include the governors of thirteen western states (AK, AZ, CA, CO, ID, MT, ND,
NM, OR, SD, UT, WA, and WY). Tribal nations selected as WRAP members to represent the 247 tribes
within the WRAP region include Pueblo of Acoma, Campo Band of Kumeyaay Indians, Cortina Indian
Rancheria, Hopi Tribe, Hualapai Nation of the Grand Canyon, Nez Perce Tribe, Northern Cheyenne Tribe,
ESMP Document Draft B, 4/2/02 II - B - 3
1 implementing the GCVTC Recommendations, as well as addressing broader air quality
2 issues, such as the Regional Haze Rule (Rule). The WRAP is designed as a stakeholder-
3 based organization, which uses consensus for development of policy and technical tools
4 to assist states and tribes in the WRAP region4. WRAP participants include state air
5 quality agencies, tribes, Federal/state/private land managers, the EPA, environmental
6 groups, industry, academia and other interested parties.
7
8 Following the issuance of the GCVTC Recommendations, the EPA issued the Regional
9 Haze Rule (Rule)5 in July 1999 to improve visibility in 156 national parks and wilderness
10 areas across the country. The Rule outlines the requirements for states and tribes to
11 address regional haze in Federal Class I areas. EPA incorporated all of the GCVTC
12 Recommendations into Section 309 of the Rule, which may be used by some of the
13 WRAP states. The remaining WRAP states must utilize the nationally applicable Section
14 308 provisions of the Rule.
15
16 Progress toward the national [visibility] goal will require regional programs that
17 operate over large geographic areas and limit emissions of pollutants that can
18 cause regional haze.6
19
20 EPA recognizes the WRAP as the Regional Planning Organization that is developing the
21 necessary policy and technical tools to implement the Regional Haze Rule in the WRAP
22 region.
23
24 Context
25
26 Current Smoke Management Programs
27 Most current smoke management programs to date in the WRAP region have been
28 developed to address public health and nuisance concerns. Generally, they do not
29 address all the potential visibility-impacting fire sources (prescribed fire on wildlands,
30 wildland fire use, wildfire and agricultural burning), nor do they have procedures to
Salish and Kootenai Confederated Tribes, Pueblo of San Felipe, and Shoshone-Bannock Tribes of Fort
Hall. Federal WRAP members are the Department of the Interior, the Department of Agriculture, and the
Environmental Protection Agency.
4
The WRAP recognizes the unique legal status and jurisdiction of tribes and seeks to promote policies that
ensure fair and equitable treatment of all participating members of the WRAP. The Partnership also
recognizes the states' and tribe's authority and responsibility to develop, adopt and implement their
individual state and tribal implementation plans. Further, the Partnership recognizes the discretion of the
U.S. Environmental Protection Agency and its responsibility to develop national regulatory initiatives, and
review State and Tribal implementation plans through public rulemaking procedures. In addition, the
Partnership recognizes the affirmative responsibility of the federal land managing agencies under the Clean
Air Act to protect the air quality related values, including visibility of Class I areas and to manage all the
areas under their respective jurisdictions for the public purposes set forth in their governing statutory
authorities. The WRAP has no regulatory authority and recognizes that all legal authority is reserved by its
members in accordance with existing law. The Partnership also recognizes the United States' trust
responsibility as carried out by the federal agencies to protect tribal resources from degradation. –Excerpted
from the WRAP Charter, cite website.
5
Published in the Federal Register on July 1, 1999 (64 FR 35714).
6
RHR, II, D, 2. p. 35718
ESMP Document Draft B, 4/2/02 II - B - 4
1 specifically address minimization of visibility impacts. The EPA’s Interim Air Quality
2 Policy on Wildland and Prescribed Fires7 (Interim Policy) and the Agricultural Air
3 Quality Task Force’s Air Quality Policy on Agricultural Burning8 (AAQTF) were
4 developed to guide states/tribes in addressing, primarily, public health (NAAQS) impacts
5 of smoke as well as to help guide land managers in reduction of impacts from burning
6 operations.
7
8 In its Interim Policy on smoke management programs, the EPA lists seven basic
9 components that it requires for a smoke management program to be certifiable9,
10 including: A) Authorization to Burn, B) Minimizing Air Pollution Emissions, C) Smoke
11 Management Components of a Burn Plan, D) Public Education and Awareness, E)
12 Surveillance and Enforcement, F) Program Evaluation and G) Optional Air Quality
13 Protection.10
14
15 The AAQTF sets up a two-tiered voluntary program, in which the first tier is based on a
16 predetermined set of burn conditions. The second tier is designed for areas where
17 agricultural burning would be expected to contribute to NAAQS violations or to visibility
18 impairment in mandatory Federal Class I areas. In this second tier, many of the same
19 elements as the EPA requires in its Interim Policy are involved, including burn
20 authorization, air quality monitoring, emissions reductions techniques, public
21 notification, and enforcement requirements.11
22
23 An integral part of the existing EPA policy on smoke management programs is the clear
24 guidance to consider the visibility effects of burning when planning burning operations,
25 and to consider alternatives to burning as well as the of use of other emission reduction
26 practices. However, the policy does not provide specific mechanisms for the development
27 of a smoke management program that addresses regional haze. EPA’s Interim Policy
28 states:
29 After the regional haze rules become final, states[tribes] will need to address the
30 impacts of fires and other contributing sources on meeting reasonable progress in
31 their control strategy analyses, as well as during periodic progress assessments.
32 The EPA will revisit this section of the Air Quality Policy on Wildland and
33 Prescribed Fires after the final rules for implementing the regional haze program
34 have been promulgated.12
35
36 To date, the EPA has not revisited the Interim Policy to integrate regional haze
37 considerations outlined in the Rule.
38
39 The AAQTF, in its Policy published after the EPA’s Interim Policy, addresses regional
40 haze as follows:
7
EPA Interim Air Quality Policy on Wildland and Prescribed Fires cite
8
AAQTF Air Quality Policy on Agricultural Burning cite
9
EPA Interim Policy: A state/tribe certifies “to EPA that they have adopted and are implementing a SMP
that includes the [seven] basic components identified in this policy.” P. 7 IV.
10
EPA Interim Policy cite, pp. 17-23.
11
AAQTF, p.2
12
EPA’s Interim Policy, p. 31
ESMP Document Draft B, 4/2/02 II - B - 5
1
2 [The Regional Haze Rule] establishes a program to facilitate the integration of
3 emission management strategies for regional haze with SIP[TIP] components that
4 address emissions of NOx, SO2, VOCs and PM2.5. The Rule strongly encourages
5 multi-state planning efforts to address the haze issue and Air Quality Agencies are
6 moving forward with this effort.13
7
8 The Regional Haze Rule: Enhanced Smoke Management Program
9
10 The GCVTC Recommendations call for “the development and implementation of criteria
11 and requirements for the use of enhanced smoke management programs (including
12 alternative management practices).”14 The Regional Haze Rule refers to smoke
13 management programs as a means to protect public health, prevent NAAQS violations,
14 mitigate nuisance smoke, as well as address visibility impacts in Class I areas, and in
15 Section 309, specifically calls for “enhanced smoke management programs for fire that
16 consider visibility effects, not only health and nuisance objectives.”15
17
18 ESMPs and NAAQS/Nuisance
19
20 Visibility impacts are to be mitigated through smoke management programs that also
21 address public health (NAAQS) and nuisance smoke. States/tribes are currently
22 addressing NAAQS and/or nuisance to the extent they deem appropriate through existing
23 smoke management efforts or programs, using the available EPA guidance to address
24 their specific situations. As a consequence, there is considerable variety among current
25 smoke management efforts of the states and tribes in the WRAP region.16
26
27 Nevertheless, the enhanced smoke management program adds visibility/regional haze
28 considerations to existing smoke management efforts for NAAQS and nuisance.
29 Although the ESMP is based on the assumption that the respective state/tribe has
30 addressed their public health and nuisance concerns associated with smoke in their
31 current smoke management efforts, the ESMP approach is structured to integrate
32 visibility protection with NAAQS and nuisance protection, in accordance with the Rule:
33
13
AAQTF, Section E, p. 10
14
GCVTC Recommendation #4, p.49
15
RHR, p. 35771 (6) (iii)
16
Very few states/tribes have smoke management programs that address all fire sources in one unified
program. As a result some fire sources may have little or no regulation while other fire sources in the same
area may have a stringent centralized authority deciding which burns may be conducted and when. Based
on the FEJF Reports [cite], prescribed fire on public wildlands is the most regulated fire source sector, with
smoke management programs run by a centralized burn authority existent in a majority of WRAP states
(AZ, CA, OR, WA, ID, MT, UT). Only three states (CA, OR, WA) in the WRAP Region actively regulate
and track agricultural fire sources, and smoke management programs for private rangeland burning are less
common than agricultural smoke management programs.
ESMP Document Draft B, 4/2/02 II - B - 6
1 The regional haze program is being promulgated in a manner that facilitates
2 integration of emission management strategies for regional haze with the
3 implementation of programs for new NAAQS for ozone and PM.17
4
5 This document outlines a framework for states/tribes to add visibility considerations to
6 existing smoke management programs and, where no smoke management programs exist,
7 to establish new programs to address visibility concerns. ESMP does not erode
8 states/tribes’ current smoke management efforts, but rather, assumes that states/tribes will
9 maintain their current smoke management efforts and/or smoke management programs
10 for NAAQS/nuisance. Since air quality problems have common precursor pollutants,
11 what a state/tribe is doing to address NAAQS may be sufficient to meet reasonable
12 progress goals.18
13
14 If there are currently no state/tribe smoke management efforts, ESMP will still apply, as
15 per the Regional Haze Rule requirements. While ESMP provides a framework for
16 visibility/regional haze, states/tribes may choose to do more to protect NAAQS, prevent
17 nuisance and/or address visibility, and may use the ESMP to do so.
18
19 Purpose
20 The purpose of this document is to outline for states/tribes in the WRAP region a
21 comprehensive approach to managing smoke emissions from all types of fire in the
22 interest of protecting visibility and regional haze in Class I areas, as required by the
23 Regional Haze Rule.
24
25 The ESMP addresses direct visibility impacts and regional haze in mandatory Federal
26 Class I areas so as to improve visibility on the worst days and maintain visibility on clean
27 days. Worst days are defined by the Rule as those days that fall in the lowest 20th
28 percentile for visibility measurements from IMPROVE monitoring, and the best days are
29 those days that are in the highest 20th percentile on an annual basis [cite?].
30
31 In keeping with EPA policy and the Rule, these recommendations are the result of
32 WRAP region-wide multi-state planning and coordination efforts focused on addressing
33 the development of smoke management programs that address visibility and regional
34 haze.
35
36 …progress toward the national [visibility] goal will require regional programs that
37 operate over large geographic areas and limit emissions of pollutants that can
38 cause regional haze…19
39
40 This document has been developed to assist WRAP states/tribes meet the requirements of
41 the Regional Haze Rule, and is based on principles of equity, predictability, and
42 feasibility. This document considers the existing policy on smoke management programs
17
RHR, section ?, p. 35719, emphasis added.
18
RHR, II, E., p.35721
19
RHR, Section D, 2, p. 35718
ESMP Document Draft B, 4/2/02 II - B - 7
1 provided by EPA for both wildland and agricultural burning. The ESMP approach goes
2 beyond the existing policy in addressing visibility effects and regional haze, as required
3 by the Rule.
4
5 States and tribes in the WRAP region are anticipated to incorporate the ESMP
6 recommendations into the SIP/TIP submitted to EPA in order to meet the requirements of
7 the Rule. This document outlines elements specific to the ESMP that, if incorporated into
8 the SIP/TIP as enforceable measures, will be approvable by EPA. At the same time, this
9 document recognizes the differences among WRAP states/tribes with regard to air quality
10 issues, emissions information, fire source sectors, and state legislative or tribal
11 governmental barriers, and provides implementation options and guidance to assist
12 states/tribes is developing an ESMP appropriate to the situation. As the SIPs/TIPs will be
13 revisited and revised, per the schedule specified in the Rule, there will be opportunities to
14 refine the ESMP to reflect scientific advances and policy changes. [Do we still need
15 this?]
16
17 Should the requirements of the Rule not be met by states/tribes, EPA could disapprove
18 the SIP/TIP or intervene with a FIP. The purpose of this document is to assist states/tribes
19 to address visibility impacts associated with fire in away that is adequate for SIP/TIP
20 implementation, and that should minimize the possibility of EPA intervention in the
21 regional haze process with regard to fire sources.
22
23 Scope/Applicability
24
25 Equal Application of ESMP for Sections 308 and 309
26
27 States/tribes complying with either Section 308 or 309 of the Regional Haze Rule will
28 need a program to develop and track reasonable progress toward the natural visibility
29 goal, calculate baseline and natural visibility conditions, develop a long-term strategy for
30 management of emissions, establish a monitoring strategy, prepare periodic reports
31 demonstrating progress, and develop or update SIPs/TIPs. Further, emissions from all
32 fire (wildland and agricultural) are to be accounted for in both Sections 308 and 309 of
33 the Rule [cite?]. ergo: states must deal w/ these things in their sips – Pete is this true?
34
35 Although the ESMP is specifically referred to only in Section 309 of the Rule, the ESMP
36 is a viable tool that states/tribes under section 308 may want to implement to meet the
37 requirements of the Rule. Section 308 of the Rule states:
38
39 (v) The state must consider, at a minimum, the following factors in developing its
40 long-term strategy [for regional haze]:
41 (E) Smoke management techniques for agricultural and forestry management
42 purposes including plans as currently exist within the states for these purposes.20
43
20
RHR, p. 35767, 308 (d) (3) (v) (E)
ESMP Document Draft B, 4/2/02 II - B - 8
1 And:
2 The State must identify all anthropogenic sources of visibility impairment
3 considered by the State in developing its long-term strategy [for regional haze].
4 The State should consider major and minor stationary sources, mobile sources,
5 and area sources.21
6
7 Therefore, under section 308, if the state/tribe’s analytical process shows that
8 anthropogenic sources of fire contribute to visibility impairment in a Class I area, then
9 the Rule requires smoke management techniques for agricultural and forestry lands.
10 Smoke management techniques that address visibility are, by this document’s definition,
11 ESMPs, and therefore the ESMP template described here can be applied to meet these
12 purposes for Section 308 as well as Section 309.
13
14 Section 118(a) of the Clean Air Act requires that all entities, federal and non-federal, be
15 subject to the same requirements, authorities and processes, and the Rule is clear that all
16 sources, facilities, and property are to be treated equitably [cite]. Additionally,
17 stakeholder input garnered in the development process of the WRAP Policy on
18 Categorization of Fire Emissions supported consistent consideration of fire between
19 Sections 308 and 309 of the Rule. The ESMP, therefore, will be applicable and useful to
20 all states and tribes in the WRAP region.
21
22 It is anticipated that the establishment of enhanced smoke management programs will be
23 incorporated into the State or Tribal Implementation Plans (SIP/TIP) submitted to EPA in
24 order to meet the requirements of the Rule. States complying with Section 309 of the
25 Regional Haze Rule will need [be required] to have a Regional Haze SIP submitted by
26 December 31, 2003, with implementation of cited control measures, including the
27 implementation of an enhanced smoke management program, by the following year.
28 States/tribes complying with Section 308 must have incorporated Regional Haze
29 requirements into their SIPs/TIPs within 12 months of designation as PM2.5 attainment, or
30 within three years after designation as PM2.5 non-attainment, but no later than December
31 31, 2008.
32
33 Fire Source Type
34 Most states/tribes address fire source sectors differently, as does EPA in its guidance
35 documents. Consequently, fire sources in the WRAP region are currently regulated at
36 various and inconsistent levels, from rigorous regulation to regulation with exemption
37 applied, to no regulation. This variability makes more important the need for the
38 development of a consistent and universal ESMP for the WRAP region.
39
40 The elements of the ESMP are considered to be effective to address visibility impacts
41 associated with emissions from fire regardless of land type (wildland, agricultural land,
42 rangeland) ownership (i.e., Federal, state, tribal, public, private), cause of ignition (e.g.,
43 lightening, arson, accidental human, land management practices), or purpose of the fire
44 (e.g., vegetative residue disposal, hazard reduction, maintain ecosystem health). It will be
21
RHR, p. 35767, (iv)
ESMP Document Draft B, 4/2/02 II - B - 9
1 a responsibility of states/tribes [or: It will be the discretion of states/tribes] to determine
2 the level of implementation of the ESMP to adequately address fire sources in their
3 regional haze SIP/TIP.
4
5 This document has been developed in light of existing WRAP policy and guidance, and,
6 in particular, integrates the WRAP Policy on Categorizing Fire Emissions22 into its
7 approach and definitions.
8
9 The WRAP Policy on Categorizing Fire Emissions states the following:
10
11 A. All fires must be managed to minimize visibility impacts.
12 B. All emissions from fire classified as an “anthropogenic” source will be
13 controlled to the maximum extent feasible, subject to economic, safety, technical
14 and environmental considerations.
15 C. Emissions from all fires will be tracked.23
16
17 The fire emissions classifications of “natural” and “anthropogenic”24 amplify the fire
18 source sectors to which the Rule states that the ESMP applies25, so as to account for
19 natural background condition values. For example, those fire sources that are classified as
20 “natural” (e.g., wildfire and prescribed fire for ecosystem maintenance) will be managed
21 so as to minimize visibility impacts, whereas those fire sources that are classified as
22 “anthropogenic” (all other prescribed fire) will require varying degrees of control based
23 on the Natural Background Policy’s feasibility criteria.26 This will facilitate the
24 demonstration of reasonable progress in SIPs/TIPs that takes into account natural
25 background condition values, as outlined in the Rule. [HELP]
26
27 The EPA also recognizes that fire of all kinds (wildfire, prescribed fire, etc.)
28 contributes to regional haze, and that there is a complex relationship between
29 what is considered a natural source of fire versus a human-caused source of fire.27
30
31 The smoke management plans [that consider visibility effects] must address all
32 sources of fire used for land management purposes.28
33
34 In light of this, states/tribes are strongly encouraged to utilize, wherever possible, smoke
35 management and control practices as standard operating procedure and best management
36 practice. This is not to imply that all states/tribes will do this in the same way, or to the
22
WRAP Policy on Categorizing Fire Emissions (cite website?)
23
WRAP Policy on Categorizing Fire Emissions, Section 2.1., p. 8, see also definitions of both in the
Glossary Appendix.
24
For more information about fire source classification, see the WRAP Policy on Categorizing Fire
Emissions. [cite website?]
25
“Documentation that all Federal, State, and private prescribed fire programs within the State evaluate and
address the degree of visibility impairment from smoke in their planning and application.” RHR, p. 35771
(6) (i)
26
WRAP Policy for Categorizing Fire Emissions, Section 3.1.2., p.11
27
64 FR 35735.
28
RHR, IV, C, 6, p. 35753
ESMP Document Draft B, 4/2/02 II - B - 10
1 same degree; to do so would ignore the wide variety of circumstances among
2 geographical areas and source sectors within the WRAP region.
3
4 This document does not apply to other open burning activities on residential, commercial,
5 or industrial property (e.g., backyard burning, garbage incineration, residential wood
6 combustion, construction debris). Nor does it apply to Native American cultural non-
7 vegetative burning for traditional, religious or ceremonial purposes (e.g., cremation,
8 sweat lodge fires).29
9
10 Class I Areas
11
12 These recommendations apply to impacts on mandatory Federal Class I areas in the
13 WRAP region. Each state/tribe has an obligation to account for the emissions in its own
14 Class I areas, as well as for those emissions it produces that have impacts outside its
15 jurisdiction. This approach to the ESMP provides the methodology for this to occur.
16
17 Section 309 of the Rule specifies that the Class I areas of the Colorado Plateau be
18 addressed in the 2003 SIP submittal, and all Class I areas that were not included initially
19 by states opting for the 309 pathway will be included by the 2008 SIP deadline. For
20 WRAP states not opting for Section 309, Section 308 stipulates all Class I areas be
21 addressed in a SIP submittal tied to the PM2.5 designation (2005 – 08).
29
WRAP Policy on Categorizing Fire Emissions, Section 1.4., p. 7
ESMP Document Draft B, 4/2/02 II - B - 11
1
2 Enhanced Smoke Management Program Elements
3
4 Elements of an Enhanced Smoke Management Program for Visibility/Regional
5 Haze in the WRAP Region
6
7 1) Actions to Minimize Emissions from Fire
8 2) Evaluation of Smoke Dispersion
9 3) Alternatives to Fire
10 4) Public Notification of Burning
11 5) Air Quality Monitoring
12 6) Surveillance and Enforcement
13 7) Smoke Management Program Enforcement
14 8) Burn Authorization
15 9) Regional Coordination
16
17 Rationale – I just started this section – am too pooped to any better right now, but you
18 get the gist. There is a lot more that comes from the Phoenix Notes.
19
20 The first seven elements come directly from section 309 of the Regional Haze Rule that
21 states:
22
23 Documentation that all Federal, State, and private prescribed fire programs within
24 the State [/Tribe] evaluate and address the degree [of] visibility impairment from
25 smoke in their planning and application. In addition the plan must include smoke
26 management programs that include all necessary components including, but not
27 limited to, actions to minimize emissions, evaluation of smoke dispersion,
28 alternatives to fire, public notification, air quality monitoring, surveillance and
29 enforcement, and program evaluation.30
30
31 These categories of smoke management efforts are also found in EPA’s Interim Policy
32 and the AAQTF Recommendations.
33
34 The Burn Authorization element is also found in the EPA’s Interim Policy as one of the
35 seven basic components of a smoke management program, and is included in the AAQTF
36 policy on agricultural burning as well. Burn authorization is key to managing smoke
37 effects, and to minimizing emissions in Class I areas.
38
39 Explain the possible consequences of not having an enforceable burn authority: e.g.
40 everyone burns at one time, cumulative effects contributes to regional haze, which
41 could result in SIP non-approval/disapproval. This burn authority would apply to all fire
42 EXCEPT wildfire. Example: Agricultural Burn Manager (from the AAQTF – cite), etc.
43
44 The Regional Coordination element is necessary to address transport issues, and is cited
45 repeatedly in the Rule as key to reaching the National Visibility Goal.
30
RHR, p. 35771, 6 i (emphasis added)
ESMP Document Draft B, 4/2/02 II - B - 12
1
2 Progress toward the national [visibility] goal will require regional programs that
3 operate over large geographic areas and limit emissions of pollutants that can
4 cause regional haze.31
5
6 And:
7
8 In developing each reasonable progress goal, the state [/tribe] must consult with
9 those states [/tribes], which may reasonably be anticipated to cause or contribute
10 to visibility impairment in the mandatory Class I Federal area.32
11
12 9) Coordination (ESMPTT)
13 Multi-state coordination mandated by RHR for the Visibility SIP. (Cite)
14 Note that there will be conflicts between smoke management efforts for
15 visibility/regional haze and for public health (NAAQS). This is the reality.
16 Explain that if state/tribe does not make this possible, regional haze (i.e., transport)
17 cannot be addressed, again leading to a possible (likely) SIP problem.
18
19 Advise states/tribes to coordinate with other state/tribes to address all visibility impacts in
20 Class I areas, from all sources and sectors. (Fire as one source sector including state, fed,
21 private lands). Explain that this coordination can be accomplished in a number of ways
22 depending on the state/tribe’s individual needs/circumstances, e.g., website,
23 Idaho/Montana Burn Authority, NIFC-type regional level burn authority.
24
25 Add sentence to remind about significant sources beyond 100K for impacts. Remember
26 “within/near” concept from GCVTC.
27
28 Implementation
29
30 The approach to the ESMP as outlined here provides an equitable and practical method
31 for states/tribes to manage smoke emissions for visibility. The approach takes into
32 account the current differences among states/tribes in the WRAP region as to source
33 sector burning practices, air quality issues and current smoke management efforts. This
34 ESMP framework provides for the systematic development of smoke management
35 programs across the WRAP region that address visibility impairment in Class I areas and
36 are compatible with current smoke management efforts for NAAQS and nuisance.
37
38 States/tribes may select different levels of implementation of the ESMP elements to apply
39 to its different fire source sectors and/or geographical areas.33 This promotes economic
40 efficiency by preventing over-regulation of a fire source that is not a contributor to
41 visibility impairment and regional haze. The approach also assists those states/tribes
42 currently without smoke management programs and the related infrastructure to feasibly
43 begin addressing smoke management for visibility. At the same time, these ESMP
31
RHR, II, D, 2. p. 35718
32
RHR, Section 51.308 (d), (1), (B), (iv), p. 35766
33
See Section IV of this document for specific guidance/options on this.
ESMP Document Draft B, 4/2/02 II - B - 13
1 recommendations will enable those states/tribes with more advanced programs to
2 expeditiously address their visibility concerns.
3
4 The Policy for Categorizing Fire Emissions creates the concept of management and
5 control of fire emissions wherever possible, subject to economic, safety, technical and
6 environmental considerations. Those considerations will vary from state to state, fire
7 source sector to fire source sector, resulting in the potential patchwork of ESMPs across
8 the WRAP region. In recognition of this, the ESMP recommendations allow an approach
9 that is sensitive to the difference among the states/tribes and so can be utilized to develop
10 ESMPs that address these specific circumstances.
11
12 ESMP Considerations this section needs to be written
13 Considerations: (all off-ramps,) pg. 35771 (6.iv)
14 Efficiency
15 Economics
16 Law
17 Land management objectives
18 Etc.
19 Emission reduction opportunities
20 Reduction of visibility impacts -- if reduction of visibility impact won’t be
21 accomplished, don’t do what won’t work
22 ESMPTT Needs to Explain: if you have barriers ($, law, etc) then you may not be able to
23 implement ESMP in the 309 SIP timeframe & therefore may not be able to go 309 – must
24 go 308. If you want to change those barriers to enable ESMP, then there is no problem
25 going 309.
26
27 Emissions Tracking this section needs editing
28
29 [Tie to Annual Emissions Goal for 309 reasonable progress demonstration thru
30 2018??]
31
32 RHR, Sect 309 pg. 35771 6(ii)
33 “Statewide inventory and emissions tracking system (spatial and temporal) of VOC,
34 NOx, elemental carbon, Organic Carbon, PM 2.5”
35 This is a baseline requirement of RHR that is critical/important for the implementation of
36 ESMP. The ESMP document recommends as a minimum the following tracking
37 requirements… (Use our current baseline requirement language, including blackened
38 acreage, fuel type, location, etc., and projections*** of same)
39
40 Because the Rule says “Controls” and ERTs, then ESMP also recommends as important
41 in the tracking capability/process: real-time tracking and tracking of impact and ERTs.
42 ***Reference PFPA for projections
43
ESMP Document Draft B, 4/2/02 II - B - 14
1 The minimum tracking requirement provides the foundation for quantifying the impact of
2 fire emissions on visibility by requiring, in accordance with the Regional Haze Rule34,
3 that all states/tribes begin a basic emissions inventory.
4
5 In keeping with the GCVTC Recommendations35, the Rule36, and the WRAP Policy on
6 Categorizing Fire Emissions, all emissions from fire sources in the WRAP region,
7 regardless of ownership, land use type or cause of ignition, need to be tracked.
8
9 According to the WRAP Policy on Categorizing Fire Emissions:
10
11 Emissions from all fires will be tracked for two purposes, to classify the fire as
12 “natural” or “anthropogenic”, and, if “anthropogenic”, to facilitate the
13 demonstration of reasonable progress….[Further,] the use of alternatives and
14 emission reduction practices needs to be in a fire emissions tracking system for
15 the demonstration of reasonable progress….”37
16
17 Additionally, the emissions tracking system and resulting emissions inventory will be
18 critical to the state/tribe’s development of its ESMP. Therefore, the following represents
19 a list of the basic elements needed for the tracking system:
20
21 Date of burn, burn location, fuel type, tons per acre consumed, blackened acres,
22 etc.
23
24 The Rule also requires that there be evaluation of visibility impairment from smoke for
25 both planning and operational purposes.38 In order to facilitate planning, tracking should
26 also include the assimilation of projection information for the various fire source sectors.
27 To facilitate the operational aspect, and in keeping with the WRAP Policy for
28 Categorizing Fire Emissions on management of fire emissions, a part of the ESMP
29 baseline requirement will be basic considerations of transport issues and for timing of
30 ignitions for better dispersion.39 – Still relevant here?
31
32 Accurate inventories of regulated pollutants emitted by burning on wildlands and other
33 private lands will allow for tracking progress in emission reductions, revising SIPS to
34 reflect needed reasonable progress goal revisions, and modeling at the local to the
35 regional level to assess whether the reported emissions are consistent with monitoring
36 data.
37
38 Whatever the level of implementation of the ESMP, it is important that information can
39 be compared between/within states or tribes in order to assess impacts to regional haze.
40 By collecting the seminal burn activity information uniformly, the emissions can then be
34
RHR states all 309 states will track emissions and all 308 states need to determine sources of impairment
and level of contribution. [Cite.]
35
[Cite GCVTC – Rec #2 re: Fire – “Implement an emissions tracking system for all fire activities.” p.48]
36
RHR, p. 35771, (6) (ii) – is there also a cite for this for sect 308?
37
WRAP Policy for Categorizing Fire Emissions, 3.1.3., p. 12
38
RHR, Section (d), 6, i. P. 35771
39
WRAP Policy on Categorizing Fire Emissions, Section 3.1.1., p. 10
ESMP Document Draft B, 4/2/02 II - B - 15
1 calculated in a consistent fashion across the WRAP region. This still allows for
2 individual approaches to emissions estimation at the state or tribal level while creating
3 the opportunity for WRAP states/tribes to create a consistent emissions calculation
4 process.
5
6 Certainly, these methods will evolve over time, but it is their uniformity in application
7 that is critical. As the SIPs/TIPs will be revisited and revised, per the schedule specified
8 in the Rule, there will be opportunities to refine these recommendations to reflect
9 scientific advances and/or policy changes.
10
11 Implementation Options this section needs to be written
12
13 The WRAP-approved ESMP includes nine elements to be included in the SIP. If a
14 state/tribe wants to do less than a jurisdiction-wide ESMP, then they can use the
15 following criteria to determine what geographical areas or fire source sectors will need
16 what measures (under the nine elements) to address their visibility issues. The criteria are
17 not prescriptive, but meant to assist states/tribes in determining the level of stringency
18 needed to address their visibility issues.
19
20 According to the Rule, wildfire on either agricultural lands or wildlands is not a fire
21 source sector that triggers movement to a more stringent application of ESMP.
22 Prescribed fire on agricultural lands and wildlands as well as wildland fire use/prescribed
23 natural fire can trigger more stringent application. In other words, should fire source
24 sectors be unable to manage their emissions to avoid visibility impairment, more
25 stringent ESMP levels will be needed.
26
27 As areas and sources that contribute to the regional haze problem may be from specific
28 geographic areas, the partitioning of a geographic area may be utilized under this
29 approach in a fashion similar to an area that becomes non-attainment for a criteria
30 pollutant. In this way, an entire state/tribe and/or source sector will not be penalized
31 unnecessarily. This partitioning of a sector would be at the discretion of the state or tribal
32 regulatory authority.
33
34 1) Source Sector Thresholds
35 Use to determine to which sources (because they are “reasonably expected to contribute”)
36 ESMP is applied. Like the BART model (Dave R. can explain)
37
38 And/or
39 2) Situational Criteria (this is re: location)
40 The situational criteria describe certain circumstances that, if true, would indicate to the
41 state/tribe the need for the implementation of more stringent levels of the ESMP. The
42 scenarios below can be used by states/tribes in the development of area or source-specific
43 ESMPs. Further, states/tribes can divide up the tonnage based on fire source (see table
44 below)40 to facilitate determining different ESMP levels for different sources.
40
Tons (PM10) Acres
Wildland (Forest: 20 tons/acre) Ag (4 tons/acre)
ESMP Document Draft B, 4/2/02 II - B - 16
1
2 1) >50 tons/yr PM10 total/year within state/tribe for all anthropogenic fire sources
3 No PM-10 NAAs
4 Within and near (i.e., <50 km) of Class I (“near” – per RHR, cite?)
5
6 2) >250 tons/yr PM10 total/year within state/tribe for all anthropogenic fire
7 sources
8 No PM-10 NAAs
9 Within 100 km of Class I
10
11 3) >100 tons/yr PM10 total/year within state/tribe for all anthropogenic fire
12 sources
13 With moderate PM-10 NAA/Maintenance Area
14 Within 100 km of Class I
15
16 4) >70 tons PM 10 total/year within state/tribe for all anthropogenic fire
17 sources
18 Serious PM-10 NAA
19 Within 100 km Class I
20 These criteria use Prevention of Significant Deterioration (PSD) permitting criteria for
21 tonnage numbers, so as to be familiar to state/tribes in their application.
22
23 [Ozone & >100km: Develop situational criteria for these??]
24
25 Explain to states/tribes the possible ramifications of not having enforcement and burn
26 authority for any geographic area: SIP disapproval, lawsuits under sect. 118 of the Clean
27 Air Act, other?
28 Remind states/tribes about significant sources beyond 100K.
29 Remember also to mention “within and near” concept from GCVTC.
30 Add coordination and notification parallel to PSD
31 Options to proximity radius: Clean Air Corridor (Pete L. can explain)
32
33 And/or
34 3) Impact based: what kind of sources when and where based on attributable impacts.
35 The determination of a state/tribe’s ESMP level could be based on the relative
36 contribution to visibility impairment in Class I areas of its fire source sectors.
37
38 Since the national [visibility] goal is expressed in terms of air quality (i.e.,
39 visibility) rather than emissions, we believe that it is very important to require the
Consumed consumed
250 833 12,500
100 333 5,000
70 233 3,500
50 167 2,500
ESMP Document Draft B, 4/2/02 II - B - 17
1 quantitative tracking of visibility impairment as an integral element in measuring
2 reasonable progress.41
3
4 From the point of implementation of ESMP level 1 (i.e., December 31, 2004), determine
5 if a source sector contributes to a ≥1 deciview impact on any one of the 20 percent worst
6 days in a calendar year. In order to determine this impact, a visibility impact assessment
7 could be conducted using IMPROVE Class I monitored data, the ESMP fire activity data
8 and contemporary visibility modeling techniques. The IMPROVE data has a lag time, as
9 does the visibility impact assessment.
10
11 The 1-deciview-impact metric is commonly associated with visibility analyses and is also
12 used within the PSD permitting process. In order to prevent degradation of the best
13 visibility days, the state/tribe would want to increase stringency measures under the
14 ESMP elements if there is an increasing contribution of fire sources/pollutants (excluding
15 wildfire) present with a decline in visibility of the 20 percent best days over the five year
16 EPA averaging period, i.e., failure to meet reasonable progress.
17
18 The 1-deciview threshold is calculated for a specific worst 20 percent day.
19 Use visibility impact assessment based on IMPROVE and emissions inventory or WRAP
20 modeling analysis for 2018.
21 1 deciview / 20% best: 5 yr average / 20 % worst: 1 deciview on any one day of the 20%
22 worst (Pete L. will write)
23 Incorporate Clean Air Corridor here too also (Pete L.)
24
25 Definition of Clean Air Corridor: due to x circumstances (meteorological conditions) an
26 area is a source of clean air for downwind areas. Note: these have only been established
27 for Colorado Plateau.
28
29 Legislative Barriers
30 The ability of the state/tribe to implement the ESMP may require legislative changes to
31 existing rules or removal of exemptions from regulation of specific fire sources. Under
32 Section 309 there is a SIP submittal and subsequent commitment made by the appropriate
33 state or tribal regulatory authority to implement the ESMP. Should a state/tribe be unable
34 to meet the requirements of the ESMP, it is possible that the Section 309 option may
35 become unavailable.
36
37 Regulatory Authority’s Responsibility Quickly revised this section according to the new
38 paradigm – does this still apply or should it be deleted?
39 The ESMP approach identifies the minimum responsibilities incumbent on the
40 burners/burn community and on the regulators. Throughout all the elements it is assumed
41 that the regulatory authority (state/tribe) has the oversight for the enhanced smoke
42 management program through its SIP/TIP,42 although it may choose to delegate
43 implementation to another entity, e.g., county or municipality. Therefore, it is the
44 regulatory authority’s responsibility to ensure that the mechanisms and infrastructure are
41
RHR, p. 35726
42
22 64 FS 35767, Regional haze program requirements 51.308(d)(3)(v)(E).
ESMP Document Draft B, 4/2/02 II - B - 18
1 in place to implement the ESMP. In some cases this will mean a system such as
2 consistent forms, databases or websites, or on-site mechanisms by which the needed
3 information will be obtained from the burner. It will also be the responsibility of the
4 regulatory authority to track and determine the amount of the contribution to visibility
5 impairment in Class I areas.
6
7 The greater the impact to visibility in Class I areas, the greater the responsibility of the
8 regulatory authority, and accordingly, the infrastructure necessary to implement the
9 ESMP. For example, …
10
11 It is the burner’s responsibility to ensure that data and information submitted to the
12 regulatory authority are accurate, timely, and complete. In some instances this may be no
13 more onerous than a form faxed by the burner to the regulatory authority’s office at the
14 end of the year; in others, extensive information on a daily basis regarding planned and
15 accomplished burning is required.
16
17 Timeline – the data here are no longer relevant, do we still want/need a section on
18 timing?
19
20 SIP 12/03
21 All states/tribes commit to ESMP (minimum level 1). For those states that have visibility
22 or emissions data, use situational criteria to determine level 2 or use visibility assessment
23 to determine level 3. For states/tribes with no data, start at level 1.
24 12/04
25 ESMP level 1 must be implemented. For states/tribes with no data, level 2 is encouraged
26 (incentive: possible prevention of need for ESMP level 3).
27 12/05
28 The first year of emissions data is available for those states/tribes that had none. In this
29 case, apply situational criteria and if applicable, start ESMP level 2.
30 SIP 12/08
31 IMPROVE data as well as emissions data should exist for all states/tribes to conduct a
32 visibility impact assessment to validate existing ESMP level or to determine ESMP level.
33 If the visibility impact assessment is inconclusive, the situational criteria could be used.
34 SIP 12/13
35 ALL states/tribes do visibility impact assessment in enough time to determine ESMP
36 level for this SIP. If impact of >1 deciview, ESMP level 3 or 4 is indicated.
37
ESMP Document Draft B, 4/2/02 II - B - 19
1 IV. ESMP Elements: Guidance & Options This section needs a lot more detail
2 For each of the ESMP elements listed below, there are suggested levels of
3 implementation based on the state/tribe’s visibility concerns. The various options for each
4 element are listed in order of least stringent to most stringent.
5
6 1. Actions to Minimize Emissions from Fire
7
8 Provision of emission reduction technique information by state/tribe; make WRAP
9 guidance on emissions reduction techniques available (e.g., alts to burning doc)
10
11 Burner qualifications: certifiable
12
13 Trading? or Incentives?
14
15 Annual emission goals (cap)
16
17 2. Evaluation of Smoke Dispersion
18
19 The state/tribe provides (or finds ways to provide) the following support to the burn
20 community to assist in impact reduction. E.g., website or other to make available info for
21 smoke management practices (moisture, weather, ventilation index, etc.)
22
23 Burner utilizes state/tribe information to time ignitions for better smoke dispersion.
24
25 Provide burner qualifications and training
26
27 Smoke dispersion modeling prior to the burn
28
29 Centralized decision-making
30
31 Rigorous centralized go/no go: required smoke management
32
33 3. Alternatives to Fire
34
35 State/tribe provides information on alternatives to fire; reference FEJF guidance43
36
37 Burner assesses the ability to utilize alternatives to fire
38
39 Tracking of use of ERTs
40
41 Requirement of alternatives to burning to the maximum extent feasible.
42
43 Burn curtailment
44
43
Ref Alts fire for Ag-ERG / FEJF, other FEJF Guidance docs?
ESMP Document Draft B, 4/2/02 II - B - 20
1 4. Public Notification of Burning
2
3 Ad in the newspaper
4
5 Website for burn notification and information
6
7 Creation of a public education and awareness program (GCVTC)
8
9 Involve community in planning process (SIP/NEPA)
10
11 5. Air Quality Monitoring
12
13 Notes in a logbook on smoke behavior, activity, etc. (aaqtf p.9)
14
15 On-site ambient monitoring
16
17 Visibility impact assessment based on IMPROVE data, etc.
18
19
20 6. Surveillance and Enforcement
21
22 Burner self-enforcing (peer pressure)
23
24 Source sector regulates (e.g., Agricultural Burn Manager, Smoke Management
25 Meteorologist)
26
27 State/tribe in oversight function
28
29 Full-on central authority
30
31
32 7. Smoke Management Program Evaluation
33
34 Burner self-enforcing (peer pressure)
35
36 Source sector regulates
37
38 Oversight function
39
40 Full-on central authority
41
42 Or think about period of review, i.e., annually, quarterly, daily
43
44 8. Burn Authorization (is this redundant?)
45
ESMP Document Draft B, 4/2/02 II - B - 21
1 Provide pre-established burn criteria (“permit-by-rule” system, not daily decision-making
2 by an authority)
3
4 Burn authorization/permitting by source sector (e.g., Agricultural Burn Manager p. 9
5 aaqtf)
6
7 Central Authority -- Daily approval and coordination of burns
8
9 ** Burn Plan = Mandatory (?) -- Wildland already req’d under BSMP; Ag & Private kick
10 in here? Threshold over which must have burn plan? – reference PFPA for recs on
11 elements of a Burn Plan (cite)
12
13 9. Regional Coordination
14
15 Website or other to post the pre-burn activity info for burners/regulators to promote
16 voluntary coordination; Burner utilizes state/tribe burn information to consider transport
17 issues
18
19 Source sector authority coordination
20
21 Centralized authority coordination
22
23 Multi-state/tribe coordination of fire projects when inter-jurisdictional impacts are
24 expected.
25
26 Involved states/tribes develop a multi-state/tribe authority: go/no-go
27
28 Involved states/tribes develop a NIFC-level (regional) authority: go-no-go
29
30 [Per NBTT: include manage element for “N” i.e., addressing viz impacts of wildfire and
31 maintenance burns by …create examples of specific management action here!]
32
33 Emissions Tracking
34
35 Burn Activity Inventory
36
37 The Burn Activity information needs to be available to the state/tribe on an annual basis,
38 and needs to be attributable to any given day. This information can be estimated or
39 collected through direct methods (directly or indirectly determined, e.g., remote sensing,
40 survey, yearly log book). This might be done at a state/tribe level or through individual
41 burner tracking. States/tribes will have to implement their emissions tracking programs
42 by December 2004. It is anticipated that the conversion of the burn activity information
43 to an emissions inventory will be done by the state/tribe, or by the WRAP on behalf of
44 the states/tribes [?*]. All burners [who tracks wildfire?] need to track, at a minimum, the
45 following activity information, with the exception of de minimus burning levels of 10
ESMP Document Draft B, 4/2/02 II - B - 22
1 acres or less per burn, or 50 acres total in a year. [Need consensus on de minimus levels
2 for cumulative totals]
3
4 Burn Activity Inventory – Minimum:
5 Day of Burn Size of Burn (Acres)
6 Location Fire Source Sector
7 Fuel Type Anthropogenic or Natural
8 Tons per Acre Consumed (Blackened acres?)
9
10 Add real-time reporting: same burn activity information, but made available on a
11 daily basis prior to the burn, and made available to cross-jurisdictional
12 authorities. This could be done, for example, by the burner submitting projected
13 burning estimates to a regional or local entity that would post the information on
14 its website, or, if applicable, using a regulatory authority’s website or phone-in.
15
16 Add projection estimates (both 1-yr and 5-yr), for …[what purpose – explain
17 here] For planning purposes, the actual pre-burn information will need to include
18 fuel loadings, consumption expectations, if non-fire alternatives can be utilized
19 and rationale for lack of use, evaluation of potential smoke dispersion and
20 visibility impacts, air quality monitoring and public notification plans.
21
22 Add an annual report to include the number of non-fire alternatives and emissions
23 reduction techniques employed that could be tracked, and then allow for the
24 calculation of the amount of emissions saved. This tracking could be useful for
25 demonstrating reasonable progress toward emissions reduction goals and possible
26 trading purposes.
27
28 Oversight Authority
29 State/Tribe is responsible, and may delegate to local authorities or entities, for receiving
30 the inventory information and projections, and then transmitting the information/files
31 electronically to a central repository [WRAP on behalf of states/tribes?*]. The state/tribe
32 will provide information to the burn community to allow for timing of ignitions for better
33 dispersion and transport considerations.
34
35 Components of the central authority’s information database must be developed so that
36 new information can be added and tracked without duplication of time and effort.
37
38 Infrastructure
39 Minimal: Standardized Burn Activity Inventory requirements and annual
40 repository/compilation. Pamphlet outlining methods and conditions for better dispersion
41 and identification of downwind sensitive Class I areas.
42
43
44
45
46
ESMP Document Draft B, 4/2/02 II - B - 23
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17 APPENDICES
18
19
20 ALL REVISED – PLEASE READ!
21 Contents:
22 Glossary
23 Relevant Reading List & Excerpts
24 Additional Resources
25 (see list of things to consider that mostly come from the ESMPTT work product papers.)
26
27
ESMP Document Draft B, 4/2/02 II - B - 24
1 ENHANCED SMOKE MANAGEMENT PROGRAM
2 Glossary of Terms & Acronyms
3 (DRAFT)
4 BOLD = new or revised definition
5
6 2064 Natural Conditions Goal - The ultimate goal of the regional haze program is the
7 absence of visibility impairment due to human-caused emissions.
8
9 Agricultural Air Quality Task Force (AAQTF) - A task force to address agricultural air
10 quality issues established by the Chief of the Natural Resources Conservation Service.
11
12 Accidental Human Ignition - An unintentional random event. (E.g., Fire ignited by a
13 cigarette butt, an escaped campfire, or a combine.)
14
15 Activity Fuels - Fuels resulting from, or altered by, forestry practices such as timber
16 harvest or thinning, as opposed to naturally created fuels. This may be one we want to
17 leave in?
18
19 Agricultural Fire/Burning - Any fire ignited by management actions to meet specific
20 objectives (i.e., managed to achieve resource benefits) on agricultural land.
21
22 Agricultural Land - Agricultural land includes croplands, pasture, and other lands on
23 which crops or livestock are produced (PL 104-127, Section 1240A). Rangeland will be
24 included with wildland for the purposes of the Fire Emissions Joint Forum work.
25
26 Air Quality – The characteristics of the ambient air (all locations accessible to the general
27 public) as indicated by concentrations of the six air pollutants for which national
28 standards have been established and by visibility in mandatory Federal Class I areas.
29
30 Air Quality Manager – The regulatory body responsible for managing the air quality
31 protection program for a state, local or tribal government.
32
33 Alternatives To Burning (see Non-burning Alternatives) - No prescribed fire, nor ignition
34 source.
35
36 Ambient Air Monitoring and Reporting Forum (AMRF) - The Ambient Air Monitoring
37 and Reporting Forum was established to make recommendations to the Western Regional
38 Air Partnership with regard to appropriate approaches for collection, use, and reporting of
39 ambient air quality and meteorological monitoring data as needed to further the overall
40 goals of the Western Regional Air Partnership.
41
42 Annual Emissions - Actual emissions for a plant, point, or process, either measured or
43 calculated.
44
45 Anthropogenic - Produced by human activities.
46
ESMP Document Draft B, 4/2/02 II - B - 25
1 Anthropogenic Emissions Source Classification (“anthropogenic”) - A categorization that
2 designates which fire emissions contribute to visibility impairment in a Federal Class I
3 area. “Anthropogenic” emissions must be controlled to achieve progress toward the 2064
4 natural conditions goal for each Federal Class I area in the WRAP region. This
5 classification includes natural and human-caused ignitions.
6
7 AP-42 – The Environmental Protection Agency’s Compilation of Air Pollutant Emission
8 Factors for stationary point, area, and mobile sources. An emission factor is a
9 representative value that attempts to relate the quantity of a pollutant released to the
10 atmosphere with the release of that pollutant. Emission factors are then used to estimate
11 the magnitude of source’s pollutant emissions.
12
13 Area Source - A source category of air pollution that generally extends over a large area.
14 Prescribed burning, field burning, home heating, and open burning are examples of area
15 sources.
16
17 Area Sources - Smaller sources that do not qualify as point sources under the relevant
18 emissions cutoffs. Area sources encompass more widespread sources that may be
19 abundant, but that, individually, release small amounts of a given pollutant. These are
20 sources for which emissions are estimated as a group rather than individually. Examples
21 typically include dry cleaners, residential wood heating, auto body painting, and
22 consumer solvent use. Area sources generally are not required to submit individual
23 emissions estimates.
24
25 Arson - The intentional, malicious or fraudulent ignition of a fire or explosion that
26 damages property of the arsonist or another. (E.g., A fire intentionally ignited to accrue
27 ill-gotten gains, such as from an insurance settlement, or a fire intentionally ignited as
28 retribution against a land manager.)
29
30 Attainment Area - an area considered to have air quality as good as or better than the
31 National Ambient Air Quality Standards (NAAQS) as defined in the CAA. Note that an
32 area may be in attainment for one or more pollutants but be a non-attainment area for one
33 or more other pollutants.
34
35 Avoidance- I will put this under Best Management Practices as an example.
36
37 Basic Smoke Management Plan (BSMP) – The seven elements that make up an EPA
38 certifiable (define!!) smoke management program for NAAQS/nuisance.
39
40 Best Available Control Measures (BACM) - Control measures to be developed by
41 Environmental Protection Agency (EPA) which apply to residential wood combustion,
42 fugitive dust, and prescribed and silvicultural burning in "serious" PM-10 non-attainment
43 areas. BACM is more stringent than RACM. Final guidance on BACM is still being
44 developed.—is this true?
45
ESMP Document Draft B, 4/2/02 II - B - 26
1 Best Management Practices (BMPs) – Is a term applied collectively to any administrative
2 or on-the-ground procedure that reduces the negative impacts of some action. An
3 example of a Best Management Practice with respect to air quality would be conducting a
4 prescribed burn when atmospheric ventilation is good which in term promotes smoke
5 dispersal. BMPs are routinely applied to burning activities. A second example of a BMP
6 is avoidance, which is a smoke control strategy that considers meteorological conditions
7 when scheduling prescribed fires in order to avoid incursions into smoke sensitive areas.
8
9 Certifiable SMP (?) –
10
11 Class I Area –An area set aside under the Clean Air Act to receive the most stringent
12 protection from air quality degradation. Mandatory Class I Federal Areas are (1)
13 international parks, (2) national wilderness areas larger than 5,000 acres in size, (3)
14 national parks that exceed 6,000 acres in size and were in existence prior to the 1997
15 CAA Amendments. The extent of a mandatory Class I Federal area includes subsequent
16 changes in boundaries, such as park expansions. Class I areas can also include lands
17 designated by States or Tribes.
18
19 Clean Air Corridor – Is a region that generally brings clear air to a receptor region, such
20 as a Class I area. Is a source of clean air.
21
22 Control of Fire - The controllability of a fire is dictated by a variety of considerations
23 such as firefighter and public safety, risk to property and resources, fire fighting
24 resources available, land management objectives, and environmental, social, economic,
25 and political constraints. The environmental and social constraints include, among other
26 things, how air quality and/or visibility will be affected at sensitive receptors. Control of
27 fire is analogous to full suppression by management action.
28
29 Control of Fire Emissions - Actions may be taken to control fire emissions by utilizing
30 best management practices such as the use of alternatives, biomass utilization, and other
31 emission reduction techniques.
32
33 Criteria Pollutants - Carbon monoxide (CO), lead (Pb), nitrogen oxides (NO ), sulfur x
34 dioxide (SO ), Ozone (O ), particulate matter of aerodynamic diameter less than or equal
35 to 10 micrometers (PM ) and particulate matter of aerodynamic diameter less than or
36 equal to 2.5 micrometers (PM ).
37
38 Cumulative Effects – Is the effect on the environment, which results from the incremental
39 impact of the action when added to other past, present, and reasonable foreseeable future
40 actions regardless of what agency, entity or person undertakes such action. Cumulative
41 effects can result from individually minor but collectively significant actions taking place
42 over a period of time.
43
44 Deciview - a unit of visibility proportional to the logarithm of the atmospheric extinction.
45 Under many circumstances a change in one deciview will be perceived to be the same on
46 clear and hazy days.
ESMP Document Draft B, 4/2/02 II - B - 27
1
2 De Minimus Levels -- Levels of smoke coming from burns covering less than X acres or
3 consume less than Y tons of fuel as established by a State or Tribe.
4
5 Ecosystem Maintenance – As it relates to fire and fire dependant ecosystems, is a
6 prescribed fire or wildfire managed for resource benefits, in an ecosystem that is
7 currently in an ecologically functional and fire resilient condition that is utilized to mimic
8 the natural role of fire. [review this definition!] note revision
9
10 Ecosystem Restoration – As it relates to the use of fire for vegetation manipulation, is the
11 re-establishment of natural vegetation that may be accomplished through the reduction of
12 unwanted and/or unnatural levels of biomass, which may have accumulated due to past
13 management action. Prescribed fires, wildfires managed for resource benefits and
14 mechanical treatments may be utilized to restore an ecosystem to an ecologically
15 functional and fire resilient condition. [review this definition!] note changes
16
17 Emission - pollution discharged into the atmosphere from smokestacks, other vents, and
18 surface areas of commercial or industrial facilities; from residential chimneys; and from
19 motor vehicle, locomotive, aircraft, or other non-road engines.
20
21 Emission Factor (EFp) - The mass of particulate matter produced per unit mass of fuel
22 consumed (pounds per ton, grams per kilogram). Do we use this term? Yes, see AP-42
23 definition
24
25 Emission Factors - Ratios that relate emissions of a pollutant to an activity level at a plant
26 that can be easily measured, such as an amount of material processed, or an amount of
27 fuel used. Given an emission factor and a known activity level, a simple multiplication
28 yields an estimate of the emissions. Emission factors are developed from separate
29 facilities within an.8-3 industry category, so they represent typical values for an industry,
30 but do not necessarily represent a specific source. Published emission factors are
31 available in numerous sources.
32
33 Emission Inventory - A listing, by source, of the amount of air pollutants discharged into
34 the atmosphere of a community.
35
36 Emissions Goal/Cap – Is the concept of placing a limit on the total amount of emissions
37 generated in a year or an extend time period (i.e. 10 years). At the present time there is no
38 legal precedent for this.
39
40 Emission Reduction – A strategy for controlling smoke from prescribed fires that
41 minimize the amount of smoke output per unit of area treated.
42
43 Enhanced Smoke Management Plan (ESMP) – Is a plan for fire that considers visibility
44 effects, not only for health and nuisance objectives and are based on the criteria of
45 efficiency, economics, law, emission reduction opportunities, management objectives,
46 and reduction of visibility impact.
ESMP Document Draft B, 4/2/02 II - B - 28
1
2 Entity – Someone, or an organization or agency that exists.
3
4 Environmental Assessment (EA) - EAs were authorized by the National Environmental
5 Policy Act of 1969. They are concise, analytical documents prepared with public
6 participation that determine if an Environmental Impact Statement is needed for a
7 particular project or action. If an EA determines that an EIS is not needed, the EA
8 becomes the document allowing agency compliance with NEPA requirements.
9
10 Environmental Impact Statement (EIS) - EISs were authorized by the National
11 Environmental Policy Act of 1969. Prepared with public participation, they assist
12 decision makers by providing information, analysis and an array of action alternatives,
13 allowing managers to see the probable effects on the environment.
14
15 Escaped Prescribed Fire - Any fire ignited by management actions on wildland or
16 agricultural land to meet specific objectives that goes out of prescription (e.g., fire
17 intensity greater than specified in a pre-set fire plan, pre-set wind speeds exceeded, fire
18 jumps pre-established boundaries, etc.) in a predefined geographic area.
19
20 ESMP Criteria – Being developed
21
22 ESMP Elements – See ESMP above.
23
24 ESMP Task Team – A diverse group of people tasked with developing an Enhanced
25 Smoke Management Plan, operating under the umbrella of the Western Regional Air
26 Partnership, Fire Emissions Join Forum with the intent of implementing the
27 recommendations of the Grand Canyon Visibility Transport Commission.
28
29 Federal Class I area - In 1977, Congress identified 156 national parks, wilderness areas,
30 international parks and other areas that were to receive the most stringent protection from
31 increases in air pollution. It also set a visibility goal for these areas to protect them from
32 future human-caused haze, and to eliminate existing human-caused haze, and required
33 reasonable progress toward that goal.
34
35 Fire Emissions Joint Forum (FEJF) - The Fire Emissions Joint Forum’s mission is to
36 address both policy and technical issues while developing programs and tools relating to
37 prescribed fire and air quality for the Western Regional Air Partnership and related
38 Western Regional Air Partnership forums.
39
40 Fire - When this term appears, it refers inclusively to wildfire, prescribed natural
41 fire/wildland fire managed for resource benefits, prescribed fire, rangeland fire, and
42 agricultural fire.
43
44 Fire Dependant Ecosystem – A community of plants and animals that must experience
45 recurring disturbances by fire, in order to sustain its natural plant succession, structure
ESMP Document Draft B, 4/2/02 II - B - 29
1 and composition of vegetation, and maintain appropriate fuel loading and nutrient cycling
2 to ensure proper ecosystem function.
3
4 Fire Interval - Time (in years) between two successive fires in a designated area (i.e., the
5 interval between two successive fire occurrences); the size of the area must be clearly
6 specified.
7
8 Fire Return Interval – The number of years between two successive fires in a given area
9 that would occur naturally. For ponderosa pine this is approximately 4 to 7 years.
10 [Difference between Fire Interval above?] naturally occurring vs. occurring
11
12 Fire Source – Is the source of ignition, be it natural or anthropogenic.
13
14 Fire Use – See wildland fire use.
15
16
17 FLM Burn Plan –Is a strategy formulated by federal land managers designed to minimize
18 emissions, disperse smoke and accomplish one or more resource objectives with the use
19 of fire.
20
21 Fuel Loading - The amount of fuel present expressed quantitatively in terms of weight of
22 fuel per unit area. This may be available fuel (consumable fuel) or total fuel and is
23 usually dry weight.
24
25 Fuel Moisture Content - The quantity of moisture in fuel expressed as a percentage of the
26 weight when thoroughly dried at 212 degrees F
27
28 Fuel Reduction – Is the manipulation, including combustion, or removal of fuels to
29 reduce the likelihood of ignition and/or to lessen potential damage and resistance to
30 control.
31
32 Fuel Treatment - Manipulation or removal of fuels to reduce the likelihood of ignition
33 and/or to lessen potential damage and resistance to control (e.g., lopping, chipping,
34 crushing, piling and burning). (Syn. FUEL MODIFICATION) [Should this be an e.g. of
35 “Smoke Management” or “Impact Reduction”?] I would leave it here as is as both terms
36 are used interchangeably.
37
38 Grand Canyon Visibility Transport Commission (GCVTC). - The GCVTC was
39 authorized under Section 169B(f) of the Clean Air Act and composed of the governors of
40 eight western states (AZ, CA, CO, NM, NV, OR, UT, WY), four tribes (Acoma Pueblo,
41 Hopi, Hualapai, and Navajo), four Federal land management agencies (Bureau of Land
42 Management, U.S. Fish and Wildlife Service, U.S. Forest Service, National Park
43 Service), the Columbia River Inter-Tribal Fish Commission, and the Environmental
44 Protection Agency. The Commission was established to recommend methods to preserve
45 and improve visibility on the Colorado Plateau, and submitted Recommendations to EPA
46 in June 1996
ESMP Document Draft B, 4/2/02 II - B - 30
1
2 Impact Reduction -- see Manage Fire Emissions. I would leave as it is.
3
4 Interagency Monitoring of Protected Visual Environments (IMPROVE) -- A cooperative
5 visibility monitoring effort, using a common set of standards across the United States,
6 between the EPA, Federal land management agencies, and state air agencies.
7
8 Interim Policy - Is a policy drafted by the EPA in partnership with land management
9 agencies (Departments of Agriculture, Defense and Interior), State Foresters, State air
10 regulators and others to obtain recommendations and develop a national policy. The
11 Policy addresses how best to improve the quality of wildland ecosystems and reduce
12 threats of catastrophic wildfires through the increased use of managed fire, while
13 achieving national clean air goals.
14
15 Jurisdiction – Is a geographic area of authority.
16
17 Land Managers - When this term appears, it refers inclusively to Federal, state, tribal, and
18 private land managers.
19
20 Light Extinction - The net effect on the amount of light from a scene that reaches an
21 observer of particles that absorb light and particles that scatter light. [Is this term used by
22 us?/ Concept relevant?] I don’t think so, this applies to visibility but might want to leave
23 in?
24
25 Maintenance Burning -- Prescribed burning (regardless of ignition), which emulates the
26 natural role that fire had on the ecosystem. This includes burning the same vegetation
27 type, similar fuel loading, seasonality and fire interval. Any use of prescribed fire that
28 does not conform to all of the above, is not considered maintenance burning. [Proposed
29 by SK] – see also above “Ecosystem Maintenance”
30
31 Manage Fire Emissions - Actions may be taken to manage fire emissions to minimize
32 impacts on visibility, public health, and nuisance concerns. Some management actions
33 include concepts such as the timing of ignitions for better dispersion and consideration of
34 downwind air quality and visibility. It may also include consideration of factors related to
35 the area to be burned such as the fuel moisture condition and other physical parameters.
36 Manage fire emissions is analogous to smoke management.
37
38 Modeling – Is the artificial simulation of some event or action that has quantifiable
39 results. Mathematical expressions and computers are frequently used in modeling
40
41 Monitoring - Periodic or continuous surveillance or testing to determine the level of
42 compliance with statutory requirements and/or pollutant levels in various media or in
43 humans, animals, and other living things.
44
45 National Ambient Air Quality Standards (NAAQS) - the main ambient standards for the
46 following criteria pollutants: carbon monoxide, lead, nitrogen oxides, sulfur oxides,
ESMP Document Draft B, 4/2/02 II - B - 31
1 ozone, particulate matter of aerodynamic diameter less than or equal to 10 micrometers
2 and particulate matter of aerodynamic diameter less than or equal to 2.5 micrometers.
3
4 Natural Background Condition - An estimate of the visibility conditions at each Federal
5 Class I area that would exist in the absence of human-caused impairment.
6
7 Natural Emissions Source Classification (“natural”) - A categorization that designates
8 which fire emissions can result in a natural reduction of visibility for each Federal Class I
9 area in the WRAP region. This classification includes natural and human-caused
10 ignitions.
11
12 Natural Ignition - Fire/Burn ignited due to a natural (i.e., non-human-caused) event. (E.g.,
13 Fire ignited by lightning or volcanic eruption.)
14
15 Natural Background Task Team (NBTT) - A task team of the Fire Emissions Joint Forum
16 working on determining the classification of fire emissions as either “natural” or
17 “anthropogenic”. Team members include Forum and non-Forum members with special
18 expertise.
19
20 National Environmental Policy Act (NEPA) – Establishes procedures that Federal
21 Agencies must follow in making decisions on Federal actions that may impact the
22 environment. Procedures include evaluation of environmental effects of proposed actions,
23 and alternatives to proposed actions: involvement of the public and cooperating agencies.
24
25 Non-Attainment Area – An area identified by an air quality regulatory agency through
26 ambient air monitoring (and designated by the Environmental Protection Agency) that
27 presently exceeds federal ambient air standards. See Attainment Area above.
28
29 Nuisance Smoke – Unwanted smoke that does not exceed National Ambient Air Quality
30 Standards primarily for particulate matter.
31
32 Organic Carbon - Complex carbon-containing compounds often emitted by plants and
33 from many human activities.
34
35 Particulate Matter - Any liquid or solid particles. "Total suspended particulates" as used
36 in air quality are those particles suspended in or falling through the atmosphere. They
37 generally range in size from 0.1 to 100 microns.
38
39 Pasture Land - Grazing lands comprised of introduced or domesticated native forage
40 species that are used primarily for the production of livestock. They receive periodic
41 renovation and/or cultural treatments such as tillage, fertilization, mowing, weed control,
42 and may be irrigated. They are not in rotation with crops (Natural Resources
43 Conservation Service National Range and Pasture Handbook, 1997.)
44
45 Plume Blight - Visual impairment of air quality that manifests itself as a coherent plume.
46
ESMP Document Draft B, 4/2/02 II - B - 32
1 Particulate matter of aerodynamic diameter less than or equal to 10 micrometers (PM10 )
2 -- A measure of small solid matter suspended in the atmosphere that can penetrate deeply
3 into the lung where they can cause respiratory problems. Emissions of PM10 are
4 significant from fugitive dust, power plants, commercial boilers, metallurgical industries,
5 mineral industries, forest and residential fires, and motor vehicles.
6
7 PM2.5 - Particulate Matter of aerodynamic diameter less than or equal to 2.5 micrometers
8 A measure of fine particles of particulate matter that come from fuel combustion,
9 agricultural burning, woodstoves, etc.
10
11 Point Source - a source of pollution that is point-like in nature. An example is the smoke
12 stack of a coal-fired power plant or smelter. See source.
13
14 Point Sources - Large, stationary, identifiable sources of emissions that release pollutants
15 into the atmosphere. Sources are often defined by state or local air regulatory agencies as
16 point sources when they annually emit more than a specified amount of a given pollutant,
17 and how state and local agencies define point sources can vary.
18
19 Prescribed Fire - Any fire ignited by management actions to meet specific objectives (i.e.,
20 managed to achieve resource benefits).
21
22 Prescription - A written statement defining the objectives to be attained as well as the
23 conditions of temperature, humidity, wind direction and speed, fuel moisture, and soil
24 moisture, under which a fire will be allowed to burn. A prescription is generally
25 expressed as acceptable ranges of the prescription elements, and the limit of the
26 geographic area to be covered.
27
28 Prevention of Significant Deterioration (PSD) -- A program identified by the Clean Air
29 Act to prevent air quality and visibility degradation and to remedy existing visibility
30 problems. Areas of the country are grouped into 3 classes that are allowed certain
31 degrees of pollution depending on their uses. National Parks and Wilderness Areas
32 meeting certain criteria are "Class I" or "clean area" in that they have the smallest
33 allowable increment of degradation.
34
35 Rangeland - Land on which the historic climax plant community is predominantly
36 grasses, grass-like plants, forbs, or shrubs. Includes lands re-vegetated naturally or
37 artificially when routine management of that vegetation is accomplished mainly through
38 manipulation of ecological principles. Rangeland includes natural grasslands, savannas,
39 shrub lands, most deserts, tundra, alpine communities, coastal marshes and wet meadows
40 (Natural Resources Conservation Service National Range and Pasture Handbook, 1997.)
41
42 Reasonably Available Control Measures (RACM) - Control measures developed by EPA,
43 which apply to residential wood combustion, fugitive dust, and prescribed and
44 silvicultural burning in and around "moderate" PM-10 non-attainment areas. RACM is
45 designed to bring an area back into attainment and uses a smoke management program
46 that relies on weather forecasts for burn/no-burn days.
ESMP Document Draft B, 4/2/02 II - B - 33
1
2 Regional Haze - visibility impairment caused by the cumulative air pollutant emissions
3 from numerous sources over a wide geographic area.
4
5 Regional Planning Organization - An organization that will first evaluate technical
6 information on regional haze and related issues to better understand how their states and
7 tribes impact national park and wilderness areas (Federal Class I areas) across the
8 country. The organization will then pursue the development of regional strategies to
9 reduce emissions of particulate matter and other pollutants leading to regional haze. The
10 five Regional Planning Organizations that receive funding from EPA to address regional
11 haze and related issues are: Central States Regional Air Partnership (CENRAP) for the
12 central states, Midwest Regional Planning Organization for the mid-western states,
13 Ozone Transport Commission (OTC) for the northeastern states, Southeast States Air
14 Resource Managers (SESARM) for the southeastern states, and Western Regional Air
15 Partnership (WRAP) for the western states.
16
17 Regional Haze Rule (Rule) -- Regulations published in the Federal Register on July 1,
18 1999 (64 FR 35714) that require states to establish goals for improving visibility and to
19 develop long-term strategies for reducing emissions of pollutants that cause visibility
20 impairment.
21
22 Resource Management Plan – A document prepared with public participation and
23 approved by the responsible official that provides general guidance and direction for land
24 management activities. This Plan may identify the need for fire in a specific area for a
25 specific benefit.
26
27 Restoration Burning A type of prescribed burning that strives to become Maintenance
28 Burning. Many types of prescribed burning can be under the auspices of Restoration
29 Burning, but can have different objectives. An example could be burning for wildlife
30 restoration. The goal is to burn away unwanted vegetation and stimulate growth of
31 desired vegetation. This type of burning could be classified as Restoration Burning.
32 After many successful “Wildlife Burns,” these burns could be “Maintenance Burns” if
33 performed under the guidelines of Maintenance Burning. See Ecosystem Restoration
34 above. [Proposed by SK]
35
36 Section 308 – Refers to a section of the Regional Haze Rule that outlines a long-term
37 strategy for a States and Tribes to establish goals for improving visibility and for
38 reducing emissions of pollutants that cause visibility impairment. The course outlined by
39 Section 308 is impact based.
40
41 Section 309 – The definition for this tern is the same as Section 308 except the course
42 outlined in this section is based on reasonable progress. States and Tribes have a choice
43 of the section they opt to implement.
44
45 Sensitive Receptor - See Smoke Sensitive areas below.
46
ESMP Document Draft B, 4/2/02 II - B - 34
1 Smoke Effects - The effects on visibility (both plume blight and regional haze), public
2 nuisance, and the health-based NAAQS due to emissions from fire.
3
4 Smoke Intrusion - Smoke from prescribed fire entering a designated area at unacceptable
5 levels.
6
7 Smoke Management Program (SMP) - The objectives of a basic or enhanced smoke
8 management program are to ensure: 1) no health-based NAAQS are exceeded; 2)
9 nuisance smoke is mitigated; and 3) smoke impacts on visibility are minimized in Class I
10 areas and meet the Grand Canyon Visibility Transport Commission Recommendations.
11
12 Smoke Sensitive Area – Any area where smoke and air pollutants can adversely affect
13 public health, safety and welfare. This term is synonymous with sensitive receptor.
14 Smoke sanative areas are usually associated with places of human habitation such as
15 towns, campgrounds, trails, hospitals, schools, roads, airports and mandatory Class I
16 Federal areas.
17
18 Source -In atmospheric chemistry, the place, places, group of sites, or areas where a
19 substance is injected into the atmosphere. Can include point sources, elevated sources,
20 area sources, regional sources, multiple sources, etc.
21
22 Source – See Area/Fire/Point above.
23
24 State Implementation Plan (SIP) - a state plan approved by EPA for the establishment,
25 regulation, and enforcement of air pollution standards. (See also Tribal Implementation
26 Plan -- TIP)
27
28 Suppression – A management action intended to protect identified values from a fire,
29 extinguish a fire, or alter a fire’s direction of spread.
30
31 Tribal Implementation Plan (TIP) -- Plans devised by tribes to carry out their
32 responsibilities under the Clean Air Act. TIPs must be approved by the U.S.
33 Environmental Protection Agency and include public review.
34
35 Vegetative Burning - Burning of vegetation (i.e., plants or plant growth). (E.g., Burning
36 of grasslands or forestlands.)
37
38 Vegetative Residue Disposal – Is the term given to the treatment of unwanted vegetation
39 after harvest or some other activity has been conducted. Examples of this include the
40 burning or plowing under of agricultural stubble and burning or lopping and scattering of
41 silvicultural activity slash.
42
43 Wildfire - Any unwanted, non-structural fire.
44
45 Wildfire Managed for Resource Objectives - The management of naturally ignited fires,
46 regardless of land type or ownership, to accomplish specific, pre-stated resource
ESMP Document Draft B, 4/2/02 II - B - 35
1 management objectives in predefined geographic areas with or without a plan in place.
2 This term is considered to be analogous with the terms Wildland Fire Managed for
3 Resource Benefits and Prescribed Natural Fire that are used in regulations and policies
4 regarding Federal wildlands.
5
6 Wildland - An area where development is generally limited to roads, railroads, power
7 lines, and widely scattered structures. The land is not cultivated (i.e., the soil is disturbed
8 less frequently than once in 10 years), is not fallow, and is not in the USDA Conservation
9 Reserve Program (CRP). The land may be neglected altogether or managed for such
10 purposes as wood or forage production, wildlife, recreation, wetlands, or protective plant
11 cover (EPA Interim Air Quality Policy on Wildlands and Prescribed Fires). The land is
12 not “agricultural land” as operationally defined above. Silvicultural land and rangelands
13 (per the FEJF charge), woodlots, and private timberlands will be included with wildlands
14 for the purposes of the FEJF work.
15
16 Wildland Fire - All types of fire (see definition of fire above), except fire on agricultural
17 land.
18
19 Wildland Fire Managed for Resource Benefits/Prescribed Natural Fire - These terms both
20 have current use in regulations and policies. They are considered to be synonymous and
21 are used interchangeably in this work plan. These terms refer to the management of
22 naturally ignited fires to accomplish specific, pre-stated resource management objectives
23 in predefined geographic areas outlined in the fire management plan.
24
25 Wildland Fire Use – The management of naturally ignited wildland fires to accomplish
26 specific pre-stated resource management objectives in predefined geographic areas
27 outlined in Fire Management Plans. This term has been used interchangeably with
28 prescribed natural fire (PNF) and fire use for resource benefit (FURB).
29
30 Western Regional Air Partnership (WRAP) - The WRAP is a collaborative effort of tribal
31 governments, state governments and Federal agencies to promote and monitor
32 implementation of Recommendations from the GCVTC. The WRAP may also address
33 other common western regional air quality issues as raised by its membership. The
34 activities of the WRAP are conducted by a network of committees and forums, composed
35 of WRAP members and stakeholders who represent a wide range of social, cultural,
36 economic, geographic and technical viewpoints. The WRAP members include the
37 governors of thirteen western states (AK, AZ,CA, CO, ID, MT, ND, NM, OR, SD, UT,
38 WA, and WY). Tribal nations selected as WRAP members to represent the 247 tribes
39 within the WRAP region include Pueblo of Acoma, Campo Band of Kumeyaay Indians,
40 Cortina Indian Rancheria, Hopi Tribe, Hualapai Nation of the Grand Canyon, Nez Perce
41 Tribe, Northern Cheyenne Tribe, Salish and Kootenai Confederated Tribes, Pueblo of
42 San Felipe, and Shoshone-Bannock Tribes of Fort Hall. Federal WRAP members are the
43 Department of the Interior, the Department of Agriculture, and the Environmental
44 Protection Agency. The National Tribal Environmental Council and the Western
45 Governors’ Association administer the WRAP.
46
ESMP Document Draft B, 4/2/02 II - B - 36
1 WRAP Region - The WRAP region is the area covering all of the 247 member tribes and
2 the 13 member states.
3
4 Yield Improvement - Burning that improves growing conditions for subsequent crops
5 (i.e., by adding nutrients or available water to the soil) or burning that stimulates new
6 growth. (E.g., Field burning on seed production fields.)
7
8 Visibility - Plume blight and regional haze.
9
10
11
12
ESMP Document Draft B, 4/2/02 II - B - 37
1 Additional Related Reading
2
3 Regional Haze Rule [cite]
4
5 Grand Canyon Visibility Transport Commission Recommendations [cite]
6
7 EPA’s Interim Air Quality Policy on Wildland and Prescribed Fire
8 http://www.epa.gov/ttn/oarpg/t1/memoranda/firefnl.pdf
9 [Purpose, Scope, App, Background is available – no Exec. Summ.]
10
11 Agricultural Air Quality Task Force
12 http://fargo.nserl.purdue.edu/faca/Archives/2000/Policy/Burning%20Policy.htm
13
14 WRAP Policy on Categorizing Fire Emissions
15 http://www.wrapair.org/commindex.htm
16
17 FEJF BSMP Draft
18 http://www.wrapair.org/commindex.htm
19
20 IMPROVE Annual Summary (Ann A. locate & get to RR)
21
22 Reference FEJF Work Products: (how to cite? – Pete?)
23 Annual Emissions Goal Paper
24 Alts to Burning Paper: Wildland, Agricultural Land
25 PFPA Paper
26 Note: If above three docs are not ready, reference that FEJF is preparing them.
27
28
29
30
ESMP Document Draft B, 4/2/02 II - B - 38
1
Grand Canyon Visibility Transport Commission:
Recommendations for Improving Western Vistas
to the United States Environmental Protection Agency
June 1996
2
3 EXECUTIVE SUMMARY
4 The Colorado Plateau's national parks and wilderness areas provide a unique, panoramic
5 visual experience for people from around the world. This experience depends on
6 maintaining high visual air quality in the region, which is threatened by haze resulting
7 from projected growth over the next fifty years. Congress has set a national goal of
8 remedying existing human-caused visibility impairment, and preventing future
9 impairment, at these national parks and wilderness areas. Congress recognized that not all
10 haze is human-caused and that haze is a regional issue. Congress created the Grand
11 Canyon Visibility Transport Commission in 1991 to advise the U.S. Environmental
12 Protection Agency on strategies for protecting visual air quality at national parks and
13 wilderness areas on the Colorado Plateau. The Commission established a Public Advisory
14 Committee (PAC) to obtain broad input as it formulated these strategies.
15 The Commission conducted an extensive review of scientific, technical, and other
16 information with assistance from a range of governmental, business, tribal, and
17 environmental interests. It developed more comprehensive databases, and new computer
18 modules to analyze these data and model future air quality. The Commission significantly
19 advanced understanding of regional haze, but limitations and uncertainties remain. Based
20 on that information and its own deliberations, the PAC developed a set of emissions
21 management recommendations for the Commission with a full understanding of progress
22 and limitations in available knowledge. These recommendations are aimed at protecting
23 clear days and reducing dirty days at national parks and wilderness areas on the Colorado
24 Plateau. Following a series of public meetings in April 1996, the PAC and Operations
25 Committee conducted a final review and approval of these recommendations and
26 forwarded them to the Commission for action. The Commission formally considered the
27 PAC and Operations Committee reports on June 10, 1996 and approved them as the
28 Commissions report to the Environmental Protection Agency. The EPA should use the
29 Commission's recommendations as guidance for developing national strategies and/or
30 rulemaking. Implementation of all specific program components will remain the
31 responsibility of tribes, states and their political subdivisions, and, in some cases, federal
32 agencies.
33 Some of the Commission's recommendations ask the EPA to take specific actions or
34 institute particular programs, in cooperation with the tribes, states and federal agencies as
35 implementing bodies. Other recommendations provide a range of potential policy or
36 strategy options for consideration by the EPA and implementing entities. As the EPA
37 develops policies and takes actions based on this report, this distinction between
ESMP Document Draft B, 4/2/02 II - B - 39
1 "actions" and "options" should be maintained with diligence. That is, recommendations
2 intended as policy options should not become mandated actions or regulatory programs.
3 The primary recommendations include:
4 • Air Pollution Prevention. Air pollution prevention and reduction of per capita
5 pollution is a high priority for the Commission. The Commission recommends
6 policies based on energy conservation, increased energy efficiency and promotion
7 of the use of renewable resources for energy production.
8 • Clean Air Corridors. Clean air corridors are key sources of clear air at Class I
9 areas, and the Commission recommends careful tracking of emissions growth that
10 may affect air quality in these corridors.
11 • Stationary Sources. For stationary sources, the Commission recommends closely
12 monitoring the impacts of current requirements under the Clean Air Act and
13 ongoing source attribution studies. Regional targets for SO2 emissions from
14 stationary sources will be set, starting in 2000. If these targets are exceeded, this
15 would trigger a regulatory program, probably including a regional cap and
16 market-based trading. During the next year, participants in the Commission's
17 process will develop a detailed plan for an emissions cap and market trading
18 program.
19 • Areas In And Near Parks. The Commission's research and modeling show that a
20 host of identified sources adjacent to parks and wilderness areas, including large
21 urban areas, have significant visibility impacts. However, the Commission lacks
22 sufficient data regarding the visibility impacts of emissions from some areas in
23 and near parks and wilderness areas. In general, the models used by the
24 Commission are not readily applicable to such areas. Pending further studies of
25 these areas, the Commission recommends that local, state, tribal, federal, and
26 private parties cooperatively develop strategies, expand data collection, and
27 improve modeling for reducing or preventing visibility impairment in areas within
28 and adjacent to parks and wilderness areas.
29 • Mobile Sources. The Commission recognizes that mobile source emissions are
30 projected to decrease through about 2005 due to improved control technologies.
31 The Commission recommends capping emissions at the lowest level achieved and
32 establishing a regional emissions budget, and also endorses national strategies
33 aimed at further reducing tailpipe emissions, including the so-called 49-state low
34 emission vehicle, or 49-state LEV.
35 • Road Dust. The Commission's technical assessment indicates that road dust is a
36 large contributor to visibility impairment on the Colorado Plateau. As such, it
37 requires urgent attention. However, due to considerable skepticism regarding the
38 modeled contribution of road dust to visibility impairment, the Commission
39 recommends further study in order to resolve the uncertainties regarding both
40 near-field and distant effects of road dust, prior to taking remedial action. Since
41 this emissions source is potentially such a significant contributor, the Commission
42 feels that it deserves high priority attention and, if warranted, additional emissions
43 management actions.
ESMP Document Draft B, 4/2/02 II - B - 40
1 • Emissions from Mexico. Mexican sources are also shown to be significant
2 contributors, particularly of SO2 emissions. However, data gaps and jurisdictional
3 issues make this a difficult issue for the Commission to address directly. The
4 Commission recommendations call for continued bi-national collaboration to
5 work on this problem, as well as additional efforts to complete emissions
6 inventories and increase monitoring capacities. These matters should receive high
7 priority for regional and national action.
8 • Fire. The Commission recognizes that fire plays a significant role in visibility on
9 the Plateau. In fact, land managers propose aggressive prescribed fire programs
10 aimed at correcting the buildup of biomass due to decades of fire suppression.
11 Therefore, prescribed fire and wildfire levels are projected to increase
12 significantly during the studied period. The Commission recommends the
13 implementation of programs to minimize emissions and visibility impacts from
14 prescribed fire, as well as to educate the public.
15 • Future Regional Coordinating Entity. Finally, the Commission believes there is
16 a need for an entity like the Commission to oversee, promote, and support many
17 of the recommendations in this report. To support that entity, the Commission has
18 developed a set of recommendations addressing the future administrative,
19 technical and funding needs of the Commission or a new regional entity and has
20 asked the Operations Committee to complete detailed plans by September, 1996.
21 The Commission strongly urges the EPA and Congress to provide funding for
22 these vital functions and give them a priority reflective of the national importance
23 of the Class I areas on the Colorado Plateau.
24 To the maximum extent feasible, Commission recommendations calling for additional
25 exploration and study, etc. (necessary for filling information gaps and for resolving
26 certain policy issues) should be accomplished by the year 2000. Until such time as future
27 organizational arrangements have been determined, all tasks, which are not assigned to
28 any particular existing entity, should be performed by or under the auspices of the
29 Operations Committee.
30 The Commission believes that reasonable progress toward the national visibility goal is
31 achieved to the extent that current Clean Air Act requirements, existing laws and
32 regulations, and the Commission's recommendations result in a significant near-term
33 decrease in emissions that contribute to visibility impairment and ensure long-term
34 protection of visibility. For example by 2000-2010, pollutants from stationary and mobile
35 sources are expected to be reduced by 30% from the 1990 levels.
ESMP Document Draft B, 4/2/02 II - B - 41
1 AIR QUALITY POLICY ON
2 AGRICULTURAL BURNING
3
4 RECOMMENDATION FROM THE
5 AGRICULTURAL AIR QUALITY TASK FORCE
6
7 TO
8 U.S. DEPARTMENT OF AGRICULTURE
9 November 10, 1999
10
11
12 EXECUTIVE SUMMARY
13
14 The AAQTF Agricultural Burning Policy recommends States/Tribes adopt a Smoke
15 Management Program (SMP) to reduce the public health and welfare impacts of using
16 burning in support of agricultural production. The SMP is implemented through an
17 Agricultural Burning Manager (ABM)—the air quality agency or designated authority
18 responsible for managing agricultural burning at the state, local, or tribal level. The
19 policy is founded on two basic principles: (1) allow the use of fire as an accepted
20 management practice, consistent with good science, to maintain agricultural production;
21 and (2) protect public health and welfare by mitigating the impacts of air pollution
22 emissions on air quality and visibility. The recommended SMP is two-tiered. De
23 minimus fires, as established by the ABM, are exempt.
24
25 Tier One: Tier 1 is a voluntary program for areas where agricultural burning rarely
26 causes or contributes to air quality problems. The SMP establishes conditions (time of
27 day and year, meteorological conditions, safety parameters, type of burn, maximum
28 number of acres, etc.) under which agricultural burning can occur. It is essentially a
29 permit by rule.
30
31 Tier Two: Tier 2 is a more structured program than Tier 1 and is designed for areas
32 where agricultural burning contributes to Particulate Matter National Ambient Air
33 Quality Standards violations or visibility impairment in Class I Federal areas. (Areas set
34 aside under the Clean Air Act to receive he most stringent protection from air quality
35 degradation.) The SMP would include a process for authorizing/granting approval for
36 agricultural burns and establish criteria for burn/no-burn decisions. Detailed permitting
37 requirements such as a real-time meteorological assessment for bun decisions, air quality
38 monitoring, public notification, and enforcement requirements would likely be included
39 in a Tier 2 SMP.
40
41 The policy also recommends additional research in the following areas: the ability to
42 predict downwind concentrations of particulate matter utilizing various modeling
43 techniques; evaluating the applicability of current sampling techniques to agricultural
44 burning; determining accurate emission factors; evaluating techniques to reduce
45 emissions of material determined detrimental to human health and visibility; and
46 developing alternatives to agricultural burning.
ESMP Document Draft B, 4/2/02 II - B - 42
1
2 WRAP Policy on Categorizing Fire Emissions
3 EXECUTIVE SUMMARY
4
5 The Western Regional Air Partnership (WRAP), as the successor to the Grand Canyon
6 Visibility Transport Commission (GCVTC), is charged with implementing the GCVTC
7 Recommendations as well as addressing broader air quality issues, such as the Regional
8 Haze Rule. The Regional Haze Rule (Rule), issued by the Environmental Protection
9 Agency (EPA) in July 1999, outlines the requirements for states and tribes to address
10 regional haze in Federal Class I areas, and sets the goal of reaching natural background
11 conditions in Federal Class I areas by 2064. EPA recognizes the WRAP as the Regional
12 Planning Organization that is developing the guidance and means to implement the Rule
13 in the WRAP region.
14
15 There are a number of sources that the EPA has identified as potential contributors to
16 natural background conditions, one of which is fire. The Regional Haze Rule Preamble
17 stipulates that fire of all kinds contributes to regional haze and that fire can have both
18 natural and human-caused sources. The Preamble further states that some fire that is
19 human ignited may be included in a state’s or tribe’s determination of natural background
20 conditions.
21
22 The WRAP Fire Emissions Joint Forum (FEJF) was established to develop policy and
23 technical tools to address smoke effects caused by wildland and agricultural fire on
24 public, tribal, and private lands. Due to the limitations of the current visibility monitoring
25 technology to determine fire impacts, the FEJF was charged with addressing fire
26 emissions’ contribution to natural background conditions. The FEJF formed the Natural
27 Background Task Team (NBTT) to develop a methodology to categorize fire emissions
28 as either “natural” or “anthropogenic”; thus providing the basis for fire’s inclusion in
29 natural background condition values and ultimately, the tracking of reasonable progress.
30
31 This Policy has been developed over an 18-month period by the NBTT; a group made up
32 of state, tribal, and federal agency representatives, as well as those from industry,
33 agriculture, academia, and environmental organizations. During this process, the NBTT
34 solicited public input regarding both technical and policy issues. The resulting
35 Recommended Policy for Categorizing Fire Emissions was granted consensus approval
36 by the FEJF on August 30, 2001. The WRAP granted consensus approval for the Policy
37 on November 15, 2001. As part of the WRAP consensus approval action, the Initiatives
38 Oversight Committee (IOC) Transmittal Letter to the WRAP was modified and
39 incorporated into this Policy as Appendix C.
40
41 The Policy is comprised of two main sections: Classification Criteria and Classification
42 Program Management. The Classification Criteria section determines the “natural” and
43 “anthropogenic” sources of fire that contribute to regional haze, as stated in the Preamble
44 to the Rule. The Program Management section expresses the prerequisites that enable
45 classification to be effective and equitable. Although the Program Management section
ESMP Document Draft B, 4/2/02 II - B - 43
1 addresses prerequisites that need to exist, it does not describe how they will be brought
2 about. This work is currently underway in the FEJF as well as in other WRAP Forums.
3
4 The Classification Criteria clarify the relationship between what would be defined as a
5 “natural” fire emissions source and what would be defined as an “anthropogenic” fire
6 emissions source, thereby addressing the complex relationship EPA acknowledges in the
7 Preamble to the Rule. Under the Policy, most fire emissions sources are classified
8 “anthropogenic”, which is in keeping with the Rule’s primary objective of the
9 development of long-term strategies for reducing emissions of visibility impairing
10 pollutants. However, some fire emissions sources are classified as “natural” in
11 recognition of fire’s inherent occurrence as part of the landscape.
12
13 The Program Management section supports the classification process by iterating that all
14 types of fires must be managed to minimize visibility impacts in order to assure equity
15 among the different fire source types and other air pollution sources. In cases where a fire
16 is classified as “anthropogenic”, its emissions will be controlled in order to demonstrate
17 reasonable progress toward the 2064 natural conditions goal. The Program Management
18 section also recognizes that to determine fire emissions’ contribution to visibility impacts,
19 emissions from all fires will be tracked. This across-the-board tracking is also necessary
20 to allow the classification process to function uniformly across the WRAP region.
21
22 The Policy will provide states and tribes an equitable and practical method for
23 determining which fire emissions will be considered part of the natural background
24 conditions in Federal Class I areas. In so doing, the Policy will enable states and tribes to
25 address natural reductions of visibility from fire as well as identify those fire emissions
26 that need to be controlled to achieve progress toward the 2064 natural conditions goal.
27 The FEJF is developing policy and technical tools that will support this Policy and its
28 implementation, such as guidance on Enhanced Smoke Management Plan elements,
29 recommendations for creation of an annual emissions goal, availability and feasibility of
30 alternatives to burning, recommendations for managing fire emissions sources, guidance
31 for feasibility determinations, a methodology for tracking fire emissions, and a stepwise
32 progression for the Program Management elements of the Policy.
33
34 CLASSIFICATION PROGRAM MANAGEMENT
35
36 D. All fires must be managed to minimize visibility impacts.
37
38 E. All emissions from fires classified as an “anthropogenic” source will be controlled to
39 the maximum extent feasible subject to economic, safety, technical and
40 environmental considerations.
41
42 F. Emissions from all fire will be tracked.
43
44 CLASSIFICATION CRITERIA
45
46 C. Prescribed Fire is an “anthropogenic” source, except where it is utilized to maintain
ESMP Document Draft B, 4/2/02 II - B - 44
1 an ecosystem that is currently in an ecologically functional and fire resilient
2 condition, which is classified as a “natural” source.
3
4 D. Wildfire that is suppressed by management action is a “natural” source. Wildfire,
5 when suppression is limited for safety, economic, or resource limitations, remains a
6 “natural” source. Wildfires managed for resource objectives are classified the same as
7 prescribed fires.
8
9 C. Native American cultural burning for traditional, religious, and ceremonial purposes
10 is a “natural” source.
11
ESMP Document Draft B, 4/2/02 II - B - 45
1
2 More Detail on ESMP Elements from TT Work Products
3
4 Trading [reference EPA’s EIP Policy and AAQTF’s ERC document (per Jason)]
5
6 Determining when multiple day burns can be carried out requires advanced
7 meteorological analysis and planning. (Multiple day emissions evaluation.) [from GZ]
8
9 Komie’s Purpose of Burn list, etc.
10
11 Emissions Reductions (Kuehn)
12
13 Special Events: Collect information within each airshed pertaining to recurring special
14 events and specifically planned events, e.g. annual marathon races, community parades
15 and special events, county fairs, opening hunting season, state holidays, etc. Whether or
16 not there was a concern during the actual burn would depend on a number of factors such
17 as: weather, public acceptance, public education efforts, news releases, etc. Information
18 should be collected for display in a GIS (Lat/Long, UTM) for rapid lookup. (GZ)
19
20 Smoke Management Program Examples
21
22 In an ESMP, annual fire reporting would go into more detail to include information on
23 Wildfire, Prescribed (including agriculture burning) and Fire Use Fires, Ceremonial fire
24 use, etc.
25
26 Inform coordination center of anticipated burns for the year including the earliest ignition
27 date. This would initiate the burn sequencing process. This is the pre-season burn list.
28
29 Develop enhanced smoke notification lists for various pre-established climatologically
30 airflow patterns scenarios. [sic] Draw upon lists for preburn notification and advanced
31 warning should wind directions aloft change to outside of the forecast.
32
33 Address Smoke Dispersion Evaluation – who does it, for what purpose – include RHR –
34 our philosophy about it. Modeling, Monitoring? Ensure that this is included in BSMP –
35 see GZ’s paper
36
37 Require regional approval and real-time tracking of burns. With the regional tracking
38 concept, the regional coordination center should coordinate multiple burns across the
39 western region and multi-states to avoid multiple-layering impacts on airsheds and across
40 state boundaries. This would permit for informed last minute decisions so that airshed
41 optimization can occur.
42
43 Utilize gamed smoke flow paths from the Modeling Section to determine the level of
44 notifications required.
45
ESMP Document Draft B, 4/2/02 II - B - 46
1 Technical Tools:
2
3 Modeling
4 -Regulatory Authority use information derived from the Modeling and Interpretation
5 Section. Game anticipated airflow patterns based on climatological data, utilizing
6 advanced modeling techniques for determining smoke dispersion.
7
8 -Regulatory Authority model/game the year’s set of planned burns using the latest
9 multiple burn assessment tool. This would allow for optimizing annual airsheds and
10 reduce multi-layering of transport smoke paths.
11
12 -Question: Will Burner need to do Modeling and if so, what? When?
13 Specific models, types of models, and the complexity and refinement of modeling
14 inputs will vary with the objective of smoke impact analyses. Less refined total
15 emission analyses may be used for less complex projects. More complex projects
16 may utilize qualitative meteorological analyses; while, even more complex projects
17 will require quantitative dispersion modeling. Once dispersion modeling is triggered,
18 appropriate modeling may range from simplistic Gaussian (Define) to complex
19 photochemical models. The criteria for assessing the complexity of projects should
20 include an analysis of emissions, terrain, meteorology, severity of air quality
21 problems, proximate to population, and governmental regulations. The selection of
22 models will consider all local, state, and federal requirements. Spatial and
23 jurisdictional coverage of potential impacts will also be considered. Models may be
24 applied to both regional and local planning scales. (Ahuja, et al)
25
26 Monitoring
27
28 -Use of real-time PM monitoring equipment in smoke sensitive areas and for visibility
29 concerns. Preferred use of 2.5 µm monitors. Establish thresholds for mandatory and
30 recommended use of monitors. Use to educate public in PM levels and for public and
31 media notification triggers. Use as a tool to sensitize the public to various PM levels.
32 Post the information on the smoke home page and in local media sources. Utilize such
33 models as WinHaze* (PM level comparison tool) to build public awareness of PM levels.
34 *Include in Software appendix?
35
36 -Access real-time high-resolution satellite data for verifying and tracking smoke. Use
37 this data to better improve regional scheduling of burns in future
38
39 On-Site Meteorology
40
41 -Utilize pilot balloons near sensitive receptors prior to ignition to check for proper
42 transport winds. This would ensure that transport winds were as predicted and that
43 appropriate downwind receptors were notified accordingly.
44
ESMP Document Draft B, 4/2/02 II - B - 47
1 -Utilize portable weather stations in areas with known unusual wind patterns. Familiarize
2 meteorologist if needed with a site visit prior to burning. In extremely difficult areas
3 utilize IMET on site during the burn.
4
5 Technical Tools
6
7 Climatology/Meteorology
8
9 -Climatological analysis is needed to determine when multiple day projects can be carried
10 out.
11
12 -Conduct analysis of regional airflow patterns so that statistically safe opportunities for
13 burning throughout the year can be taken advantage of, spreading the smoke over a
14 broader time period.
15
16 -Use meteorological data for gaming smoke situations and scheduling multi-day projects.
17
18 Software List
19
20 Other Appendices to address details of aspects of ESMP that need further clarification
21 e.g., Level 4 Regional Coordination, A/N, etc.
22
23 Trading
24 An emission cap and trade program for fire sources could be used as a compliance option
25 under the annual emission goal requirements of Section 309 of the Regional Haze Rule.
26 In January 2001, the EPA issued a policy document entitled Improving Air Quality with
27 Economic Incentive Programs that provides information on discretionary economic
28 incentive programs (EIPs), including required elements of an EIP program. The EIP
29 Guidance is designed to assist States or Tribes with meeting the requirements of EPA’s
30 Regional Haze Rule.
31
32 The EIP Guidance lists several EIP types such as Emission Averaging Programs, Source
33 Specific Emissions Caps, Multi-Source Emission Cap-and-Trade, and Open Market
34 Trading. Emission Averaging Programs and Source Specific Emission Caps are designed
35 for stationary sources that are subject to a rate-based regulatory limit. Emission Cap-and-
36 Trade and Open Market Trading EIPs allow sources flexibility in complying with
37 emission limits through emission reductions on a mass basis, not a rate-based system.44
38
39 The ESMP Policy does not recommend a uniform Trading Program at levels 1 – 3.
40 However, at level 4 it may be beneficial to establish a trading program for fire due to the
41 following:
42 • It may provide a valuable incentive for land managers to actively pursue non-burning
43 and emission reduction alternatives.
44 • It may dispel any perceived inequities among fire sources and other sources of air
45 pollution.
44
Frances Bernards’ White Paper
ESMP Document Draft B, 4/2/02 II - B - 48
1 • [Need another advantage here to be equal to disadvantages]
2
3 The disadvantages of a program may be:
4 • The expense related to the reductions. The current EIP program is primarily
5 structured for stationary sources (which emit well quantified and monitored
6 pollutants) and contain rigid administrative requirements. A less rigid structure may
7 be needed to accommodate fire sources to reduce the costs.
8 • The seasonality of fire emissions may affect the success of an inter-source cap-and-
9 trade program.
10 • If the cap-and-trade program is limited to visibility impairing aerosols, there may not
11 be a pool of non-fire sources that would choose to participate.
12 None of the above precludes a state or regulatory entity from further pursuing the
13 viability of an emissions trading program at any ESMP level.
14 [Note: RHR addresses trading under 309 on p.35757 – need to include quote?]
15
16
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ESMP Document Draft B, 4/2/02 II - B - 50
ESMP Task Team Conference Call
April 29, 2002
Approval of ESMP Document for Submission to FEJF
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ESMPTT Conference Call
April 29, 2002
Conference Call Record
Participants: Ann Acheson (ESMPTT Co-Chair), Frances Bernards (UT DEQ), Evan
Shipp (CA, San Joaquin Air Pollution District), Pete Stewart (FS Reg. 3), Vicky Komie
(NM Air Quality Bureau), Bob Palzer (Sierra Club), Mark Fitch (AZ DEQ), Suraj Ahuja
(FS Reg.5), Jason Baldwin (Farm Bureau), Mike Ziolko (ESMPTT Co-Chair), Pete Lahm
(FEJF Chair), Rebecca Reynolds, (ESMPTT Facilitator).
Purpose: Review of the ESMP Document Draft to recommend to the FEJF at the May
2002 meeting.
Overall Comments:
Shipp: Good overall. I feel like we’ve dealt with many issues of concern.
Bernards: Flexibility built into it. No major concerns – I like it.
Stewart: Overall I like the document; it’ll work. Much less prescriptive.
Komie: Everything flowing from previous documents. Does this well. What it doesn’t
do: give enough “tools” and a better understanding of how to use them. Can there be a
tools section? Importance of emissions inventory: document “did not mention emissions
tracking elements.” It is not as complete as I’d like to see it. On the whole, however, it
is pretty good.
Shipp: Technical tools--check elements on the web site (he’ll email it to Co-Chairs).
Palzer: Document is a bit longer than it needs to be. Need to clean up some of the
redundancies in it. Quite an improvement--it is going in the right direction. Regarding
incentives options: I would like to get the Co-Chairs some others.
Fitch: This is a very good job; overall I think this is a winner.
Ahuja: Needs a lot of refinement. Elements (1&2) need visibility connection. Material is
there, but there are redundancies and it could use some re-organization.
Issues
Shipp: This document is supposed to integrate NAAQS and Visibility, but I feel like
there is a contradiction. Don’t feel like it integrates them well enough.
Bernards: Regarding annual emission goal (AEG): I have quite a few comments. Section
4.3.1 Actions to Minimize Fire: Suggest integrating AEG here. Reference to AEG and
prescribed fire assessment and emission tracking paper: need to discuss linkage to
Chronological Record II - 213
Section 4.3.8.3 (Centralized Burn Authority). Also, in the Background section needs to
have more. Also, there is not a definition for visibility – add to the glossary? Visibility
definition: Was deleted/omitted from the glossary. Will be put back in. Regarding the
difference among projects in the Purpose Section: there are too many mentions --
redundant. Define all kinds of fire right at the beginning. Once you define fires the
exemption section may be a little more clear. Section 1.2 “This policy applies to impact”
-- change to “visibility impacts.” Also, which ESMP elements are required? Which
elements are from the Rule, it is not clear which elements are from Rule and then which
we highly recommend. Delineation between the required and recommendations.
Finally, under Section 4.3.1: Paragraph 2 on emission reduction techniques: need to add:
“as defined in the FEJF policies on Annual Emissions Goals currently under
development.” Can Mike clean up 2nd paragraph of 4.3.1? Is the first sentence
contradictory? Were utilized is after the burn? What was used and what wasn’t used? --
contradictory?
Palzer: I have a problem with 1st paragraph in 4.3.1: May be other means than use of fire
to reduce emissions and address alternatives as an option. Take out “require the use of
heavy mechanical equipment.” Other techniques may require mechanical means.
Baldwin: Regarding Scope & Applicability: WRAP does not have the authority to give
exemptions. Exemptions shouldn’t be in a guidance document. Define what it applies
to, not what it doesn’t. Regarding Trading: AAQTF is working on recommendations on
ERCs. I will get this to the Co-Chairs.
RE: Exemptions: unfortunate turn of phrase. We are not exempting anything, we are
describing what has been exempted. Who’s determination is it? NBTT? Sectors are not
to be considered (per Frances) per workshop materials. Interpretation from RHR.
Ahuja: Can we recommend reducing fees as an incentive?
Lahm: Something on the 1st page. Define the terms of fire. 1.4 Elements all or some of
these. Not all of these are required? Is this the intent?
Potentially rearrange 308 and 309 discussion: Emissions tracking should be before
308/309. Emission tracking under 2.4?
Implementation Tools does a good job of laying out that these are options for
implementation. Section 1-3 these are the elements; all are part of ESMP. Lead in to
section 4 you relax this. Be clear if all the requirements are required or not.
Implementation tools don’t have to be rigorous, but there is an inconsistency.
Read through “coulds”, “woulds” and “shoulds”.
Situational criteria – letter E – 2500 tons – edit this.
Chronological Record II - 214
4.3.6: seems like it is driven by NAAQS and nuisance – why? Doesn’t fit in context
away from NAAQS and nuisance. Inconsistent with visibility theme. (per Mike: written
from another NAAQS model. He doesn’t see same inconsistency). Make the shoe fit in
re: visibility. Mike will edit.
Voluntary program not discussed as option in Section 4 (4.3. various authorities and
throughout document). Another mention before that but “If you blink, you’ll miss it.”
Fits as potential implementation policy for the state as it moves forward. Flexibility for
states & tribes this is something that could be put out there more dramatically. #33
footnote: tie voluntary 2.3.2. EPA has put forward annex policy this is new information
we didn’t have in Denver. (Pete will run it by Dave Randall) (Pete & Mark F. are going
to do wording on Tues, 4/30)
Need co-chairs to discuss the Annex policy (re: voluntary). Call Vicky if need be. New
Mexico example: can we speak to it in this policy?
“Exemptions” wording/DELETE exemptions. Don’t define types of fire in introduction –
need to add this. Scope. Elements: not clear whether it is all required or some: be clear
and consistent. ESMP does not address or “does not apply” instead of exemptions. In
Scope: States should assess the impacts of these fire sources. Need more in section 1.5
considerations (Pete will assist with this). Elements will each be affected by
considerations (Pete). People need to be aware of the off ramps.
Emissions tracking: want it at the very beginning. Re-emphasize for Vicky as well.
Move 2.4.4 to before 2.4.1. Universal importance and paramount. Substantively the
same, just move it.
Lahm: need collaborative effort for number 250. Level higher than 250 tons would need
to be addressed by the state/tribe. >than 250 tons and/or >100km distance. Put this
narrative in and take out “E”.
Palzer: Agree to write up some more Incentives language. Before FEJF.
Ahuja: I want mention of visibility on elements 1 and 2 at least. Otherwise, it feels like I
am reading a BSMP document.
Fitch: Section 3 (Elements Rationale) is 1 ½ pages long. Seems like 80% of what is in
Section 3 has already been said. Move 4.3 to Section 3 and shorten up rationale part as
the lead-in.
Bernards: Let’s let co-chairs make the decision. Look at order of section 3 and section 4,
ESMP element 8&9, move to 1.4. See if there is a more clear, and precise way to
organize. Reduce redundancies wherever possible.
Lahm: 9 elements make up the WRAP ESMP Policy, but WRAP Policy is not a mandate.
Chronological Record II - 215
Fitch: Section 3 should be lead to 4.3. Explanation of the elements should follow the
rationale. 4.1 & 4.2 move to Appendices. More just examples of how to do things.
Make 4.3 section 3.1. This way 4.3 doesn’t fall under implementation tools. Should be
part of rationale not implementation tools.
Moving 4.3 would help clean up and show 9 elements are required elements for ESMP.
Shipp: 4.2 needs to stay in the body of the document.
Stewart: There is no linkage between BSMP and ESMP in this draft. NAAQS linkage?
Also, Mandatory vs. Other Class I Areas?
Komie: It feels like we are losing tools we have already identified. Policy will be there
with Darla’s document. Feels like the pieces are scattered. ESMP seems weaker without
emission tracking information. Need to run down the other documents. Need to get
emissions inventory. Make this more robust in section 4 (importance of emissions
inventory).
To get a walk across between all FEJF policies, could they all be published together?
FEJF will consider.
Shipp: Seems contradictory how we are dealing with NAAQS. Section 2.3 (RHR quote)
integration stuff here. Next section: I don’t see this as integration. Use criteria in
situational stuff, this is how we are going to integrate NAAQS. Interim report speaks of
BSMP. Policies in this are equivalent to ESMP. Make BSMP linkage “more in your
face.” NAAQS pollutants of concern also contribute to regional haze and therefore,
states/tribes need to address both. (make it stronger!). NAAQS and visibility are
connected -- must consider both. PM2.5 SIP how does that affect visibility SIP?
When the state/tribe is doing one or the other, and has to do both, should take into
consideration the other. Put this into 2.1 Purpose, 2nd paragraph.
4.3.6: Add nuisance to visibility. Do we need to say nuisance everywhere it says
NAAQS? No, do a check to make sure it makes sense to say both. Check to make sure if
it refers to NAAQS only or if it’s nuisance also. Also, when should it be visibility. Check
for appropriate linkage.
ESMP Approval Process:
To FEJF by close of business Friday.
FEJF meets 5/15 --NO ESMPTT meeting attached to the FEJF Meeting, but ESMPTT is
welcome to attend.
Record FEJF comments, revise ESMP draft, then begin Outreach Process.
Incorporate Outreach review comments; and get revised ESMP Document to FEJF for
approval.
FEJF submit for IOC review then on to WRAP by mid July.
Chronological Record II - 216
FEJF Meeting
Coeur d’Alene, Idaho: May 15-17, 2002
Review & Approval of ESMP Policy
Chronological Record II - 217
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Chronological Record II - 218
FEJF Meeting
Review ESMP
Coeur d’Alene, Idaho
May 15-17, 2002
Meeting Record
Day 1
May 15, 2002
Participants: Ann Acheson, ESMP Co-chair, USFS; Suraj Ahuja, USFS; Don Arkell,
WESTAR; Francis Bernards, (FEJF), UT DEQ; Larry Biland, (FEJF), USEPA; Rich
Fisher, (FEJF TOC Liaison), USDA/FS/WO; Mark Fitch, AZ DEQ; Carl Gossard, BLM;
John Graves, BIA; Dennis Haddow, USFWS; Ray Hedrick, SRP; Rob Klein, AK Dept of
Environmental Conservation; Vicky Komie, NM AQB; Scott Kuehn, (FEJF), Plum Creek
Timber Co; Pete Lahm, (FEJF Chair), USDA Forest Service; Jim Lawrence, (FEJF),
WFLC; Bob Palzer, Sierra Club; Darla Potter, WDEQ-AQD; Dave Randall, (FEJF), Air
Sciences; Diane Riley, (FEJF), DEQ; James Scarborough, Air Sciences; Pat Shaver,
(FEJF), USDA/NRCS; Evan Shipp, (FEJF Alternate), SJVAPCD; Dick Stander, Ecology,
WA; John Veranth, (FEJF), University of Utah; Mark Wagoner, (FEJF), Agriculture;
Karen Woods, WA Dept. of Ecology; Mike Ziolko, (FEJF Alternate), ESMP co-chair,
OR Dept of Forestry; Greg Zschaechner, BLM; Rebecca Reynolds, Facilitator, Rebecca
Reynolds Consulting, Inc.
PRESENTATION OF THE ESMP POLICY (A. ACHESON & M. ZIOLKO)
ESMP Policy Development Background
End of July, WRAP will meet to pass policies that will be needed by states for them to
implement provisions of 309 of the Regional Haze Rule. Hopefully, FEJF will finalize
some of the draft policies that have been written, in preparation for public review and the
July meeting.
Objective for the Day: Reach consensus on the Enhanced Smoke Management Program
Policy recommendations.
FEJF Charge: Recommend an Enhance Smoke Management Program Framework for
WRAP approval to facilitate states/tribes regional haze SIP/TIP submittal by December
2003.
ESMP Task Team Charge: Based on the Regional Haze Rule and other guidance
documents, develop an Enhanced Smoke Management Program framework that will
address smoke effects on visibility from forest land, rangeland, and agricultural burning
applicable for whole WRAP region.
ESMP Task Team includes a broad variety of stakeholders. The ESMP Policy draft has
been developed through a series of ten meetings and some 20 conference calls since
Chronological Record II - 219
September 2001, and the Policy has gone through at least four major iterations. The
ESMP Policy document presented today looks very different from previous versions.
IOC members and WESTAR members have also had opportunities to review the Policy
as it has developed and their comments have been incorporated into the development
process.
ESMP Policy Development Next Steps
Garner FEJF consensus and record comments (today)
Revise ESMP draft accordingly
Outreach Process
- Cross-sectional stakeholder review
- Outreach list drafted, 50 people will review
- Standard comment form will be provided, so that comments can be
consolidated easily
- FEJF input on the reviewer list will be taken today, please submit names
- FEJF Forum members will also be sent to ESMP document and can provide
comment
- ESMP Task Team will revise document as appropriate and re-submit to
FEJF for approval
FEJF Consensus approval: FEJF Conf Call for this scheduled on MONDAY,
JULY 1st, 2002, 10:00 am MDT (FEJF Members ONLY)
IOC/TOC review follows
WRAP Approval: July 2002 Meeting
States/Tribes use the ESMP Policy to help determine 308/309 pathway and to
develop regional haze SIP/TIP
Specific Timeframe
June 2002 Outreach reviewer comments due
ESMP Policy Revision & Submission to FEJF
IOC briefing
July 2002 FEJF Consensus Approval
IOC Approval
WRAP Approval
Aug 2002 Final ESMP delivered to states and tribes to use
Final EMSP documentation
Dec 2003 309 Regional Haze SIPS due to EPA
The Final WRAP Policy for Enhanced Smoke Management Programs should:
1. Foster Equity
2. Provide for a Flexible and Uniform Application and implementation
And include all the elements provided in Section 309 of the RHR:
1. Actions to minimize emissions
2. Evaluation of Smoke Dispersion
3. Alternatives to Fire
4. Public Notification
Chronological Record II - 220
5. Air Quality Monitoring
6. Surveillance and Enforcement
7. Program evaluation
With the following additional elements added:
8. A burn authorization component that assesses cumulative visibility impacts
9. Regional coordination, central to burn authorization, coordinated decision-
making
FEJF COMMENT ON ESMP POLICY
FACILITATED DISCUSSION
(All references to section, page or line numbers refer to the May15th, 2002 version of the
ESMP Policy)
What are the basic elements that are mandatory? (S. Kuehn)
(A) The policy is emphatic about the identification and inclusion of the elements (all 9) in
a state’s/tribe’s ESMP. However, states/tribes decide the level of implementation.
What are the “should” and what are the “musts”? Certain points need to be better
defined. (L. Biland)
(A)WRAP Policy needs to be emphatic about what is in an ESMP, but we should not be
prescriptive/regulatory about how it is implemented. Note: Section 1 of the Policy
describes the “musts”, Section 2 is addresses why, and Section 3 is guidance on
implementation.
Are NAAQS and nuisance concerns to be included in this document, or just visibility? (P.
Shaver)
(A) There is an understanding in the ESMP that NAAQS and nuisance are already being
addressed. The focus here is specifically regional haze and visibility. This Policy is
meant to augment SIP/TIPs that are already in place, and address visibility issues for
areas that do not already have smoke management programs in place.
In Section 3 there is a lot of non-visibility stuff, which could be part of the cause of the
confusion. Consider editing to address visibility more specifically. (D. Riley)
Section 3 is half of the document: perhaps this is too long and gives the wrong emphasis.
Instead, emphasize the 9 ESMP elements. Consider putting some of Section 3 in the
Appendices. (D. Potter)
Expand on BSMP/ESMP: perhaps add a fact sheet on what differences are, and what is
relative only to an ESMP. Explain better the ESMP as a tool for 308 Sections 2.4.2 and
2.4.3 pp 17-18. (L. Biland)
Show differences between 308/309 and BSMP/ESMP combinations. Explain and
differentiate in briefings and executive summary. (J. Veranth)
Get up front in the document and really clear:
Chronological Record II - 221
- 309 mandates ESMP
- BSMP and ESMP, ESMP = Visibility
- 308 adopt the ESMP for good smoke management and consistency
Real issue: once WRAP approves this, what happens? (D. Stander)
(A) It goes to states and tribes. EPA will review the presence of the ESMP elements, but
EPA will not specifically address WRAP ESMP Policy.
Make the WRAP-EPA relationship clear -- Section 2.2 Footnote 36, page 13 -- more
formally define state/tribe WRAP-EPA relationship. In the Executive Summary and/or in
Section 1? (D. Stender)
Suggest bringing Purpose (Section 2.1) into Section 1. (F. Bernards)
Happy with the present structure, however, it would be helpful if there could be an
explanation about how the Policy is broken up, up front, about how to use it. (D. Arkell)
Regulative authority: not clear if it can be delegated to non-governmental entities. (E.
Shipp)
(A) Yes, we can make this clear in Section 3 (Section 3.1, pg 19, add “NGO”)
What is the standing or implication or meaning of the ESMP Policy? So what? (R.
Fisher)
What must one do under ESMP that does not have to be done under BSMP? (L. Biland)
Also, what criteria will EPA use to determine whether a state/tribe’s ESMP is
adequate? Consider supplying regional guidelines on this. (D. Arkell)
Question on Section 3.3.1.4 Emissions Goal (J. Veranth)
Economies that are tourist dependent and rely on visibility. More fully flesh out this
concept in Section 3.3.1.3 (B. Palzer)
How is a burn manager or smoke manager going to implement the 9 elements to address
regional haze? Consistency between section 1 and 3.
(A) Much of the details about what is going to be done to improve visibility, specific
implementation of emission reduction techniques, the use of improve data, deciview
thresholds, etc. will be addressed in the collaborative development of SIP/TIPs, signed
off by the EPA, and reviewed thereafter every 5 years to ensure that visibility is getting
better.
The “Musts” of an ESMP
1st 309 = ESMP
2nd WRAP ESMP = 9 elements to be considered
Chronological Record II - 222
3rd 308 States must consider ESMP elements as part of its analytical process
4th EPA must review/approve SIP/TIP
***States/Tribes have the authority about how to implement all or none of the elements
once they are considered*** The emphasis on this is key to IOC’s approval of the ESMP
Policy. (D. Potter)
Section 3, too detailed? e.g., Burner qualifications , on page 26 (D. Potter)
Make clear that 9 elements in Section 3 are same as in Sect 1, and are musts. (S. Kuehn)
Make 1.3 emphasized!! How? Also, BSMP/ESMP clarification. (C. Gossard)
Specify priorities of ESMP, e.g. emission reduction? (E. Shipp)
Section 3, emphasize the significance to visibility improvement for each element.
Section 2.1 Purpose: Manage and Control more in Section 1
Also, GVCTC: “minimize increases in emissions” emphasize this in section 1 or 2?
Get rid of BSMP discussions all together, and simply state that ESMPs are an
enhancement to NAAQS and nuisance mitigation measures already in place as written in
SIP/TIPs. (C. Gossard)
Change ESMP to “ESMP for Visibility and Regional Haze” – Acknowledge that both
BSMP and ESMP exists as concepts – see section 2.3.1
Proposed ESMP Revisions RBR: should this be its own line (separate idea) or is it
section 2.3.1 and should be pulled up a line?
Executive Summary
1. ESMP Policy in relation to WRAP and Regulatory Authorities
2. WRAP ESMP = 9 elements: “The necessary components,” and explain SIP/TIP
Process. Watch use of “Could” and “Should” Consensus that these 9 elements are
sufficiently broad and inclusive to meet the intent.
3. Clarify BSMP/ESMP relationship
4. Clarify 308/309 Pathways, “Elements the same for all states, 308 or 309”
5. Discussion of Flexible Framework and Document Structure
6. Purpose – This is what this is, you should buy into it, this is why….
Section 3 – Not Prescriptive
**No Implementation Strategies should be construed as being required**
(The only requirements are to consider the 9 elements when SIP/TIP planning)
1. All to Appendix, or individual pieces? Each element should have a paragraph or
two descriptions, however, the details of each element should be presented in the
appendices.
2. Revise for visibility only.
3. Check language for consistency of the 9 elements.
Chronological Record II - 223
Appendices
1. Remove BSMP (YES) crosswalk visibility stuff to app??
2. Drop other Executive Summaries for WRAP version
3. Add BSMP Footnote pg. 14
Content
1. ESMP for Visibility and Regional Haze
2. Move Purpose 2.1 after intro 1.1 (first paragraph of page 10)
3. Expand SIP/TIP Process 2.4.4 to include SIP/TIP Process (e.g., collaborative
development – EPA oversight)
Final ESMP Document Structure
Executive Summary
Policy
- 9 elements
- 6 considerations
Section 1 Annotated Policy
- Intro 1.1 and 1.2
- 9 elements + 1st Paragraph sec. 3.3
- Rationale
- 6 Considerations (Sect. 3.1.1)
Section 2 Background
Section 3 Implementation 3.1, 3.2
Appendix Detail 3.3
Further issues:
Some folks may be uncomfortable with moving implementation strategies in to the
appendices, and is unsure about consensus with this point. (E. Shipp)
(ESMPs) Mandatory/Voluntary? Has TT addressed this on pg 16? (D. Riley)
(A) Consideration of the elements is mandatory, how a state chooses to implement the
ESMP is left to the sip process.
Self-regulating vs. voluntary, Pete likes the inclusion of “self regulating.”
Change pg. 16, when discussing voluntary measures, specify SO2 point sources.
Find old language on “voluntary programs” (Denver Draft) and insert lines 28-30. Delete
current lines 28-30 and insert them as footnote to the new lines from the Denver draft.
Also cite ID and NM voluntary programs.
Timeframe (pages 19 and 24) EPA Region 9 – up to 1 year to implement after submittal?
(D. Riley)
(A) Up to 1 year to obtain authority to run a program…need a commitment in the SIP,
then implementation timeframe is negotiated. HOWEVER, the RHR indicates that SIPS
in 309 states have to be implemented from 12/31/03 and effective through 12/31/18.
64FR35770 Section 309 – replace text in document regarding timeframe* (L. Biland)
*Footnote: Region 9 EPA has okayed states/tribes negotiating in implementation time
frames (up to one year).
Chronological Record II - 224
Implementation should be more inclusive for Agriculture, rangeland, and wildland, e.g.,
pg. 23, footnote 61 table, and page 21 land management objectives: manipulate fuels,
residue, crops.
Concerned about impressing the point that states/tribes are allowed to pick which details
of elements they wish to implement, without considering how deeply or dedicatedly they
will implement the details of EACH element. (D. Randall)
3 pathways are listed, not “recommended.” (D. Randall)
Fire/fire emissions, impacts (D. Randall)
Improve ESMP definition, and watch Class I mandatory from the Rule. (D. Randall)
Outreach Comments – Review Period: May 24 to June 3
Need to be received electronically (to Rebecca Reynolds)
Should relate specifically to the document
Should cite specific locations
Should show how or why analyses are flawed
Should show or cite errors
Should provide preferred wording
FEJF conference call for the ESMP Policy consensus approval: Monday, July 1, 2002
10:00 am MDT
Chronological Record II - 225
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Chronological Record II - 226
1
2
3
4
5
6
7
8
9 WRAP Policy for
10 Enhanced Smoke Management Programs
11 (ESMP)
12
13 DRAFT
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37 Prepared by the Enhanced Smoke Management Task Team for
38 the Fire Emissions Joint Forum
39 May 15, 2002
ESMP Policy Draft C, 5/15/02 II - C - 1
1 WRAP Policy for
2 Enhanced Smoke Management Programs
3 (ESMP)
4 DRAFT
5
6
7
8 TABLE OF CONTENTS
9
10 Executive Summary 5
11 To be written.
12
13 1. The Enhanced Smoke Management Program 6
14
15 1.1 Introduction 6
16
17 1.2 Scope and Applicability 6
18 1.2.1 Fire Categorization 7
19
20 1.3 Elements of an ESMP 8
21 1.3.1 ESMP Elements Rationale 9
22
23 1.4 ESMP Considerations 10
24
25 2. Background 10
26
27 2.1 Purpose 10
28
29 2.2 Regulatory Environment 12
30
31 2.3 Context 14
32 2.3.1 Current Smoke Management Guidance 14
33 2.3.2 Current Smoke Management Efforts 15
34
35 2.4 The Regional Haze Rule 16
36 2.4.1 Emissions Tracking 17
37 2.4.2 Section 309 17
38 2.4.3 Section 308 18
39 2.4.4 Regional Haze SIP/TIP Submittal 18
40
41
42
43
ESMP Policy Draft C, 5/15/02 II - C - 2
1 TABLE OF CONTENTS
2
3 3. ESMP Implementation Tools 19
4
5 3.1 Regulatory Authority’s Responsibility 19
6 3.1.1 ESMP Considerations: Examples 20
7 3.1.2 Funding Mechanisms 21
8
9 3.2 Implementation Options 22
10 3.2.1 Source Sector Thresholds 22
11 3.2.2 Situational Thresholds 23
12 3.2.3 Impact Based Thresholds 24
13
14 3.3 ESMP Elements: Implementation Guidance 25
15 3.3.1 Actions to Minimize Emissions from Fire 25
16 3.3.1.1 Emissions Reductions Techniques 25
17 3.3.1.2 Burn Manager Qualification 26
18 3.3.1.3 Incentives 27
19 3.3.1.4 Emissions Goal 27
20
21 3.3.2 Evaluation of Smoke Dispersion 27
22
23 3.3.3 Alternatives to Fire 28
24
25 3.3.4 Public Notification of Burning 29
26
27 3.3.5 Air Quality Monitoring 30
28
29 3.3.6 Surveillance and Enforcement 31
30
31 3.3.7 Program Evaluation 32
32
33 3.3.8 Burn Authorization 33
34 3.3.8.1 Permit by Rule 34
35 3.3.8.2 Burn Permitting System 34
36 3.3.8.3 Centralized Burn Authority 34
37 3.3.8.4 Regional Burn Authority 35
38
39 3.3.9 Regional Coordination 35
40 3.3.9.1 Source Sector Authority Coordination 35
41 3.3.9.2 Centralized Authority Coordination 36
42 3.3.9.3 Regional (Multi-State/Tribe) Coordination 36
43
44
45
ESMP Policy Draft C, 5/15/02 II - C - 3
1 TABLE OF CONTENTS
2
3 4. Appendices 37
4
5 Appendix A. Glossary 38
6
7 Appendix B. Related Documents Listing 44
8
9 Appendix C. Related Documents Excerpts 45
10
11 Executive Summary
12 Grand Canyon Visibility Transport Commission Report 46
13
14 Purpose and Scope/Applicability
15 EPA Interim Air Quality Policy on
16 Wildland and Prescribed Fire 49
17
18 Executive Summary
19 Air Quality Policy on Agricultural Burning,
20 Agricultural Air Quality Task Force Recommendation 52
21
22 Executive Summary
23 WRAP Policy for Categorizing Fire Emissions 53
24
25 Digest
26 FEJF Wildland Fire: Elements of a Basic Smoke
27 Management Program Report Draft 56
ESMP Policy Draft C, 5/15/02 II - C - 4
1 WRAP Policy for
2 Enhanced Smoke Management Programs
3 (ESMP)
4
5
6 Executive Summary
7
8 To be written.
ESMP Policy Draft C, 5/15/02 II - C - 5
1 1. The Enhanced Smoke Management Program (ESMP)
2
3 1.1 Introduction
4
5 The Western Regional Air Partnership (WRAP) Policy for Enhanced Smoke
6 Management Programs (ESMP) identifies for states/tribes in the WRAP region the
7 necessary elements of a smoke management program to address emissions from all types
8 of fire to protect visibility in Class I areas. The ESMP Policy is an outgrowth of the
9 following documents:
10
11 1. The Grand Canyon Visibility Transport Commission’s (GCVTC)
12 Recommendations, June 10, 1996;1
13 2. The WRAP’s Charge to the Fire Emissions Joint Forum (FEJF), July 29, 1998;2
14 3. The Workplan of the FEJF, February 25, 1999;3
15 4. The federal Regional Haze Rule (Rule), July 1, 1999;4
16 5. The WRAP Policy for Categorizing Fire Emissions, November 15, 2001.5
17
18 The ESMP Policy is advanced by the WRAP as a sound policy for states/tribes choosing
19 to implement the requirements of the Regional Haze Rule either under Section 308 or
20 Section 309. The ESMP is a package of nine elements that are to be implemented subject
21 to efficiency, economics, law, emission reduction opportunities, land management
22 objectives, and reduction of visibility impact. Consistent with the WRAP’s Charter and in
23 recognition of the unique air quality circumstances of states/tribes throughout the WRAP
24 region, the ESMP Policy does not prescribe how a state/tribe integrates an ESMP into its
25 regional haze State/Tribe Implementation Plan (SIP/TIP), nor does it prescribe the degree
26 to which any particular state/tribe implements an ESMP. In an effort to provide assistance
27 to states/tribes in these matters, the FEJF has prepared Section 3 of this document,
28 “ESMP Implementation Tools.”
29
30 1.2 Scope and Applicability
31
32 This Policy applies to visibility impacts from fire in Class I areas in the WRAP region.
33 Each state/tribe has an obligation to account for those emissions it produces that have
34 impacts in its own Class I areas, as well as those that have impacts outside its jurisdiction.
35 This approach to the ESMP provides the methodology for this to occur.
36
37 The ESMP applies to all fire as it is defined by the WRAP Fire Categorization Policy:
38
1
Grand Canyon Visibility Transport Commission, Recommendations for Improving Western Vistas,
Report to the U.S. EPA, June 10, 1996 (hereafter referred to as “GCVTC Report”).
2
Fire Emissions Joint Forum Charge, July 29, 1998.
3
Workplan Western Regional Air Partnership – Fire Emissions Joint Forum, February 25, 1999.
4
Published in the Federal Register on July 1, 1999, 64 FR 35714.
5
WRAP Policy for Categorizing Fire Emissions, November 15, 2001 (hereafter referred to as “WRAP Fire
Categorization Policy”).
ESMP Policy Draft C, 5/15/02 II - C - 6
1 This Policy applies to both wildland and agricultural lands regardless of
2 ownership (i.e., Federal, state, tribal, public, private), cause of ignition (e.g.,
3 lightning, arson, accidental human, land management practices) or purpose of the
4 fire (e.g., vegetative residue disposal, hazard reduction, maintain ecosystem
5 health). It is the intent that this Policy be applied equitably across all land types
6 and sources.6
7 All fire sources are included in the ESMP because it is recognized that all fires contribute
8 to regional haze.7
9
10 The WRAP Fire Categorization Policy specifically does not apply to Native American
11 cultural non-vegetative burning for traditional, religious, or ceremonial purposes (e.g.,
12 cremation, sweat lodge fires).8 Nor does it apply to open burning activities on residential,
13 commercial, or industrial property (e.g., backyard burning, garbage incineration,
14 residential wood combustion, construction debris).9 States/tribes may want to consider
15 the impacts of these fire sources when determining application of the ESMP Policy.
16
17 Most states/tribes address fire source sectors differently, as does EPA in its guidance
18 documents. Consequently, fire sources in the WRAP region are currently regulated at
19 various and inconsistent levels, from rigorous regulation to regulation with exemption
20 applied, to no regulation. This variability makes important the need for the development
21 of a consistent framework for ESMP to be applied in the WRAP region.
22
23 Under the ESMP Policy, states/tribes will adopt the ESMP, and may apply it uniformly to
24 its entire jurisdiction. Alternatively, states/tribes may select different degrees of
25 implementation of all the ESMP elements to apply to its different fire source sectors
26 and/or geographical areas depending upon their projected or actual impact upon Class I
27 areas and regional haze.10 In selecting the latter alternative, a state/tribe may promote
28 economic efficiency by preventing over-regulation of a fire source that is not a
29 contributor to visibility impairment and regional haze. This approach may also assist
30 those states/tribes currently without smoke management programs and the related
31 infrastructure to feasibly begin addressing smoke management for visibility. At the same
32 time, those states/tribes with more advanced programs will be able to expeditiously
33 address their visibility concerns. The variation in the implementation of the ESMP is the
34 level of effort applied to each of the nine elements, unless the state/tribe can justify not
35 applying an element to the satisfaction of EPA in its SIP/TIP submittal process.
36
37 1.2.1 Fire Categorization
38
39 The WRAP Fire Categorization Policy was developed to clarify the complex relationship
40 between what is considered a natural source of fire and what is considered a human-
6
WRAP Fire Categorization Policy, p. 7.
7
GCVTC Report, p.47.
8
WRAP Fire Categorization Policy, p. 24.
9
Ibid.
10
See Section 4.2, Implementation Options, of this document for guidance on how this could be achieved.
ESMP Policy Draft C, 5/15/02 II - C - 7
1 caused or anthropogenic source, as acknowledged in the Rule.11 Therefore, in the Fire
2 Categorization Policy, fire has been classified in two categories, “natural” and
3 “anthropogenic” (see the Glossary for definitions).
4
5 According to the WRAP Fire Categorization Policy, wildfire that is suppressed by
6 management action is a “natural” source, and must be managed to minimize visibility
7 impacts.12 It is recognized that the inclusion of wildfire in the ESMP may prove difficult
8 since wildfires are managed with fire fighter and public safety, and protection of property
9 and resources as primary criteria for strategic decision-making. However, under an
10 ESMP, visibility considerations should be added to the list of criteria evaluated to select
11 the appropriate management response wherever possible, subject to safety, economic and
12 resource limitations.13
13
14 Applying ESMP in this manner will facilitate the demonstration of reasonable progress in
15 SIPs/TIPs while taking into account natural background condition values, as outlined in
16 the Rule.
17
18 1.3 Elements of an ESMP
19
20 The elements of an ESMP are based upon careful review and consideration of the federal
21 Regional Haze Rule, the Environmental Protection Agency’s (EPA) Interim Air Quality
22 Policy on Wildland and Prescribed Fires (EPA Interim Policy)14, and the Agricultural
23 Air Quality Task Force’s (AAQTF) Recommendation on Air Quality Policy on
24 Agricultural Burning (AAQTF Recommendation on Air Quality Policy).15 The following
25 are all determined to be necessary elements of a smoke management program to address
26 emissions from all types of fire to protect visibility in Class I areas (i.e., ESMP):
27
28 10) Actions to Minimize Emissions from Fire
29 Any burning techniques that reduce the actual amount of emissions produced.
30
31 11) Evaluation of Smoke Dispersion
32 Using meteorological conditions to assess the ability to minimize smoke impacts.
33
34 12) Alternatives to Fire
35 Removal or reduction of fuels by mechanical, biological or chemical treatments.
36
11
64 FR 35735.
12
WRAP Fire Categorization Policy, p. 8.
13
Ibid. Example: Options may exist when suppressing a wildfire to choose between two strategies that may
create different amounts of burned acres and subsequent emissions. With the inclusion of visibility
considerations, the strategy creating fewer emissions would be chosen, assuming all other considerations
were equal between the strategy choices.
14
U.S. EPA, Office of Air Quality Planning and Standards, Interim Air Quality Policy on Wildland and
Prescribed Fires, April 23, 1998 (hereafter referred to as “EPA Interim Policy”).
15
Agricultural Air Quality Task Force, Air Quality Policy on Agricultural Burning, Recommendation to the
U.S. Department of Agriculture, November 10, 1999 (hereafter referred to as “AAQTF Recommendation
on Air Quality Policy”).
ESMP Policy Draft C, 5/15/02 II - C - 8
1 13) Public Notification of Burning
2 Any method that communicates burn information to the burn community, to air
3 regulators and to the general public.
4
5 14) Air Quality Monitoring
6 Observations and/or equipment that enable an assessment of air quality impacts.
7
8 15) Surveillance and Enforcement
9 An oversight mechanism that allows for the evaluation of the effectiveness of smoke
10 management efforts as defined by the SIP/TIP.
11
12 16) Program Evaluation
13 A mechanism to assess the adequacy of the implementation of the ESMP.
14
15 17) Burn Authorization
16 The management approach used to facilitate burn decision-making.
17
18 18) Regional Coordination
19 Communication and information sharing across state/tribe jurisdictional lines.
20
21 1.3.1 ESMP Elements Rationale
22
23 The first seven ESMP elements come directly from Section 309 of the Regional Haze
24 Rule that states that SIPs/TIPs “must include smoke management programs that include
25 all necessary components including, but not limited to, actions to minimize emissions,
26 evaluation of smoke dispersion, alternatives to fire, public notification, air quality
27 monitoring, surveillance and enforcement, and program evaluation.”16 These same smoke
28 management components are also found in the EPA Interim Policy and the AAQTF
29 Recommendation on Air Quality Policy.
30
31 The EPA Interim Policy and the AAQTF Recommendation on Air Quality Policy also
32 advocate a burn authorization component (i.e., ESMP Element #8).17 Without a central
33 burn authority considering the cumulative visibility impacts from all fire, it will be
34 difficult on a daily basis for individual burners to assess their relative contribution to
35 regional haze.
36
37 Regional coordination (i.e., ESMP Element #9) is central to burn authorization, and will
38 facilitate coordinated decision-making. It is a necessary mechanism to address transport
39 issues and cumulative effects, especially when considering impacts of a source that may
40 be large, or many sources that cumulatively are large, but a long distance from a Class I
41 area (i.e., greater than 100 km). Regional coordination is cited repeatedly in the Rule as
42 key to reaching the natural visibility goal.
43
16
64 FR 35771, § 51.309 (6) (i), emphasis added.
17
EPA Interim Policy, p. 18, and AAQTF Recommendation on Air Quality Policy, p.12.
ESMP Policy Draft C, 5/15/02 II - C - 9
1 Progress toward the national [visibility] goal will require regional programs that
2 operate over large geographic areas and limit emissions of pollutants that can
3 cause regional haze.18
4
5 and:
6
7 In developing each reasonable progress goal, the state [/tribe] must consult with
8 those states [/tribes], which may reasonably be anticipated to cause or contribute
9 to visibility impairment in the mandatory Class I Federal area.19
10
11 The ESMP elements including burn authorization and regional coordination are necessary
12 to managing smoke effects and minimizing visibility impacts in Class I areas.
13
14 1.4 ESMP Considerations
15
16 According to the Rule, the ESMP is subject to the following considerations:
17
18 Enhanced smoke management programs for fire…that are based on the criteria of
19 efficiency, economics, law, emission reduction opportunities, land management
20 objectives, reduction of visibility impact.20
21
22 States/tribes will consider these factors in the development of their ESMPs and, per the
23 GCVTC Report, states/tribes should consider these factors in a collaborative process that
24 includes state, tribal and federal land management agencies and private parties.21 These
25 criteria may influence the extent to which individual elements of the ESMP are applied or
26 the level of effort that is possible. For example, legal barriers may initially exist or
27 infrastructure may need to be developed to implement the ESMP. It is envisioned that,
28 through a collaborative effort, a schedule and process for implementing the ESMP will be
29 created that is acceptable to EPA and affected stakeholders.
30
31 2. Background
32
33 2.1 Purpose
34
35 The purpose of the ESMP Policy is to identify for states/tribes in the WRAP region the
36 necessary elements of an ESMP to address emissions from all types of fire to protect
37 visibility in mandatory Class I areas, as required by the Regional Haze Rule. Although
38 the Rule is only applicable to mandatory Class I areas, state/tribes in the WRAP region
39 may utilize the ESMP Policy to protect visibility in non-mandatory Class I areas.22
40
18
64 FR 35718.
19
64 FR 35766, § 51.308 (d) (1) (B) (iv).
20
64 FR 35771, § 51.309 (d) (6) (iv).
21
GCVTC Report, p. 49.
22
See the Glossary in Appendix for clarification of Class I areas.
ESMP Policy Draft C, 5/15/02 II - C - 10
1 The enhanced smoke management program adds visibility/regional haze considerations
2 to existing smoke management efforts for National Ambient Air Quality Standards
3 (NAAQS) and/or nuisance. The WRAP recognizes that states/tribes are addressing their
4 public health and nuisance concerns associated with smoke in their current smoke
5 management efforts. It is possible that states/tribes may encounter conflicts between
6 managing smoke for visibility considerations and smoke management efforts for NAAQS
7 and/or nuisance. It is therefore recommended that states/tribes coordinate their efforts to
8 protect visibility with existing or future efforts to address NAAQS and/or nuisance
9 smoke.
10
11 The ESMP Policy integrates visibility protection with NAAQS and nuisance protection,
12 in accordance with the Rule:
13
14 The regional haze program is being promulgated in a manner that facilitates
15 integration of emission management strategies for regional haze with the
16 implementation of programs for new NAAQS for ozone and PM.23
17
18 The elements included in the ESMP have been selected because they address direct
19 visibility impacts and regional haze in Class I areas so as to improve visibility on the
20 worst days and maintain visibility on best days. Worst days are defined by the Rule as
21 those days that fall in the lowest 20th percentile for visibility measurements from
22 IMPROVE monitoring, and the best days are those days that are in the highest 20th
23 percentile on an annual basis.24
24
25 The ESMP Policy is the result of the WRAP region-wide multi-state planning and
26 coordination effort focused on addressing the development of ESMPs that address
27 visibility and regional haze. This effort is consistent with the direction provided by EPA
28 in the Preamble to the Rule.
29
30 …progress toward the national [visibility] goal will require regional programs that
31 operate over large geographic areas and limit emissions of pollutants that can
32 cause regional haze…25
33
34 This ESMP Policy has been developed to:
35 • meet the regulatory requirements of the Regional Haze Rule,
36 • address the regulatory equity standards of CAA sect 118 and the Rule,
37 • integrate with WRAP Fire Categorization Policy,
38 • provide a predictable regulatory landscape, and
39 • be feasibly implemented by states/tribes.
40
41 This Policy considers the EPA Interim Policy and the AAQTF Recommendation on Air
42 Quality Policy. The ESMP Policy goes beyond these two documents to address visibility
43 effects and regional haze, as required by the Rule. The WRAP advances the ESMP Policy
23
64 FR 35719, emphasis added.
24
64 FR 35764.
25
64 FR 35718.
ESMP Policy Draft C, 5/15/02 II - C - 11
1 to states and tribes as sound air quality policy to address visibility and regional haze in
2 Class I areas. As such, the ESMP Policy may be incorporated into regional haze
3 SIPs/TIPs submitted to EPA in order to meet the requirements of the Rule.
4
5 This ESMP Policy contains specific elements that, if incorporated into the SIP/TIP, are
6 expected to be approvable by EPA. The WRAP, in advancing this Policy, recognizes the
7 differences among states/tribes with regard to air quality issues, emissions information,
8 fire source sectors, and state legislative or tribal governmental barriers. The WRAP also
9 recognizes that the SIPs/TIPs will be revisited and revised, per the schedule specified in
10 the Rule, giving opportunities to refine the ESMP to reflect technical advances and policy
11 changes.
12
13 The purpose of this Policy is to assist states/tribes to address visibility impacts associated
14 with fire in a way that is adequate for SIP/TIP implementation, and that should minimize
15 the possibility of EPA intervention in the SIP/TIP approval process with regard to fire
16 sources.
17
18 2.2 Regulatory Environment
19
20 In 1990, Congress amended the Clean Air Act, and as part of these amendments created
21 the Grand Canyon Visibility Transport Commission (GCVTC).26 The GCVTC was
22 charged with assessing the current scientific information on visibility impacts and making
23 recommendations for addressing regional haze in the western United States. The GCVTC
24 signed and submitted more than 70 Recommendations to the EPA in a report dated June
25 1996 that indicated that visibility impairment was caused by a wide variety of sources
26 and pollutants, and that a comprehensive strategy was needed to remedy regional haze.
27
28 Fire sources were among those specifically acknowledged in the GCVTC Report as
29 contributors to visibility impairment on an episodic basis.
30
31 All types of fire (prescribed fire and agricultural burning) must be addressed
32 equitably as part of a visibility protection strategy. 27
33
34 Further supporting equity, Section 118(a) of the Clean Air Act28 requires that all entities,
35 federal and non-federal, be subject to the same requirements, authorities and processes,
36 and the Rule is clear that all sources, facilities, and property are to be treated equitably.29
37 Additionally, stakeholder input garnered in the development process of the WRAP Fire
38 Categorization Policy supported consistent consideration of fire between Sections 308
26
The Grand Canyon Visibility Transport Commission (GCVTC) was composed of the governors of eight
western states (AZ, CA, CO, NM, NV, OR, UT, WY), four tribes (Acoma Pueblo, Hopi, Hualapai, and
Navajo), four Federal land management agencies (Bureau of Land Management, U.S. Fish and Wildlife
Service, U.S. Forest Service, National Park Service), the Columbia River Inter-Tribal Fish Commission,
and the Environmental Protection Agency.
27
GCVTC Report, p. 47.
28
Clean Air Act § 118(a).
29
64 FR 35753.
ESMP Policy Draft C, 5/15/02 II - C - 12
1 and 309 of the Rule30. The ESMP, therefore, will be applicable and useful to all states
2 and tribes in the WRAP region.
3
4 The GCVTC Report acknowledged land managers’ projection of significant increases in
5 prescribed fire in order to reduce the effects of wildfire resulting from past decades of fire
6 suppression.31 The GCVTC Recommendations cited the need for minimizing the increase
7 in emissions from all fire programs to the maximum extent feasible.32 One of these
8 Recommendations called for:
9
10 …the development and implementation of criteria and requirements for the use of
11 enhanced smoke management programs (including alternative management
12 practices) and emission reduction strategies.33
13
14 The WRAP was established in 1997 as the successor organization to the GCVTC. The
15 WRAP is a voluntary organization comprised of western governors, tribal leaders and
16 federal agencies,34 and is charged to identify regional or common air management issues,
17 develop and implement strategies to address these issues, and formulate and advance
18 western regional policy positions on air quality.35 The WRAP is designed as a
19 stakeholder-based organization, which uses consensus for the development of policy and
20 technical tools to assist states and tribes in the WRAP region.36 WRAP participants
21 include state air quality agencies, tribes, Federal/state/private land managers, the EPA,
22 environmental groups, industry, academia and other interested parties.
23
24 Following the issuance of the GCVTC Recommendations, the EPA issued the Regional
25 Haze Rule in July 1999 to improve visibility in 156 national parks and wilderness areas
30
WRAP Fire Categorization Policy, p. 7.
31
GCVTC Report, p. 23.
32
GCVTC Report, Recommendation 7, p. 50.
33
GCVTC Report, Recommendation 4, p. 49.
34
The WRAP members include the governors of thirteen western states (AK, AZ, CA, CO, ID, MT, ND,
NM, OR, SD, UT, WA, and WY). Tribal nations selected as WRAP members to represent the 247 tribes
within the WRAP region include Pueblo of Acoma, Campo Band of Kumeyaay Indians, Cortina Indian
Rancheria, Hopi Tribe, Hualapai Nation of the Grand Canyon, Nez Perce Tribe, Northern Cheyenne Tribe,
Salish and Kootenai Confederated Tribes, Pueblo of San Felipe, and Shoshone-Bannock Tribes of Fort
Hall. Federal WRAP members are the Department of the Interior, the Department of Agriculture, and the
Environmental Protection Agency.
35
WRAP Charter, p. 1.
36
The WRAP recognizes the unique legal status and jurisdiction of tribes and seeks to promote policies that
ensure fair and equitable treatment of all participating members of the WRAP. The Partnership also
recognizes the states' and tribe's authority and responsibility to develop, adopt and implement their
individual state and tribal implementation plans. Further, the Partnership recognizes the discretion of the
U.S. Environmental Protection Agency and its responsibility to develop national regulatory initiatives, and
review State and Tribal implementation plans through public rulemaking procedures. In addition, the
Partnership recognizes the affirmative responsibility of the federal land managing agencies under the Clean
Air Act to protect the air quality related values, including visibility of Class I areas and to manage all the
areas under their respective jurisdictions for the public purposes set forth in their governing statutory
authorities. The WRAP has no regulatory authority and recognizes that all legal authority is reserved by its
members in accordance with existing law. The Partnership also recognizes the United States' trust
responsibility as carried out by the federal agencies to protect tribal resources from degradation. –
Excerpted from the WRAP Charter, p.1.
ESMP Policy Draft C, 5/15/02 II - C - 13
1 across the country. The Rule outlines the requirements for states and tribes to address
2 regional haze in mandatory Class I areas. EPA incorporated all of the GCVTC
3 Recommendations into Section 309 of the Rule, which may be used by some of the
4 WRAP states/tribes. The remaining WRAP states/tribes must utilize the nationally
5 applicable Section 308 provisions of the Rule.
6
7 Progress toward the national [visibility] goal will require regional programs that
8 operate over large geographic areas and limit emissions of pollutants that can
9 cause regional haze.37
10
11 EPA recognizes the WRAP as the Regional Planning Organization that is developing the
12 necessary policy and technical tools to implement the Regional Haze Rule in the WRAP
13 region.
14
15 2.3 Context
16
17 2.3.1 Current Smoke Management Guidance
18
19 The EPA Interim Policy and the AAQTF Recommendation on Air Quality Policy were
20 developed to guide states/tribes in addressing public health (i.e., NAAQS) and welfare
21 impacts of smoke.
22
23 In its Interim Policy, the EPA lists seven basic components that it requires for a smoke
24 management program to be certifiable38 including: A) Authorization to Burn, B)
25 Minimizing Air Pollution Emissions, C) Smoke Management Components of a Burn
26 Plan, D) Public Education and Awareness, E) Surveillance and Enforcement, F) Program
27 Evaluation and G) Optional Air Quality Protection.39 The Interim Policy refers to these
28 elements as a basic program for smoke management.40
29
30 The AAQTF Recommendation on Air Quality Policy sets up a two-tiered voluntary
31 program, in which the first tier is based on a predetermined set of burn conditions. The
32 second tier is designed for areas where agricultural burning would be expected to
33 contribute to NAAQS violations or to visibility impairment in mandatory Class I areas. In
34 this second tier, many of the same elements as the EPA Interim Policy requires are
35 involved, including burn authorization, air quality monitoring, emissions reductions
36 techniques, public notification, and enforcement requirements.41
37
38 An integral part of both the EPA Interim Policy and the AAQTF Recommendation on Air
39 Quality Policy is the clear guidance to consider the visibility effects of burning when
40 planning burning operations, and to consider alternatives to burning as well as the of use
37
64 FR 35718.
38
A state/tribe certifies “to EPA that they have adopted and are implementing a smoke management
program that includes the basic components identified in this policy.” EPA Interim Policy, p. 7.
39
EPA Interim Policy, pp. 17-23.
40
EPA Interim Policy, p., 18.
41
AAQTF Recommendation on Air Quality Policy, p.2
ESMP Policy Draft C, 5/15/02 II - C - 14
1 of other emission reduction practices. However, they do not provide specific mechanisms
2 for the development of a smoke management program that addresses regional haze. The
3 EPA Interim Policy states:
4
5 After the regional haze rules become final, states [/tribes] will need to address the
6 impacts of fires and other contributing sources on meeting reasonable progress in
7 their control strategy analyses, as well as during periodic progress assessments.
8 The EPA will revisit this section of the Air Quality Policy on Wildland and
9 Prescribed Fires after the final rules for implementing the regional haze program
10 have been promulgated.42
11
12 To date, the EPA has not revisited the Interim Policy to integrate regional haze
13 considerations outlined in the Rule.
14
15 The AAQTF Recommendation on Air Quality Policy, published after the EPA Interim
16 Policy, addresses regional haze as follows:
17
18 [The Regional Haze Rule] establishes a program to facilitate the integration of
19 emission management strategies for regional haze with SIP [/TIP] components
20 that address emissions of NOx, SO2, VOCs and PM2.5. The Rule strongly
21 encourages multi-state planning efforts to address the haze issue and Air Quality
22 Agencies are moving forward with this effort.43
23
24 2.3.2 Current Smoke Management Efforts
25
26 Most current smoke management efforts and programs to date in the WRAP region have
27 been developed to address public health and/or nuisance concerns, and do not have
28 procedures to address regional haze. States/tribes are currently addressing NAAQS
29 and/or nuisance to the extent they deem appropriate through existing smoke management
30 efforts. EPA has certified some smoke management programs, both inside and outside the
31 SIP/TIP process. The EPA certified programs include those mandated by rule and state
32 statute.
33
34 There is considerable variety among current smoke management efforts of the states and
35 tribes in the WRAP region. The WRAP recognizes that few, if any, states/tribes have
36 smoke management programs that address all fire sources, (e.g., prescribed fire on
37 wildlands, wildland fire use, wildfire and agricultural burning), in one unified program.
38 Some fire sources may have little or no regulation while other fire sources in the same
39 area may have a centralized authority deciding which burns may be conducted and when.
40 Based on the FEJF-commissioned smoke management program surveys,44 prescribed fire
41 on public wildlands is the most regulated fire source sector, with smoke management
42 programs run by a centralized burn authority existent in a majority of WRAP states (AZ,
43 CA, OR, WA, ID, MT, UT). According to the FEJF surveys, three states (CA, OR, WA)
42
EPA Interim Policy, p. 31.
43
AAQTF Recommendation on Air Quality Policy, p. 10.
44
See the Related Documents Listing Appendix of this document.
ESMP Policy Draft C, 5/15/02 II - C - 15
1 in the WRAP Region actively regulate and track agricultural fire sources, and smoke
2 management programs for private rangeland burning are less common than agricultural
3 smoke management programs.
4
5 An ESMP does not erode states’/tribes’ current smoke management efforts, but rather,
6 assumes that states/tribes will maintain their current smoke management efforts and/or
7 smoke management programs for NAAQS and/or nuisance. Since air quality problems
8 have common precursor pollutants, what a state/tribe is doing to address NAAQS may be
9 sufficient to meet reasonable progress goals.45
10
11 The ESMP Policy provides a consistent approach for states/tribes to add visibility
12 considerations to existing smoke management efforts. If there are currently no state/tribe
13 smoke management efforts, ESMP will still be needed, as per the Regional Haze Rule
14 requirements. The ESMP Policy can be used to establish new programs to address
15 visibility concerns. While the ESMP Policy provides a framework for visibility/regional
16 haze, states/tribes may choose to do more to protect NAAQS, prevent nuisance and/or
17 address visibility.
18
19 2.4 The Regional Haze Rule
20
21 The Rule requires states/tribes to address visibility impacts to mandatory Class I areas
22 due to emissions from fire activities. The Preamble to the Rule emphasizes “the
23 implementation of smoke management programs to minimize effects of all fire activities
24 on visibility.”46 Just like the EPA’s 1992 Prescribed Burning Background Document47
25 required incorporation of BACM for fire emissions into the SIPs/TIPs to address PM10
26 NAAQS, the Rule requires states/tribes under Section 309 to incorporate an ESMP into
27 regional haze SIPs/TIPs that address visibility impacts in mandatory Class I areas for all
28 fire sources. Although the ESMP is a mandatory part of the SIP/TIP under Section 309,
29 the EPA has recently endorsed voluntary measures and an established backstop program
30 as a potentially adequate approach to meeting regional haze requirements.48
31
32 Fire is addressed in both Sections 308 and 309 of the Rule as a source of potential
33 visibility impairment. States/tribes complying with either Section 308 or 309, addressing
34 other than the 16 Class I areas on the Colorado Plateau, will need a strategy to develop
35 and track reasonable progress toward the natural visibility goal, calculate baseline and
36 natural visibility conditions, develop a long-term strategy for management of emissions,
37 establish a monitoring strategy, prepare periodic reports demonstrating progress, and
38 develop or update SIPs/TIPs. The WRAP advances the ESMP Policy as the consistent
39 means for Section 308 and 309 states/tribes to meet certain requirements of the Rule.
40
45
64 FR 35721.
46
64 FR 35748.
47
U.S. EPA, Office of Air Quality Planning and Standards, Prescribed Burning Background Document
and Technical Information Document, EPA-450/2-92-003, September 1992.
48
Annex to be published in the Federal Register, May 2002. [The specific aspects of EPA’s decision with
regard to the Annex will be identified in this footnote. – ed.]
ESMP Policy Draft C, 5/15/02 II - C - 16
1 2.4.1 Emissions Tracking
2
3 The tracking of emissions from all fire (i.e., wildland and agricultural land) is a
4 requirement of the Regional Haze Rule for states/tribes choosing to implement the Rule
5 via Section 30849 and via Section 309,50 and will provide information critical to
6 implementing several of the necessary elements of an ESMP. Accurate inventories of
7 regulated pollutants emitted by burning on wildlands and agricultural lands will allow for
8 revising SIPs/TIPs to reflect needed reasonable progress goals, tracking progress in
9 emission reductions, and effectiveness of visibility monitoring and modeling.
10
11 It is important that information can be compared within and between states/tribes in order
12 to assess impacts to regional haze. By collecting the seminal burn activity information
13 uniformly, the emissions can then be calculated in a consistent fashion across the WRAP
14 region. Section 309 also requires projected fire emissions be addressed in order to
15 facilitate regional haze planning and operational smoke management.51 The FEJF is
16 currently developing guidance on emissions tracking for use in the WRAP region to
17 facilitate these objectives.
18
19 2.4.2 Section 309
20
21 The EPA incorporated all of the GCVTC Recommendations into Section 309 of the Rule,
22 which specifically calls for “enhanced smoke management programs for fire that consider
23 visibility effects, not only health [NAAQS] and nuisance objectives….”52 Under Section
24 309, states/tribes must incorporate an ESMP into their SIP/TIP, which will give them the
25 demonstration of reasonable further progress through 2018, as required by the Rule.53
26 The ability of the state/tribe to implement the ESMP may require legislative changes to
27 existing rules or removal of exemptions from regulation for specific fire sources. Should
28 a state/tribe be unable to meet the requirements of the ESMP, it is possible that the
29 Section 309 option may become unavailable.
30
31 Also under Section 309, the Rule calls for the establishment of annual emissions goals for
32 fire that will minimize emissions increases from fire to the maximum extent feasible.54
33 The FEJF is currently developing guidance on the establishment of annual emissions
34 goals that will reinforce the ESMP. The FEJF guidance will address how emission
35 reduction techniques (ERTs) could be established to minimize emission increases as well
36 as the tracking of those ERTs. The tracking of the ERTs will be coordinated with the
37 FEJF guidance on Emission Tracking.
38
39
40
49
64 FR 35767, § 51.308 (d) (3) (iv).
50
64 FR 35771, § 51.309 (d) (6) (ii)
51
64 FR 35771, § 51.309 (d) (6) (i).
52
64 FR 35771, § 51.309 (d) (6) (iv).
53
64 FR 35769, § 51.309 (a).
54
64 FR 35771, § 51.309 (d) (6) (v).
ESMP Policy Draft C, 5/15/02 II - C - 17
1 2.4.3 Section 308
2
3 The ESMP is specifically referred to only in Section 309 of the Rule. The WRAP is
4 advancing the ESMP Policy as a viable tool that states/tribes under Section 308 should
5 implement to meet the requirements of the Rule.
6
7 Section 308 of the Rule states:
8
9 (v) The state [/tribe] must consider, at a minimum, the following factors in
10 developing its long-term strategy [for regional haze]:
11 (E) Smoke management techniques for agricultural and forestry management
12 purposes including plans as currently exist within the states for these purposes.55
13
14 and:
15 The State [/Tribe] must identify all anthropogenic sources of visibility impairment
16 considered by the State [/Tribe] in developing its long-term strategy [for regional
17 haze]. The State [/Tribe] should consider major and minor stationary sources,
18 mobile sources, and area sources.56
19
20 Therefore, under Section 308, if the state/tribe’s analytical process57 shows that fire
21 sources contribute to visibility impairment in a mandatory Class I area, then the Rule
22 requires smoke management techniques for agricultural and forestry lands. According to
23 the ESMP Policy, an enhanced smoke management program means smoke management
24 techniques that address visibility. By this definition, therefore, the ESMP described
25 herein can be applied to meet these purposes for Section 308 as well as Section 309.
26
27 2.4.4 Regional Haze SIP/TIP Submittal
28
29 It is anticipated that the establishment of ESMPs will be incorporated into the SIPs/TIPs
30 submitted to EPA in order to meet the requirements of the Rule. It is recommended that
31 states/tribes integrate their NAAQS and visibility SIP/TIP requirements.
32
33 States/tribes complying with Section 309 are required to have a regional haze SIP/TIP
34 that addresses the Class I areas of the Colorado Plateau (the 16 Class I areas specified by
35 the GCVTC) 58 submitted by December 31, 2003, with implementation of cited control
55
64 FR 35767, § 51.308 (d) (3) (v) (E).
56
64 FR 35767, § 51.308 (d) (3) (iv).
57
As outlined in the Rule under Section 308, this process includes calculating the baseline of all sources;
comparing the baseline visibility conditions with natural conditions; assessing the contribution to this of the
different sources (of which smoke is one); then considering in the development of long term strategies:
smoke management techniques, including current smoke management programs that exist; and if not
adequate, considering enforceable emissions limitations and compliance schedules and other measures as
necessary. 64 FR 35765 § 51.308.
58
The GCVTC Report specified 16 mandatory federal Class I areas on the Colorado Plateau that were
adopted into Section 309 of the Regional Haze Rule. These 16 Class I areas are: Grand Canyon National
Park, Sycamore Canyon Wilderness, Petrified Forest National Park, Mount Baldy Wilderness, San Pedro
Parks Wilderness, Mesa Verde National Park, Weminuche Wilderness, Black Canyon of the Gunnison
Wilderness, West Elk Wilderness, Maroon Bells Wilderness, Flat Tops Wilderness, Arches National Park,
ESMP Policy Draft C, 5/15/02 II - C - 18
1 measures, including the implementation of an ESMP, by the following year. Further, all
2 mandatory Class I areas other than the Colorado Plateau 16, will be addressed in
3 SIPs/TIPs by the 2008 Section 309 deadline.
4
5 States/tribes complying with Section 308 must have incorporated Regional Haze Rule
6 requirements into their SIPs/TIPs within 12 months of designation as PM2.5 attainment, or
7 within three years after designation as PM2.5 non-attainment, but no later than December
8 31, 2008. Under Section 308, all mandatory Class I areas, except those addressed under
9 Section 309, will be addressed in the SIP/TIP submittal tied to the PM2.5 designation.
10
11 3. ESMP Implementation Tools
12
13 The ESMP implementation tools as outlined here provide for the systematic development
14 of smoke management programs across the WRAP region that address visibility
15 impairment in Class I areas and are compatible with current smoke management efforts
16 for NAAQS and nuisance. The WRAP Fire Categorization Policy creates the concept of
17 management and control of fire emissions wherever possible, subject to economic, safety,
18 technical and environmental considerations. Those considerations will vary from state to
19 state, fire source sector to fire source sector. In recognition of this and the current
20 differences among states/tribes in the WRAP region as to source sector burning practices,
21 air quality issues and current smoke management efforts, the ESMP implementation
22 options that follow are intended to assist states/tribes to develop ESMPs that address their
23 specific circumstances.
24
25 States/tribes may select different degrees of implementation of the ESMP elements to
26 apply to their different fire source sectors and/or geographical areas. This promotes
27 economic efficiency by preventing over-regulation of a fire source that is not a
28 contributor to visibility impairment and regional haze. The approach also assists those
29 states/tribes currently without smoke management programs and the related infrastructure
30 to feasibly begin addressing smoke management for visibility. At the same time, these
31 ESMP implementation options will enable those states/tribes with more advanced
32 programs to expeditiously address their visibility concerns.
33
34 3.1 Regulatory Authority’s Responsibility
35
36 The ESMP approach identifies the minimum responsibilities incumbent on the
37 burners/burn community and on the regulators. Throughout all the elements it is assumed
38 that the regulatory authority (i.e., state/tribe) has the oversight for the ESMP through its
39 SIP/TIP,59 although it may choose to delegate implementation to another entity, e.g.,
40 county or municipality. Therefore, it is the regulatory authority’s responsibility to ensure
41 that the mechanisms and infrastructure are in place to implement the ESMP. In some
42 cases this will mean a system such as consistent forms, databases or websites, or on-site
Canyonlands National Park, Capital Reef National Park, Bryce Canyon National Park, and Zion National
Park. 64 FR 35770, § 51.309 (b) (1).
59
64 FR 35767, § 51.308(d) (3) (v) (E).
ESMP Policy Draft C, 5/15/02 II - C - 19
1 mechanisms by which the needed information will be obtained from the burner. It will
2 also be the responsibility of the regulatory authority to track emissions and determine the
3 amount of the contribution to visibility impairment in Class I areas.
4
5 The greater the impact to visibility in Class I areas, the greater the responsibility of the
6 regulatory authority, and accordingly, the infrastructure necessary to implement the
7 ESMP. For example, areas where multiple source type or multiple landowner/land
8 managers are impacting a Class I area may require increased oversight and coordination
9 of burning to mitigate the problem.
10
11 It is also incumbent upon the regulatory authority to develop a SIP/TIP that is consistent
12 with Section 118 of the Clean Air Act pertaining to equitable treatment of federal
13 activities. Section 118 requires that all entities, federal and non-federal, be subject to the
14 same requirements, authorities and processes. Section 118 states, in part:
15
16 "...Each department, agency, and instrumentality of the executive, legislative, and
17 judicial branches of the Federal Government (1) having jurisdiction over any
18 property or facility, or (2) engaged in any activity resulting, or which may result,
19 in the discharge of air pollutants, and each officer, agent, or employee thereof,
20 shall be subject to, and comply with, all Federal, State, interstate, and local
21 requirements, administrative authority, and process and sanctions respecting the
22 control and abatement of air pollution in the same manner, and to the same extent
23 as any nongovernmental entity...".60
24
25 Applying ESMP requirements equitably is the regulatory authorities' responsibility. It is
26 the burner's responsibility to meet the ESMP requirements. The burner needs to ensure
27 that data and information submitted to the regulatory authority are accurate, timely, and
28 complete. In some instances this may be no more onerous than a form faxed by the
29 burner to the regulatory authority’s office at the end of the year; in others, extensive
30 information on a daily basis regarding planned and accomplished burning is required.
31
32 Finally, failure to develop appropriate and necessary oversight and responsibilities may
33 result in EPA's disapproval of the visibility SIP/TIP.
34
35 3.1.1 ESMP Considerations: Examples
36
37 As discussed in Section 1.4 of this document, states/tribes will need to consider the
38 following factors in the development of their ESMPs, which will have an impact on how
39 the ESMP elements are implemented. Examples of the ESMP considerations are as
40 follow:
41
42 Efficiency: What are the resources, infrastructure, networking, workforce and
43 information necessary to reduce visibility impacts in Class I areas? Is it feasible to share
44 these items with another group in order to reduce redundancy or build on existing
45 expertise?
60
Clean Air Act § 118 (a).
ESMP Policy Draft C, 5/15/02 II - C - 20
1
2 Economics: What is the cost of the above items? Are there ways to economically
3 quantify improvements to regional haze in a local area? What is the economic trade-off
4 of moving fuels off-site to be converted to another use or burned elsewhere? What are
5 the economic costs to a landowner to look for emission reduction alternatives? What are
6 the economic losses to a community associated with impairment, (e.g., property values,
7 tourism, etc.)?
8
9 Law: Are there state or local rules or statutes that prohibit mechanical treatments
10 or prohibit the regulation of burning? Are there conflicts with management or law
11 necessary to protect Threatened and Endangered Species?
12
13 Emission Reduction Opportunities: Where are the best and worst places to
14 consider reducing emissions through mechanical, biological, or chemical means? Where
15 are the places where reducing emissions will be best done through smoke management
16 techniques rather than moving fuels off-site or manipulating fuels through chemicals or
17 biological decomposition?
18
19 Land Management Objectives: Are there places where manipulating fuels is not
20 an option because of land management objectives, e.g., designated wilderness, wildlife
21 habitat, crop requirements, or inaccessible terrain? Are there places where manipulating
22 fuels is more conducive to the land management objective, e.g., areas targeted for
23 commodity production?
24
25 Reduction of Visibility Impacts: Using the current information and science
26 available to a state/tribe, how will an ESMP decrease impacts to visibility?
27
28 3.1.2 Funding Mechanisms
29
30 Funding for smoke management programs can come from many possible sources. Basic
31 programs may be funded entirely from state/tribe allocations, while enhanced programs
32 may require a combination of sources, including cooperative funding from state/tribe and
33 local governments and burners. Funding mechanisms should depend on the magnitude of
34 the smoke management programs. For example, an ESMP in a state/tribe with minor
35 visibility impacts to Class I areas may not require elaborate funding mechanisms, while a
36 program in a state/tribe with a large amount of prescribed burning and a number of Class
37 I areas may need a complex funding mechanism.
38
39 The following is a list of possible methods for funding smoke management programs:
40
41 A. Funds obtained from users of prescribed fire.
42 d. MOU/MOA/Consortium Funds
43 • Each member/signatory pays an annual membership fee and there is an
44 additional per acre fee for accomplished burns.
45 e. Permit/Emission Fees
ESMP Policy Draft C, 5/15/02 II - C - 21
1 • Permit fees may vary depending on the type of burn. Some examples
2 follow:
3 o A fee for each burn plan and an additional fee based on actual
4 acreage burned.
5 o A predetermined fee for a 30-day single-site permit, another fee for
6 a multiple site annual permit of 1-500 aggregate acres, with
7 another fee for > 501 aggregate acres.
8 o Fees based on emissions from the previous calendar year with
9 periodic rate adjustments.
10 o A flat fee assessed for each unit that is registered or burned.
11 o Fees are applied taking into consideration alternative ways of
12 burning and/or fuel treatments used.
13 f. Acreage assessments
14 • An assessment, per acre, to register a unit for burning, then an assessment
15 per acre actually burned. Assessments vary by type of burn.
16 B. Grants and/or Appropriated Funding
17 • A combination of many sources including EPA grant, city and county
18 governments, fire protection assessments, property taxes.
19 • General revenue program/appropriated funds received from a legislative
20 body.
21
22 3.2 Implementation Options
23
24 The ESMP Policy includes nine elements to be included in the SIP/TIP. A state/tribe may
25 elect to develop its ESMP from these elements and apply it uniformly throughout its
26 jurisdiction. However, if a state/tribe wants to do less than a jurisdiction-wide ESMP, it
27 can then use the following criteria to determine what geographical areas and/or fire
28 source sectors will need what measures (under the nine elements) to address the
29 state’s/tribe’s visibility issues. As areas and sources that contribute to regional haze may
30 be from specific geographic areas, the partitioning of a geographic area may be utilized
31 under this approach in a fashion similar to an area that becomes non-attainment for a
32 criteria pollutant. In this way, an entire state/tribe and/or source sector would not
33 implement elements that have no bearing on the extent or magnitude of mitigating
34 visibility impairment in a Class I area. This partitioning of a sector would be at the
35 discretion of the state or tribal regulatory authority.
36
37 The following criteria are not prescriptive, but rather, are meant to assist states/tribes in
38 determining how comprehensive of an ESMP is needed to address their visibility issues.
39 Three possible pathways are recommended to help a state/tribe evaluate how
40 comprehensive of a program is needed in their jurisdiction. The options are described
41 below and may be implemented independently or in any combination, as necessary.
42
43 3.2.1 Source Sector Thresholds
44
45 Best Available Retrofit Technology (BART) requirements exist for stationary sources
46 under the Clean Air Act and EPA regulations. There is a presumption under the BART
ESMP Policy Draft C, 5/15/02 II - C - 22
1 requirements that certain sources may be reasonably expected to contribute to visibility
2 impairment. If, through computer modeling, fire sources are determined to impact
3 visibility, then ESMP criteria may be applied for some or all of the elements shown in
4 Section 3.3, below.
5
6 BART considerations for fire sources that are analogous to requirements for stationary
7 sources are:
8
9 • The availability of technology.
10 • The costs of compliance.
11 • The energy and the non-air quality environmental impacts of compliance.
12 • Any pollution control equipment in use or in existence at the source (especially if
13 incentives are used).
14 • The recurring nature of a burn on a particular parcel of land.
15 • The degree of improvement in visibility that may reasonably be anticipated to
16 result from the use of such technology. This analysis should be a regional
17 modeling analysis and be made on a cumulative impact basis.
18
19 3.2.2 Situational Thresholds
20
21 The situational criteria describe certain circumstances that, if true, would indicate to the
22 state/tribe the need for the implementation of more comprehensive elements of the
23 ESMP. The scenarios below can be used by states/tribes in the development of area or
24 source-specific ESMPs. Each scenario describes a combination of emissions, NAAQS
25 status (e.g., non-attainment area status) and proximity that may trigger the need for an
26 ESMP.
27
28 The emissions levels facilitate determining ESMP levels for different sources and are
29 consistent with PSD permitting requirements for stationary sources (see table below).61
30 The emissions are the annual totals that would be produced. The attainment status
31 accounts for existing non-attainment area (NAA) issues that a state/tribe may need to
32 address. The proximity parameter addresses how close a fire source is to a Class I area.
33
34 a) Emissions levels: Greater than 50 tons/yr of PM10 (total/year) within
35 state/tribe for all anthropogenic fire sources
36 Attainment status: No PM10 or ozone NAAs
37 Proximity: Within and near (i.e., <50 km) a Class I area
61
Tons (PM10) Acres Burned (Annual Total)
Wildland Ag
(Forest: 20 tons/acre consumed) (4 tons/acre consumed)
250 833 12,500
100 333 5,000
70 233 3,500
50 167 2,500
ESMP Policy Draft C, 5/15/02 II - C - 23
1
2 b) Emissions levels: Greater than 250 tons/yr of PM10 (total/year) within
3 state/tribe for all anthropogenic fire sources
4 Attainment status: No PM10 or ozone NAAs
5 Proximity: Within 100 km of Class I area
6
7 c) Emissions levels: Greater than 100 tons/yr PM10 (total/year) within state/tribe
8 for all anthropogenic fire sources
9 Attainment status: Moderate PM10 or ozone NAA or Maintenance Area
10 Proximity: Within 100 km of Class I area
11
12 d) Emissions levels: Greater than 70 tons/yr PM10 (total/year) within state/tribe
13 for all anthropogenic fire sources
14 Attainment status: Serious PM10 or ozone NAA
15 Proximity: Within 100 km of Class I area
16
17 Levels greater than 250 tons of PM10 and distances farther than 100 km will need to be
18 addressed by states/tribes to determine application of ESMP elements.
19
20 3.2.3 Impact Based Thresholds
21
22 The determination of a state’s/tribe’s ESMP level of effort may also be based on the
23 relative contribution of its fire source sectors to visibility impairment in Class I areas.
24
25 Since the national [visibility] goal is expressed in terms of air quality (i.e.,
26 visibility) rather than emissions, we believe that it is very important to require the
27 quantitative tracking of visibility impairment as an integral element in measuring
28 reasonable progress.62
29
30 An impact level would be used by the state/tribe to determine the comprehensive
31 approach that would need to be implemented. The one-deciview impact metric is
32 commonly associated with visibility analyses and is also used within the PSD permitting
33 process. ESMPs would begin being implemented December 31, 2004. Beginning with
34 this implementation time, states/tribes would determine if a source sector contributes to a
35 greater than or equal to one-deciview impact on any one of the 20 percent worst days in a
36 calendar year.
37
38 In order to determine this impact, a visibility impact assessment could be conducted using
39 IMPROVE monitored data, the emissions tracking fire activity data and contemporary
40 visibility modeling techniques. The IMPROVE data has a lag time as does the visibility
41 impact assessment so there would be a longer period between the time when impacts
42 were measured and strategies and revised ESMPs could be implemented.
43
44 Furthermore, to prevent degradation of the best visibility days, the state/tribe would want
45 to use additional criteria under the ESMP elements if there is an increasing contribution
62
64 FR 35726.
ESMP Policy Draft C, 5/15/02 II - C - 24
1 of fire sources/pollutants (excluding wildfire) present with a decline in visibility of the 20
2 percent best days over the five-year averaging period, i.e., failure to meet reasonable
3 progress.
4
5 3.3 ESMP Elements: Implementation Guidance
6
7 For each of the ESMP elements listed below, there are implementation options listed to
8 assist states/tribes in developing their ESMPs. This is not meant to be an exhaustive list,
9 and states/tribes may also want to review the FEJF draft report on Wildland Basic Smoke
10 Management Program Elements63 as well as the EPA Interim Policy and the AAQTF
11 Recommendation on Air Quality Policy for additional suggestions. The level of effort
12 each state/tribe would apply in its ESMP is based on the severity of the visibility impacts
13 in Class I areas affected by smoke from fire sources.
14
15 3.3.1 Actions to Minimize Emissions from Fire
16
17 A wide range of opportunities to minimize emissions exists depending upon the fire
18 source. Emission reduction techniques may be as simple as changing ignition timing
19 allowing for more efficient combustion. Other techniques may include the use of
20 mechanical means. Options to provide incentives and emissions goals may also serve this
21 purpose.
22
23 3.3.1.1 Emissions Reductions Techniques
24
25 Under an ESMP, provisions are made to account for emission reduction techniques that
26 are utilized when burning. Documentation of emission reduction practices that were
27 considered in the planning or implementation of burns also support annual emissions
28 goals and emissions tracking requirements. This documentation may be part of a burn
29 plan or other data collection or reporting system that is used to meet annual emissions
30 goals and emissions tracking requirements as defined in FEJF policies.
31
32 • Reducing the fuel load to be burned can reduce emissions. This can be
33 accomplished on forestland by not treating (no burning) portions of the unit,
34 yarding, consolidating, or isolating non-merchantable material; providing public
35 firewood access before the burn; finding off-site use for more of the wood before
36 the burn; using chemicals; burning when non-target fuels have a high fuel
37 moisture; using alternative mechanical treatments, and rapid mop-up.
38
39 • Burners should strive for the most efficient combustion possible. Vegetation
40 should be dry and in a condition that will minimize the smoke emitted during
41 combustion. When pile burning, material should be burned in dirt-free, not overly
42 compressed, cured, and dry piles. Piled material should be covered if possible.
43 Fires should be ignited so as to burn as rapidly as possible, in ways that shift the
44 proportion of the burn from the smoldering phase to the flaming phase.
45 Minimizing duff consumption and smoldering through fuel moisture
63
See a digest of this document in the Appendices.
ESMP Policy Draft C, 5/15/02 II - C - 25
1 considerations will reduce emissions as well. Burners should only burn those fuels
2 essential to meet resource management objectives and burn piles when other
3 burns are not feasible, such as in snow or rain.
4
5 Regulatory authorities and other interest groups may also use WRAP guidance
6 information, such as its Alternatives to Burning document that is currently under
7 development by the FEJF, as a reference for specific alternatives.
8
9 3.3.1.2 Burn Manager Qualification
10
11 Another manner in which to reduce emissions is to create a burn manager qualification
12 program that certifies the burner is knowledgeable of alternative burning practices,
13 emission reductions techniques and is capable of implementing them.
14
15 A certification and qualification process could be established by prescribing what training
16 meets requirements (such as training provided by the National Wildfire Coordination
17 Group) and by implementing training seminars and other institutional opportunities for
18 burners to gain the necessary skills and knowledge to implement proper smoke
19 management techniques. Burner certification/qualification programs may be similar to
20 those required by federal land management agencies like those offered by the National
21 Wildfire Coordination Group. For non-federal burners that cannot participate in federal
22 sponsored training, states/tribes should develop their own certification processes and host
23 training courses such as “State Forestry Prescribed Fire Correspondence Course” or an
24 “Interagency Basic Prescribed Fire Course”.
25
26 In an ESMP, burner qualifications might be required on permit applications and tracked
27 by the regulatory agency. Burn size, or emission output, might be limited depending on
28 the level of burner qualification. For example, a Level I qualified burner can burn up to
29 abc acres/tons while a Level II qualified burner can burn up to cde acres/tons, and so on.
30
31 As examples, a few types of burner qualifications are listed below:
32 • Satisfactory completion of “State Forestry Prescribed Fire Correspondence
33 Course” and direct experience in three prescribed burns prior to taking the
34 course, or satisfactory completion of the “Interagency Basic Prescribed Fire
35 Course” and direct experience in three prescribed burns before or after the
36 course.
37 • Completion of a National Wildfire Coordinating Group or Federal/state/tribe land
38 manager equivalent course dedicated to smoke management or attendance at a
39 state approved smoke management workshop.
40 • Successful completion of a training program, which includes home study, 8-hour
41 classroom session, and a written exam, documented practical experience in
42 prescribed burning, and a signed agreement to conduct all burns in compliance
43 with all applicable laws and ordinances,
44 • Land management agencies and the state/tribe develop and present interagency
45 training to promote understanding of the regulatory context and affects of air
46 pollution, fire ecology, and smoke management.
ESMP Policy Draft C, 5/15/02 II - C - 26
1
2 3.3.1.3 Incentives
3
4 Providing incentives to landowners and land managers for practicing emissions
5 reductions techniques is yet another option for states/tribes to include in ESMPs. This
6 approach could be seen as addressing equity issues in that those who make efforts to
7 reduce emissions are rewarded for their efforts. The reward to the landowner/land
8 manager could be seen in terms of environmental gains as well as financial gain. The
9 reward to communities could be seen in retaining property values, and maintaining
10 economic development and tourist-related industries.
11
12 Environmental win-win options may be that by decreasing emissions, a burner is given a
13 higher priority when allocating burn days. Or, by utilizing alternatives, a higher priority
14 is given to a burner when attempting to burn. Similarly, financial win-win options may be
15 to decrease any assessed fees or burn costs when alternatives are used before burning.
16 The system rewards those that take the extra time, effort and money to utilize emission
17 reductions and alternatives. Those who either choose not to, or for land management
18 constraints, cannot utilize emission reductions/alternatives, would pay more.
19
20 Landowners/land managers should also be afforded the opportunity to deal with other
21 sources to negotiate emissions management strategies for financial gain that would result
22 in a net emissions decrease. In January 2001, the EPA issued a policy document that
23 provides information on discretionary economic incentive programs, and guidance to
24 assist states/tribes with meeting the requirements of the Rule.64 In May 2002, the EPA
25 provided additional guidance on voluntary and backstop approaches to emissions
26 reduction in its Section 309 Annex to the Regional Haze Rule.65 In an ESMP, an
27 incentive may be available if a landowner/land manager can reduce his/her emissions and
28 gain financially from not only supplying a marketplace with raw materials, but also
29 receiving payment for emissions not generated.
30
31 3.3.1.4 Emissions Goal
32
33 Another action that could be taken by regulatory authorities to minimize emissions is to
34 establish an emissions goal within portions of a state/tribe, the entire state/tribe or over a
35 multi-state/tribe region. How to meet the goal would be left to the discretion of the
36 burners. Establishing such a goal would encourage burners to seek alternative methods
37 of burning and alternatives to burning so as to retain the ability to burn where no
38 alternatives are available.
39
40 3.3.2 Evaluation of Smoke Dispersion
41
42 A variety of tools and methods exist by which a burner could reduce smoke impacts over
43 periods ranging from several hours to several days. ESMPs could contain the following
44 criteria to support the dispersion estimation process.
64
EPA Improving Air Quality with Economic Incentive Programs (EIP Guidance), January 2001.
65
Annex to be published in the Federal Register, May 2002.
ESMP Policy Draft C, 5/15/02 II - C - 27
1
2 • States/tribes may provide or find ways to provide websites of current weather and
3 fuels information (i.e., fuel moisture) specific to meet the needs of burners. Burners
4 would utilize this information to time ignitions during periods of expected good
5 smoke dispersion.
6
7 • Acceptable weather and climatic conditions can be prescribed for burning in specific
8 areas so as to avoid impacting Class I areas. A predefined set of weather elements
9 would provide a degree of certainty as to when burning opportunities would be most
10 likely to occur. Burning should be banned during periods when air stagnation
11 advisories or air pollution alerts are in effect.
12
13 • As described previously, a burner qualification and certification program could be
14 established that includes advanced training on understanding the relationships
15 between weather and smoke dispersion. Individuals who have greater knowledge and
16 understanding of the factors affecting smoke behavior may make better decisions on
17 when and when not to burn.
18
19 • A more sophisticated and more comprehensive effort to evaluate smoke behavior
20 would be to conduct smoke dispersion modeling in the planning process for burning.
21 Such modeling results could be used as a screening approach to determine if there
22 should be extra reason for concern about the proposed burn(s). This approach may
23 assist in determining cumulative effects of multiple burns.
24
25 • Centralized decision-making of burn decisions with coordination among burners
26 (either by source type or between sources) would require a more intensive effort of
27 involvement by groups involved in burning. Burners would check-in with a
28 centralized burn authority to receive information about other source activity prior to
29 conducting a burn.
30
31 • A rigorous, centralized decision-making system established with the intent of
32 providing "go/no-go" decisions affords a greater level of coordination that would rely
33 on greater infrastructure and resources for support. Meteorologists and other
34 specialists with knowledge of air quality, fire, weather and fuels interaction would
35 provide services that direct where and when burning could occur.
36
37 3.3.3 Alternatives to Fire
38
39 Alternatives to fire (not alternative methods of burning) should be addressed in all
40 ESMPs. The minimal consideration in the ESMP is that states/tribes provide information
41 on alternatives to fire. The FEJF has conducted landowner/land manager studies of
42 alternatives and is providing guidance discussing the results. States/tribes should
43 establish websites with information describing the alternatives.
44
45 Burners may be required to assess the feasibility of using alternatives to fire where there
46 are many competing sources or large amounts of burning occurring. Burn plans and data
ESMP Policy Draft C, 5/15/02 II - C - 28
1 systems could contain information that helps track the practice of using alternatives to
2 fire. Emissions tracking systems and reasonable further progress assessments could use
3 this information to validate landowner/land manager's implementation of alternative
4 practices as an emissions reduction technique.
5
6 Sources of smoke from geographic areas that continue to adversely affect a mandatory
7 Class I area's 20% worst and best days, according to the Rule, may be required to
8 implement measures that utilize alternatives to burning to the maximum extent feasible as
9 a condition of further burning. Incentives should be identified wherein land owners/land
10 managers have the opportunity to offset emissions not produced in one area for emissions
11 produced in another geographic area not affecting a Class I area's visibility as long as
12 there is a net emissions decrease as a result of using the alternatives.
13
14 Geographic areas with sustained sources of adverse smoke impacts in mandatory Class I
15 areas may consider burn curtailments if programs to minimize emissions, impacts and
16 alternatives to fire use do not provide the necessary tools to meet reasonable progress
17 toward the natural visibility goal. Such actions should be considered on a fire source
18 basis so as to not impair one source's ability to use fire because of the failure of another
19 source type to take needed actions to meet the natural visibility goal.
20
21 3.3.4 Public Notification of Burning
22
23 Public notification is a significant part of the Clean Air Act, and is inherent in the
24 Regional Haze Rule. Public notification under an ESMP should be at least what is
25 required by EPA for a certifiable smoke management program, and may include extra
26 activities, depending on location. Generally, regardless of what kind of smoke
27 management program is in place, significant effort should be made to educate and notify
28 the public about burning, its impacts as well as its benefits.
29
30 Public notification consists of activities such as issuing notices through the local news
31 media including name and phone number of person/agency, fuel type, expected time and
32 date of burn, and location of burn. Other means of notification may include the use of a
33 website, public open houses or meetings, signs at burn sites, distribution of fact sheets,
34 brochures, posters, notices, personal contact by phone or visit, or legal advertisements. It
35 is a good practice to maintain a contact list of interested and affected publics, and make
36 sure that notification of planned burns gets to everyone on that list. A plan for notifying
37 the public should be part of the burn plan.
38
39 Maintaining a website for displaying and providing access to data and real-time
40 information on burn activity is strongly advised for ESMPs. Such a website would assist
41 with regional coordination efforts implemented in ESMPs.
42
43 Public education and outreach should be a major part of any smoke management
44 program. Such activities should focus on smoke impacts from fire and should include
45 information on specific air criteria for specific location, fact sheets, pamphlets, media
46 stories, and websites. Maintaining a burning calendar on a website is helpful in
ESMP Policy Draft C, 5/15/02 II - C - 29
1 informing the public of planned burning activities. Public awareness and education
2 activities may be conducted by states/tribes, burners, or in cooperation by all.
3
4 Effective public involvement, notification, and education can decrease complaints and
5 resistance to burning projects, as well as prepare the public to manage their activities
6 around scheduled burns. Public notification and education activities can also increase the
7 public’s faith in the different agencies and landowners, knowing that their health and
8 welfare is being carefully considered in both planning and implementation. A well-
9 developed public education and awareness program would not only serve the public but
10 also fulfills a Recommendation from the GCVTC.
11
12 Training and guidance in public notification techniques should be provided to burners not
13 accustomed to conducting such work, i.e., non-federal burners. Program administrators
14 might consider developing an in-state/tribe public notification process to assist the non-
15 federal burners. Programs should strive to enhance non-federal burners’ ability to involve
16 public in planning by providing training and guidance, or open forums for disseminating
17 information on planed burning activities. If the public is involved in planning of such
18 activities regarding potential affects to them, there is less chance of resistance to the burn
19 while it is in progress.
20
21 Finally, developing involvement by the community, and participation by burners, in the
22 SIP/TIP and NEPA planning processes may be beneficial in developing common
23 expectations.
24
25 3.3.5 Air Quality Monitoring
26
27 Monitoring of smoke impacts may be a very sophisticated effort using sampling
28 equipment and extensive modeling or it may be as simple as creating a log of smoke
29 behavior.
30
31 Minimal procedures would be most likely in areas of less burn activity or when farther
32 away from Class I areas. On-site record keeping with subsequent submittal to the
33 state/tribe regulatory authority should be substantive enough for use in analysis of
34 reasonable further progress tracking or emissions reduction programs.
35
36 As burning activity increases, states/tribes should consider conducting a more widespread
37 and comprehensive monitoring program. States/tribes should consider the use of
38 cameras, satellite imagery and aerial monitoring to track and document smoke
39 movement. Using IMPROVE monitored data may have to be supplemented by air quality
40 monitoring outside of Class I areas to track smoke movement.
41
42 Also, using visitor surveys in Class I areas regarding visibility impairment perceived
43 during their stay may be a way of generating subjective assessments of smoke impacts.
44 Such information would only be used to provide further validation of impacts, as relying
45 on surveys alone would be too subjective for states/tribes to administer reasonable smoke
46 management programs.
47
ESMP Policy Draft C, 5/15/02 II - C - 30
1 3.3.6 Surveillance and Enforcement
2
3 A good working relationship between regulators and burners can significantly reduce the
4 need for surveillance and enforcement. An atmosphere of trust and cooperation between
5 regulators and burners can go a long way toward facilitating emissions reductions and
6 compliance with air quality regulations.
7
8 Four primary methods under which surveillance and enforcement activities may occur
9 are:
10 • Burner self-enforcement (i.e., peer pressure)
11 • Source sector regulator (e.g., Agricultural Burn Manager, Smoke Management
12 Meteorologist)
13 • State/tribe oversight
14 • Centralized regulatory authority
15
16 Criteria and activities described below may be applicable for use in any of the four
17 methods. Some of the criteria can, obviously, only be enforced by a body that has legal
18 standing to do so. Whichever of the four methods a state/tribe may choose to implement
19 would be dependent upon the severity of the visibility impacts that are being addressed.
20
21 If states/tribes have regulations in place that govern nuisance smoke, public complaints
22 can serve to monitor compliance. Such regulations should define criteria for establishing
23 “nuisance” smoke. The number and location of public complaints may be used to monitor
24 air quality impacts of fires. In other cases, the number of complaints may not necessarily
25 be a trigger, rather the nature of the complaints and external verification of circumstances
26 leading to the complaints. In some cases, nuisance regulations may apply only to non-
27 certified burning. In such cases certified burners cannot be shutdown for nuisance
28 complaints, but can be shut down for a threat to health or safety. Some criteria for taking
29 action on smoke impacting visibility include:
30 • Is the visibility reduction (impact) occasional or constant?
31 • Is the use of property affected?
32 • What are the economic impacts?
33 • Is the location of the impact within or outside of a Class I area?
34 • What is the number of people affected?
35 • How many complaints have been received?
36 • Has the visibility impact been mitigated to the extent practicable?
37 • Is the public health threatened?
38
39 If no such visibility impact-related regulations are in place, violation of NAAQS or
40 violation of other codified permit conditions or authorizations might trigger enforcement
41 actions. Generally, a written report or warning is issued on the first instance of violation,
42 while subsequent observed violations result in appropriate legal action.
43
44 Criteria of performance standards in an ESMP must be stated clearly. Methods for
45 detecting non-compliance should also be defined. Some criteria or standards might
46 include:
ESMP Policy Draft C, 5/15/02 II - C - 31
1 • Numerical standards for optical data at specific Class I areas (e.g., deciviews)
2 • NAAQS
3 • Comparison with photos taken of certain pre-determined visibility conditions
4 (most impaired, least impaired days)
5
6 Accordingly, some methods for detecting compliance might include:
7 • IMPROVE sites
8 • Photo points
9 • NAAQS ambient air monitors
10
11 If performance standards are established in code, random audits and inspections can
12 provide assistance with compliance. Unannounced burn inspections and burn report
13 audits, including smoke dispersion information, are means of ensuring compliance with
14 air quality regulations. Aerial observations are another surveillance method.
15
16 Enforcement actions must be based on established statute and regulation, and must be
17 applied equitably to all burners. Depending on state/tribe needs and compliance history,
18 warning letters may be sent after the first instance of non-compliance or violation,
19 followed by more formal legal action.
20
21 Example enforcement actions in more comprehensive programs may include:
22 • 5-day moratorium on ignitions
23 • Civil/criminal penalties, depending on how regulations are written
24 • Burn shutdown/mop-up
25 • Notice of violation/compliance order
26 • Liability for cost of suppression or damages
27 • Revocation of permit
28 • Felony punishment for willful or intentional violation
29 • Misdemeanor for careless violation
30
31 3.3.7 Program Evaluation
32
33 Periodic program evaluation is a requirement of the Regional Haze Rule. Both Sections
34 308 and 309 require periodic reports describing progress towards meeting "reasonable
35 further progress" goals. It would be incumbent upon the state/tribe to submit progress
36 reports to EPA describing how well the ESMP is being implemented as part of meeting
37 reasonable further progress requirements. Formal periodic progress report intervals could
38 coincide with time intervals used to evaluate reasonable progress. The Regional Haze
39 Rule66 requires progress reports every 5 years. However, shorter review and evaluation
40 time periods would better determine if ESMP criteria that have been implemented are
41 effective.
42
66
64 FR 35768, § 51.308 (g) and 35772, § 51.309 (d) (10).
ESMP Policy Draft C, 5/15/02 II - C - 32
1 Generally, daily interaction between burners and program administrators can provide a
2 continuous means of program evaluation, but a formal method should be in place to
3 document periodic evaluations.
4
5 Annual evaluations of the overall smoke management program will provide the
6 information needed for periodic reports. Each element of the ESMP should consider
7 evaluating:
8 • Implementation
9 • Compliance and enforcement
10 • Sections needing clarification or improvement
11 • Progress towards goals
12 • Recommendation for revisions
13 • Additional modeling or other technological needs
14
15 These annual evaluations could include, but not be limited to:
16 • An accounting of progress towards defined visibility improvement/impact
17 reduction goals
18 • An accounting of progress towards emissions reductions goals
19 • Review of project burning for the next year, as well as additional out-year
20 planning
21 • Regional information, considering visibility impacts to and from adjoining
22 states/tribes
23 • Burn activity summaries
24 • Burning restrictions or air quality alerts
25 • Significant smoke intrusions or visibility impacts
26 • Summaries of IMPROVE and other monitored air quality data
27 • Emission inventory summaries
28 • Information tracking summaries
29 • Smoke complaint summaries
30 • Discussion of alternatives to burning
31
32 In an ESMP, federal land managers responsible for protecting air quality related values in
33 Class I areas should be given the opportunity to provide input to annual program
34 evaluations.
35
36 Where MOUs or other agreements govern smoke management programs, an annual
37 meeting should be held where members share successes and failures, data is summarized
38 and the program is evaluated. In cases where review criteria are established in state code,
39 performance can be compared against standards. Permit files may be kept for a period of
40 time, including complaint files, and statistics generated to evaluate trends in the program.
41
42 3.3.8 Burn Authorization
43
44 Burn authorization requirements are expected to vary depending upon the amount of
45 burning that is occurring, the fire source types that are conducting the burning, and the
ESMP Policy Draft C, 5/15/02 II - C - 33
1 degree of impairment that exists or may be expected to occur as a result of the burning.
2 The proximity of non-attainment areas may also have a bearing on the complexity of the
3 burn authorization procedure that should be implemented. Four broad levels of
4 stringency may be considered in the development and adoption of an ESMP.
5 • Establish a permit-by-rule system
6 • Establish a burn permitting system by source sector
7 • Establish a centralized burn authority
8 • Establish a regional burn authority
9
10 Establishment of any of these authorization situations would also entail the development
11 of coordination procedures described in Section 4.3.9, below.
12
13 3.3.8.1 Permit-by-Rule
14
15 The AAQTF Recommendation on Air Quality Policy describes a process in which a set
16 of requirements are established under which burning may take place. These requirements
17 may include acreage, time of year, time of day and meteorological factors.67 A written
18 permit may or may not be required. As long as the conditions are met, then burning may
19 occur. There is no daily decision-making by a coordinating authority in this scenario.
20
21 Such a system may be applicable for any fire source type in geographic areas of low fire
22 use. This system should, however, still allow for the collection of enough information by
23 an appropriate regulatory authority so that source activity and emissions may be tracked.
24
25 3.3.8.2 Burn Permitting System
26
27 A burn permitting system that is established by fire source type would include a local
28 burn manager whose responsibility is to develop the conditions under which burning may
29 occur and then ensure that burning occurs within the requirements that are established.
30 The criteria and elements described in this Policy would be implemented by the burn
31 manager to ensure that visibility in Class I areas is protected.
32
33 3.3.8.3 Centralized Burn Authority
34
35 A more intensive level of smoke management would involve the creation of a centralized
36 authority that provides daily coordination and approval of burns if significant state/tribe-
37 wide burning is occurring. The centralized authority may be responsible for activities of
38 one particular source type or a combination of sources. This type of program should
39 include the detailed use of meteorological information, burn information and a permitting
40 system to avoid cumulative impacts of smoke from a variety of burns.
41
42
43
44
67
AAQTF Recommendation on Air Quality Policy, p.9.
ESMP Policy Draft C, 5/15/02 II - C - 34
1 3.3.8.4 Regional Burn Authority
2
3 Establishment of a regional burn authority may be required if there are continued and
4 extensive inter-state impacts from burning. States/tribes would agree to have oversight of
5 burning by an authority that equitably considers burning opportunities for all source types
6 while addressing the Class I area impacts over broad areas. A regional burn authority
7 would likely, in most cases, be working with the most severe and persistent problems.
8
9 3.3.9 Regional Coordination
10
11 Coordination of burning activity is critical to avoiding cumulative impacts within and
12 across source types. Coordination may range from a passive mode of information sharing
13 between burners and/or the public to a more complex, active coordination in which burn
14 decisions are altered based on other activities that are occurring or have recently
15 occurred.
16
17 Coordination can occur at locations that reflect the affected level of concern. When
18 burns are located near Class I areas or non-attainment areas, coordination will be carried
19 out at a level that is appropriate. If burns are located adjacent to state/tribe boundaries,
20 coordination will occur appropriate to the smoke transport/emission path and quantity.
21
22 A common mode of coordination regardless of the complexity and magnitude of burning
23 would be information sharing via use of the web. Operationally, certain information
24 needs to be established and updated as needed. This would include:
25 • Burn information (size, location, ignition date, etc.)
26 • Names and locations of sensitive receptors; sensitive receptors should include
27 sensitive populations
28 • Locations of monitors (state, tribe, EPA or local)
29 • Database of known significant user of fire (name, phone number)
30 • Identification of airsheds or air administered units
31 • Possible identification of Clean Air Corridors
32 • Updateable database of non-attainment and maintenance areas for criteria
33 pollutants of concern
34
35 A minimal level of coordination would include the use of websites to post burn activity.
36 This passive mode of coordination would be used regardless of the burn authorization
37 method that is in place in a particular geographic area. Burners and regulators could use
38 this information to encourage and promote voluntary coordination among burners. Burn
39 locations and weather conditions may be posted or linked at a common webpage or series
40 of webpages.
41
42 3.3.9.1 Source Sector Authority Coordination
43
44 A more advanced coordination concept is that of using burn managers or smoke
45 coordination centers to actively time burning to avoid cumulative smoke impacts from
46 burns within a source sector. In addition to creating awareness of other sectors' burning
ESMP Policy Draft C, 5/15/02 II - C - 35
1 via tracking information on the web, radio or phone communications would be used to
2 distribute that burning information to burners.
3
4 A step further in this process is active management of burning with coordination
5 occurring between burn managers of different source types. Considerations that would
6 be taken into account by the burn managers are parameters such as special weather
7 conditions needed for a particular burn, fire safety considerations, etc. These
8 considerations can be identified in the early periods of burn planning so that all parties
9 are aware of the rationale behind burn decisions.
10
11 3.3.9.2 Centralized Authority Coordination
12
13 A centralized coordination authority within a state/tribe provides for a greater level of
14 control of smoke production and reduction of impacts. In this scenario, potential
15 state/tribe-wide impacts may be better managed and problems avoided than is the case
16 with more fragmented coordination points. Central authorities for each source type
17 would coordinate activities or one central authority would coordinate activities across all
18 source types. In most cases this coordination would occur through a statewide
19 coordination center that has access to information from all burning sources. Such a
20 coordination center would also be more likely to have sophisticated meteorological, air
21 quality, modeling and fire behavior and effects expertise upon which decisions would be
22 made.
23
24 3.3.9.3 Regional (Multi-State/Tribe) Coordination
25
26 Burning that creates inter-jurisdictional impacts may require the establishment and use of
27 multi-state/tribal coordination information procedures. If states’/tribes’ Class I areas are
28 consistently and measurably being impacted by smoke from outside of their own
29 boundaries, then more information sharing may be needed on day-to-day burning
30 activities. State/tribe centralized coordination centers would share information and
31 resources to limit cumulative impacts from external sources as well as from those within
32 its own boundaries.
33
34 Each state’s/tribe’s central coordination center would prioritize burns in areas that would
35 be most likely to create cross-jurisdictional impacts. On a regional basis, acres or
36 emissions may be limited by each state’s/tribe’s burn authority to minimize air quality
37 impacts in neighboring areas. Regional meteorological and air quality information would
38 be shared by coordination centers, with the result being regional approval and real-time
39 tracking of burns and their smoke impacts.
40
41 A segment of fires that are considered to be natural under the WRAP Fire Categorization
42 Policy may best be suited for regional coordination opportunities. Such fires are more
43 likely to be of longer duration and have the greater potential for generating regional haze.
44 Coordination in this case may range from monitoring smoke from such fires and
45 reporting impacts to nearby states/tribes, to limiting other burning until the smoke from
46 the natural fires has abated.
ESMP Policy Draft C, 5/15/02 II - C - 36
1
2
3
4
5
6
7
8
9
10
11 APPENDICES
12
13
14
15
16
ESMP Policy Draft C, 5/15/02 II - C - 37
1 Appendix A
2 Glossary
3
4 * Operating Definitions from Section 1.1 of the WRAP FEJF Workplan, February 25,
5 1999.
6 # Operating Definitions from the WRAP Policy for Categorizing Fire Emissions,
7 November 15, 2001.
8
9 Agricultural Fire/Burning* - Any fire ignited by management actions to meet specific
10 objectives (i.e., managed to achieve resource benefits) on agricultural land.
11
12 Agricultural Land* - Agricultural land includes croplands, pasture, and other lands on
13 which crops or livestock are produced (PL 104-127, Section 1240A). Rangeland will be
14 included with wildland for the purposes of the Fire Emissions Joint Forum work.
15
16 Alternatives To Burning – Land management practices that treat fuel without using fire.
17
18 Anthropogenic - Produced by human activities.
19
20 Anthropogenic Emissions Source Classification (“anthropogenic”)# - A categorization
21 that designates which fire emissions contribute to visibility impairment in a Federal Class
22 I area. “Anthropogenic” emissions must be controlled to achieve progress toward the
23 2064 natural conditions goal [i.e., natural visibility goal] for each Federal Class I area in
24 the WRAP region. This classification includes natural and human-caused ignitions.
25
26 Area Source - A source category of air pollution that generally extends over a large area.
27 Prescribed burning, field burning, home heating, and open burning are examples of area
28 sources.
29
30 Attainment Area - An area considered to have air quality as good as or better than the
31 national, state/tribe or local ambient air quality standards. Note that an area may be in
32 attainment for one or more pollutants but be a non-attainment area for one or more other
33 pollutants.
34
35 Best Available Control Measures (BACM) - A term used to refer to the most effective
36 measures (according to EPA guidance) for controlling small or dispersed particulates and
37 other emissions from sources such as roadway dust, soot and ash from woodstoves and
38 open burning of rush, timber, grasslands, or trash.
39
40 Best Management Practices (BMPs) – A term applied collectively to any administrative
41 or on-the-ground procedure that reduces the negative impacts of some action. An
42 example of a Best Management Practice with respect to air quality would be conducting a
43 prescribed burn when atmospheric ventilation is good, which in turn promotes smoke
44 dispersal.
45
46 Class I Area – See Mandatory Class I Area and Non-Mandatory Class I Area.
ESMP Policy Draft C, 5/15/02 II - C - 38
1 Control of Fire Emissions# - Actions may be taken to control fire emissions by utilizing
2 best management practices such as the use of alternatives, biomass utilization, and other
3 emission reduction techniques.
4
5 Criteria Pollutants - The 1970 amendments to the Clean Air Act required EPA to set
6 National Ambient Air Quality Standards for certain pollutants known to be hazardous to
7 human health. EPA has identified and set standards to protect human health and welfare
8 for pollutants: ozone, carbon monoxide, particulate matter (PM10 and PM2.5), sulfur
9 dioxide, lead, and nitrogen oxide. The term, "criteria pollutants" derives from the
10 requirement that EPA must describe the characteristics and potential health and welfare
11 effects of these pollutants. It is on the basis of these criteria that standards are set or
12 revised.
13
14 Cumulative Effects – The effect on the environment that results from the incremental
15 impact of the action when added to other past, present, and reasonable foreseeable future
16 actions regardless of what agency, entity or person undertakes such action. Cumulative
17 effects can result from individually minor but collectively significant actions taking place
18 over a period of time.
19
20 Deciview - a unit of visibility proportional to the logarithm of the atmospheric extinction.
21 Under many circumstances a change in one deciview will be perceived to be the same on
22 clear and hazy days.
23
24 Ecosystem Maintenance# – A prescribed fire or wildfire managed for resource benefits, in
25 an ecosystem that is currently in an ecologically functional and fire resilient condition,
26 that is utilized to mimic the natural role of fire.
27
28 Ecosystem Restoration# – The re-establishment of natural vegetation that may be
29 accomplished through the reduction of unwanted and/or unnatural levels of biomass,
30 which may have accumulated due to management action. Prescribed fires, wildfires
31 managed for resource benefits and mechanical treatments may be utilized to restore an
32 ecosystem to an ecologically functional and fire resilient condition.
33
34 Emission - pollution discharged into the atmosphere. Examples of emissions sources are
35 smokestacks, other vents, and surface areas of commercial or industrial facilities; from
36 residential chimneys; and from motor vehicle, locomotive, aircraft, or other non-road
37 engines.
38
39 Emission Inventory - A listing, by source, of the amount of air pollutants discharged into
40 the atmosphere.
41
42 Emissions Goal/Cap – The concept of placing a limit on the total amount of emissions
43 generated in a year or an extended time period (e.g., 10 years).
44
45 Emission Reduction – A strategy for controlling smoke from prescribed fires that
46 minimizes the amount of smoke output per unit of area treated.
ESMP Policy Draft C, 5/15/02 II - C - 39
1 Enhanced Smoke Management Program (ESMP) – A program for fire that considers
2 visibility effects, in addition to health and nuisance objectives, and is based on the criteria
3 of efficiency, economics, law, emission reduction opportunities, management objectives,
4 and reduction of visibility impact.
5
6 Federal Class I area – see Class I Area.
7
8 Fire* -- When this term appears, it refers inclusively to wildfire, prescribed natural
9 fire/wildland fire managed for resource benefits, prescribed fire, rangeland fire, and
10 agricultural fire.
11
12 Fire Source – See Fire Source Sector.
13
14 Fire Source Sector – a segment of fire attributed to a particular management or
15 ownership, e.g., wildland prescribed fire, agricultural prescribed fire, wildfire, and
16 wildland fire use.
17
18 Fire Use – A term utilized in federal land management that includes both prescribed fire
19 and wildland fire use.
20
21 Fuel Moisture Content -- The quantity of moisture in fuel expressed as a percentage of
22 the weight when thoroughly dried at 212 degrees F.
23
24 Fuel Reduction – The manipulation, including combustion, or removal of fuels to reduce
25 the likelihood of ignition and/or to lessen potential damage and resistance to control.
26
27 Fuel Treatment - Manipulation or removal of fuels to reduce the likelihood of ignition
28 and/or to lessen potential damage and resistance to control (e.g., lopping, chipping,
29 crushing, piling and burning).
30
31 Jurisdiction – A geographic area of authority.
32
33 Land Managers* - When this term appears, it refers inclusively to federal, state, tribal,
34 and private land managers.
35
36 Manage Fire Emissions# - Actions may be taken to manage fire emissions to minimize
37 impacts on visibility, public health, and nuisance concerns. Some management actions
38 include concepts such as the timing of ignitions for better dispersion and consideration of
39 downwind air quality and visibility. It may also include consideration of factors related to
40 the area to be burned such as the fuel moisture condition and other physical parameters.
41 Manage fire emissions is analogous to smoke management.
42
43 Mandatory Class I Area – An area set aside under the Clean Air Act to receive the most
44 stringent protection from air quality degradation. Mandatory Class I Federal Areas are (1)
45 international parks, (2) national wilderness areas and memorial parks larger than 5,000
46 acres in size, (3) national parks that exceed 6,000 acres in size and which were in
ESMP Policy Draft C, 5/15/02 II - C - 40
1 existence when the 1977 Clean Air Act amendments were enacted. The extent of a
2 mandatory Class I Federal area includes subsequent changes in boundaries, such as park
3 expansions.
4
5 Modeling – The artificial simulation of some event or action that has quantifiable results.
6 Mathematical expressions and computers are frequently used in modeling.
7
8 National Ambient Air Quality Standards (NAAQS) - See Criteria Pollutants.
9
10 National Environmental Policy Act (NEPA) – Establishes procedures that federal
11 agencies must follow in making decisions on federal actions that may impact the
12 environment.
13
14 National Visibility Goal – See Natural Visibility Goal.
15
16 Natural Background Condition# - An estimate of the visibility conditions at each Federal
17 Class I area that would exist in the absence of human-caused impairment.
18
19 Natural Emissions Source Classification (“natural”)# - A categorization that designates
20 which fire emissions can result in a natural reduction of visibility for each Federal Class I
21 area in the WRAP region. This classification includes natural and human-caused
22 ignitions.
23
24 Natural Ignition# - Fire/Burn ignited due to a natural (i.e., non-human-caused) event, e.g.,
25 fire ignited by lightning or volcanic eruption.
26
27 Natural Visibility Goal – The ultimate goal of the regional haze program is the absence of
28 visibility impairment due to human-caused emissions.
29
30 Non-Attainment Area (NAA) – An area identified by an air quality regulatory agency
31 through ambient air monitoring (and designated by the Environmental Protection
32 Agency) that presently exceeds federal, state/tribe or local ambient air quality standards.
33 See Attainment Area above.
34
35 Non-Mandatory Class I Areas -- Class I areas designated by states or tribes, but are not
36 deemed mandatory by the Clean Air Act. As of January 2002, these include: Fort Peck
37 Reservation in MT, Northern Cheyenne Reservation in MT, Flathead Reservation in MT,
38 Yavapai-Apache Reservation in AZ (Class I status under litigation), and Spokane
39 Reservation in WA.
40
41 Nuisance Smoke – Unwanted smoke that does not exceed National Ambient Air Quality
42 Standards primarily for particulate matter.
43
44 Particulate Matter - Any liquid or solid particles. "Total suspended particulates" as used
45 in air quality are those particles suspended in or falling through the atmosphere. They
46 generally range in size from 0.1 to 100 microns.
ESMP Policy Draft C, 5/15/02 II - C - 41
1
2 Plume Blight - Visual impairment of air quality that manifests itself as a coherent plume.
3
4 PM10 - Particulate matter of aerodynamic diameter less than or equal to 10 micrometers.
5 Emissions of PM10 are significant from fugitive dust, power plants, commercial boilers,
6 metallurgical industries, mineral industries, forest and residential fires, and motor
7 vehicles.
8
9 PM2.5 - Particulate Matter of aerodynamic diameter less than or equal to 2.5 micrometers.
10 A measure of fine particles of particulate matter that come from fuel combustion,
11 agricultural burning, woodstoves, etc.
12
13 Point Source - A source of pollution that is point-like in nature. An example is the smoke
14 stack of a coal-fired power plant or smelter. See Source.
15
16 Prescribed Fire* - Any fire ignited by management actions to meet specific objectives,
17 i.e., managed to achieve resource benefits.
18
19 Rangeland# - Land on which the historic climax plant community is predominantly
20 grasses, grass-like plants, forbs, or shrubs. Includes lands re-vegetated naturally or
21 artificially when routine management of that vegetation is accomplished mainly through
22 manipulation of ecological principles. Rangeland includes natural grasslands, savannas,
23 shrub lands, most deserts, tundra, alpine communities, coastal marshes and wet meadows
24 (Natural Resources Conservation Service National Range and Pasture Handbook, 1997.)
25
26 Regional Haze - Visibility impairment caused by the cumulative air pollutant emissions
27 from numerous sources over a wide geographic area.
28
29 Smoke Effects* - The effects on visibility (both plume blight and regional haze), public
30 nuisance, and the health-based NAAQS due to emissions from fire.
31
32 Smoke Intrusion - Smoke from prescribed fire entering a designated area at unacceptable
33 levels.
34
35 Smoke Management Efforts – Programs, practices and techniques to minimize and/or
36 reduce smoke emissions or impacts from fire.
37
38 State Implementation Plan (SIP)# - Plans devised by states to carry out their
39 responsibilities under the Clean Air Act. SIPs must be approved by the U.S.
40 Environmental Protection Agency and include public review. (See also Tribal
41 Implementation Plan -- TIP)
42
43 Suppression – A management action intended to protect identified values from a fire,
44 extinguish a fire, or alter a fire’s direction of spread.
45
ESMP Policy Draft C, 5/15/02 II - C - 42
1 Tribal Implementation Plan (TIP)# -- Plans devised by tribes to carry out their
2 responsibilities under the Clean Air Act. TIPs must be approved by the U.S.
3 Environmental Protection Agency and include public review. (See also State
4 Implementation Plan – SIP)
5
6 Wildfire* - Any unwanted, non-structural fire.
7
8 Wildfire Managed for Resource Objectives # - The management of naturally ignited fires,
9 regardless of land type or ownership, to accomplish specific, pre-stated resource
10 management objectives in predefined geographic areas with or without a plan in place.
11 This term is considered to be analogous with the terms Wildland Fire Managed for
12 Resource Benefits and Prescribed Natural Fire that are used in regulations and policies
13 regarding federal wildlands.
14
15 Wildland*- An area where development is generally limited to roads, railroads, power
16 lines, and widely scattered structures. The land is not cultivated (i.e., the soil is disturbed
17 less frequently than once in 10 years), is not fallow, and is not in the USDA Conservation
18 Reserve Program (CRP). The land may be neglected altogether or managed for such
19 purposes as wood or forage production, wildlife, recreation, wetlands, or protective plant
20 cover (EPA Interim Air Quality Policy on Wildlands and Prescribed Fires). The land is
21 not “agricultural land” as operationally defined above. Silvicultural land and rangelands
22 (per the FEJF charge), woodlots, and private timberlands will be included with wildlands
23 for the purposes of the FEJF work.
24
25 Wildland Fire# - All types of fire (see definition of fire above), except fire on agricultural
26 land.
27
28 Wildland Fire Managed for Resource Benefits/Prescribed Natural Fire* - These terms
29 both have current use in regulations and policies. They are considered to be synonymous
30 and are used interchangeably in this work plan. These terms refer to the management of
31 naturally ignited fires to accomplish specific, pre-stated resource management objectives
32 in predefined geographic areas outlined in the fire management plan.
33
34 Wildland Fire Use – See Wildland Fire Managed for Resource Benefits/Prescribed
35 Natural Fire.
ESMP Policy Draft C, 5/15/02 II - C - 43
1 Appendix B
2 Related Documents Listing
3
4 Regional Haze Rule
5 Published in the Federal Register on July 1, 1999, 64 FR 35714.
6 http://www.epa.gov/ttn/oarpg/t1/fr_notices/rhfedreg.pdf
7
8 Grand Canyon Visibility Transport Commission Report
9 Grand Canyon Visibility Transport Commission, Recommendations for Improving
10 Western Vistas, Report to the U.S. EPA, June 10, 1996.
11 http://www.wrapair.org Go to the GCVTC link.
12
13 EPA Interim Air Quality Policy on Wildland and Prescribed Fire
14 U.S. EPA, Office of Air Quality Planning and Standards, Interim Air Quality Policy on
15 Wildland and Prescribed Fires, April 23, 1998.
16 http://www.epa.gov/ttn/oarpg/t1/memoranda/firefnl.pdf
17
18 AAQTF Recommendation on Air Quality Policy
19 Agricultural Air Quality Task Force, Air Quality Policy on Agricultural Burning,
20 Recommendation to the U.S. Department of Agriculture, November 10, 1999.
21 http://fargo.nserl.purdue.edu/faca/Archives/2000/Policy/Burning%20Policy.htm
22
23 WRAP Policy for Categorizing Fire Emissions
24 Approved by the Western Regional Air Partnership, November 15, 2001.
25 http://www.wrapair.org/commindex.htm Go to the Fire Emissions Joint Form Task
26 Teams, then Natural Background.
27
28 Wildland Fire: Elements of a Basic Smoke Management Program Draft Report
29 Completed for the FEJF on July 10, 2001.
30 http://www.wrapair.org/commindex.htm Go to the Fire Emissions Joint Form Task
31 Teams, then Basic Smoke Management.
32
33 Smoke Management Program Surveys
34 http://www.wrapair.org/commindex.htm Go to the Fire Emissions Joint Form Task
35 Teams, then Basic Smoke Management.
36 1) Wildland Smoke Management Program Survey, January 26, 2001
37 2) Boulder Wildland Smoke Management Program Survey, February 2, 2001
38 3) Agricultural Burning Smoke Management Program Survey, March 30, 2001
39 4) An Assessment of Tribal Air Quality Data and Programs in the Western United States,
40 The Institute for Tribal Environmental Professional (ITEP), September 2001
41
42 Class I Area Map
43 http://www.wrapair.org Go to the WRAP Boundaries and Regional Visibility Planning in
44 the West.
ESMP Policy Draft C, 5/15/02 II - C - 44
1 Appendix C
2 Related Documents Excerpts
ESMP Policy Draft C, 5/15/02 II - C - 45
1
Grand Canyon Visibility Transport Commission:
Recommendations for Improving Western Vistas
to the United States Environmental Protection Agency
June 1996
2
3 EXECUTIVE SUMMARY
4
5 The Colorado Plateau's national parks and wilderness areas provide a unique, panoramic
6 visual experience for people from around the world. This experience depends on
7 maintaining high visual air quality in the region, which is threatened by haze resulting
8 from projected growth over the next fifty years. Congress has set a national goal of
9 remedying existing human-caused visibility impairment, and preventing future
10 impairment, at these national parks and wilderness areas. Congress recognized that not all
11 haze is human-caused and that haze is a regional issue. Congress created the Grand
12 Canyon Visibility Transport Commission in 1991 to advise the U.S. Environmental
13 Protection Agency on strategies for protecting visual air quality at national parks and
14 wilderness areas on the Colorado Plateau. The Commission established a Public Advisory
15 Committee (PAC) to obtain broad input as it formulated these strategies.
16 The Commission conducted an extensive review of scientific, technical, and other
17 information with assistance from a range of governmental, business, tribal, and
18 environmental interests. It developed more comprehensive databases, and new computer
19 modules to analyze these data and model future air quality. The Commission significantly
20 advanced understanding of regional haze, but limitations and uncertainties remain. Based
21 on that information and its own deliberations, the PAC developed a set of emissions
22 management recommendations for the Commission with a full understanding of progress
23 and limitations in available knowledge. These recommendations are aimed at protecting
24 clear days and reducing dirty days at national parks and wilderness areas on the Colorado
25 Plateau. Following a series of public meetings in April 1996, the PAC and Operations
26 Committee conducted a final review and approval of these recommendations and
27 forwarded them to the Commission for action. The Commission formally considered the
28 PAC and Operations Committee reports on June 10, 1996 and approved them as the
29 Commissions report to the Environmental Protection Agency. The EPA should use the
30 Commission's recommendations as guidance for developing national strategies and/or
31 rulemaking. Implementation of all specific program components will remain the
32 responsibility of tribes, states and their political subdivisions, and, in some cases, federal
33 agencies.
34 Some of the Commission's recommendations ask the EPA to take specific actions or
35 institute particular programs, in cooperation with the tribes, states and federal agencies as
36 implementing bodies. Other recommendations provide a range of potential policy or
ESMP Policy Draft C, 5/15/02 II - C - 46
1 strategy options for consideration by the EPA and implementing entities. As the EPA
2 develops policies and takes actions based on this report, this distinction between
3 "actions" and "options" should be maintained with diligence. That is, recommendations
4 intended as policy options should not become mandated actions or regulatory programs.
5 The primary recommendations include:
6 • Air Pollution Prevention. Air pollution prevention and reduction of per capita
7 pollution is a high priority for the Commission. The Commission recommends
8 policies based on energy conservation, increased energy efficiency and promotion
9 of the use of renewable resources for energy production.
10 • Clean Air Corridors. Clean air corridors are key sources of clear air at Class I
11 areas, and the Commission recommends careful tracking of emissions growth that
12 may affect air quality in these corridors.
13 • Stationary Sources. For stationary sources, the Commission recommends closely
14 monitoring the impacts of current requirements under the Clean Air Act and
15 ongoing source attribution studies. Regional targets for SO2 emissions from
16 stationary sources will be set, starting in 2000. If these targets are exceeded, this
17 would trigger a regulatory program, probably including a regional cap and
18 market-based trading. During the next year, participants in the Commission's
19 process will develop a detailed plan for an emissions cap and market trading
20 program.
21 • Areas In And Near Parks. The Commission's research and modeling show that a
22 host of identified sources adjacent to parks and wilderness areas, including large
23 urban areas, have significant visibility impacts. However, the Commission lacks
24 sufficient data regarding the visibility impacts of emissions from some areas in
25 and near parks and wilderness areas. In general, the models used by the
26 Commission are not readily applicable to such areas. Pending further studies of
27 these areas, the Commission recommends that local, state, tribal, federal, and
28 private parties cooperatively develop strategies, expand data collection, and
29 improve modeling for reducing or preventing visibility impairment in areas within
30 and adjacent to parks and wilderness areas.
31 • Mobile Sources. The Commission recognizes that mobile source emissions are
32 projected to decrease through about 2005 due to improved control technologies.
33 The Commission recommends capping emissions at the lowest level achieved and
34 establishing a regional emissions budget, and also endorses national strategies
35 aimed at further reducing tailpipe emissions, including the so-called 49-state low
36 emission vehicle, or 49-state LEV.
37 • Road Dust. The Commission's technical assessment indicates that road dust is a
38 large contributor to visibility impairment on the Colorado Plateau. As such, it
39 requires urgent attention. However, due to considerable skepticism regarding the
40 modeled contribution of road dust to visibility impairment, the Commission
41 recommends further study in order to resolve the uncertainties regarding both
42 near-field and distant effects of road dust, prior to taking remedial action. Since
43 this emissions source is potentially such a significant contributor, the Commission
ESMP Policy Draft C, 5/15/02 II - C - 47
1 feels that it deserves high priority attention and, if warranted, additional emissions
2 management actions.
3 • Emissions from Mexico. Mexican sources are also shown to be significant
4 contributors, particularly of SO2 emissions. However, data gaps and jurisdictional
5 issues make this a difficult issue for the Commission to address directly. The
6 Commission recommendations call for continued bi-national collaboration to
7 work on this problem, as well as additional efforts to complete emissions
8 inventories and increase monitoring capacities. These matters should receive high
9 priority for regional and national action.
10 • Fire. The Commission recognizes that fire plays a significant role in visibility on
11 the Plateau. In fact, land managers propose aggressive prescribed fire programs
12 aimed at correcting the buildup of biomass due to decades of fire suppression.
13 Therefore, prescribed fire and wildfire levels are projected to increase
14 significantly during the studied period. The Commission recommends the
15 implementation of programs to minimize emissions and visibility impacts from
16 prescribed fire, as well as to educate the public.
17 • Future Regional Coordinating Entity. Finally, the Commission believes there is
18 a need for an entity like the Commission to oversee, promote, and support many
19 of the recommendations in this report. To support that entity, the Commission has
20 developed a set of recommendations addressing the future administrative,
21 technical and funding needs of the Commission or a new regional entity and has
22 asked the Operations Committee to complete detailed plans by September, 1996.
23 The Commission strongly urges the EPA and Congress to provide funding for
24 these vital functions and give them a priority reflective of the national importance
25 of the Class I areas on the Colorado Plateau.
26 To the maximum extent feasible, Commission recommendations calling for additional
27 exploration and study, etc. (necessary for filling information gaps and for resolving
28 certain policy issues) should be accomplished by the year 2000. Until such time as future
29 organizational arrangements have been determined, all tasks, which are not assigned to
30 any particular existing entity, should be performed by or under the auspices of the
31 Operations Committee.
32 The Commission believes that reasonable progress toward the national visibility goal is
33 achieved to the extent that current Clean Air Act requirements, existing laws and
34 regulations, and the Commission's recommendations result in a significant near-term
35 decrease in emissions that contribute to visibility impairment and ensure long-term
36 protection of visibility. For example by 2000-2010, pollutants from stationary and mobile
37 sources are expected to be reduced by 30% from the 1990 levels.
ESMP Policy Draft C, 5/15/02 II - C - 48
1 The Environmental Protection Agency
2 Interim Air Quality Policy on Wildland and Prescribed Fire
3 April 23, 1998
4
5 I. PURPOSE
6
7 This policy statement has been prepared in response to plans by some Federal, tribal and
8 State wildland owners/managers to significantly increase the use of wildland and
9 prescribed fires to achieve resource benefits in the wildlands. Many wildland ecosystems
10 are considered to be unhealthy as a result of past management strategies. The absence of
11 fire effects has allowed plant species (e.g., trees and shrubs) that would normally be
12 eliminated by fires to proliferate, vegetation to become dense and insect infestations to go
13 unchecked. Wildland owners/managers plan to significantly increase their use of fires to
14 correct these unhealthy conditions and to reduce the risk of wildfires to public and fire
15 fighter safety. The largest increases are expected mainly on Federal lands in western
16 States in ecosystems where fires would naturally occur every few years (35 years or less)
17 if not suppressed. Fire has continued to be a management tool used by many public and
18 private wildland owners/managers in the southeastern States. However, Federal land
19 managers in the southeast also plan to significantly increase their use of fire above
20 current annual levels.
21
22 This policy statement integrates two public policy goals, (1) to allow fire to function, as
23 nearly as possible, in its natural role in maintaining healthy wildland ecosystems, and (2)
24 to protect public health and welfare by mitigating the impacts of air pollutant emissions
25 on air quality and visibility. This document provides guidance on mitigating air pollution
26 impacts caused by fires in the wildlands and the wildland/urban interface. It identifies the
27 responsibilities of wildland owners/managers and State/tribal air quality managers to
28 work together to coordinate fire activities, minimize air pollutant emissions, manage
29 smoke from wildland and prescribed fires managed for resource benefits, and establish
30 emergency action programs to mitigate the unavoidable impacts on the public. This
31 policy is not intended to limit opportunities by private wildland owners/ managers to use
32 fire so that burning can be increased on publicly owned wildlands. Thoughtful use of fire
33 by private, public and Indian wildland owners/managers within smoke management
34 programs is promoted to maintain healthy wildland ecosystems. Neither is this policy
35 intended to imply that states/tribes should relax existing smoke management programs or
36 limit a state’s/tribe’s ability to regulate fires managed for resource benefits.
37
38 The EPA used a deliberative process involving a multi-stakeholder workgroup to develop
39 recommendations for this policy. The workgroup did not reach consensus on all of the
40 issues raised. The EPA addressed all of the recommendations and concerns raised by the
41 stakeholders to the extent possible. The multi-stakeholder workgroup also produced
42 several “white papers” on a number of topics previously identified in earlier drafts of the
43 policy as Appendices to the policy. These papers will be published as a separate
44 document and can also be found on EPA’s TTN2000 website:
45 http://134.67.104.12/html/o3pmrh/pbissu.htm, and on the Western States Air Resources
ESMP Policy Draft C, 5/15/02 II - C - 49
1 Council (WESTAR) website: http://www.westar.org/proj_frame.html. A list of these
2 papers is provided in the Table of Contents.
3
4 II. SCOPE AND APPLICABILITY
5 The EPA does not directly regulate the use of fire within a State or on Indian lands. The
6 EPA’s authority is to enforce the requirements of the CAA. The CAA requires States and
7 tribes to attain and maintain the NAAQS adopted to protect public health and welfare.
8 This policy recommends that States/tribes implement SMPs to mitigate the public health
9 and welfare impacts of fires managed for resource benefits. While SMPs will also
10 mitigate nuisance smoke intrusions, nuisance issues have been left for the individual air
11 quality agencies to address. This policy applies to all wildland and prescribed fires
12 managed to achieve resource benefits on public, Indian and privately owned wildlands,
13 regardless of the cause of ignition (e.g., lightning, arson, accidental, land management
14 decision, etc.) or purpose of the fire (e.g., natural, resource management, hazard
15 reduction, etc.).
16
17 Federal land management agencies sometimes manage naturally ignited fires to achieve
18 resource benefits. Planning for naturally ignited fires is obviously limited, but the
19 agencies require fire management plans to be included in land use plans for an area
20 before a naturally ignited fire can be managed for resource benefits. Fires ignited in areas
21 without fire management plans are unwanted or wildfires. The interface between this
22 policy and the Natural Events Policy regarding ambient PM concentrations caused by
23 wildfires is addressed in section VII.
24
25 This policy does not apply to other open burning activities, such as burning at residential,
26 commercial or industrial sites; open burning of land clearing waste or construction debris.
27 It also does not apply to open burning of agricultural waste, crop residue or land in the
28 USDA Conservation Reserve Program. The EPA is working with the USDA Agriculture
29 Air Quality Task Force to develop equitable policies for emissions from activities that
30 could be classified as agricultural burning.
31
32 This policy addresses the impacts of air pollutant emissions from fires managed for
33 resource benefits on public health and welfare. The primary indicators of public health
34 impacts used are ambient air quality impacts above the NAAQS for fine particles with an
35 aerodynamic diameter less than or equal to a nominal 2.5 micrometers (PM), and
36 particles with an aerodynamic diameter less than or equal to a nominal 10 micrometers
37 (PM). There are both 24-hour (daily) and annual NAAQS for PM and PM. Emissions of
38 nitrogen oxides (NO), VOC, and CO from fires can also impact the NAAQS for NO, O,
39 and CO. However, the actions required to reduce VOC and CO emissions are the same as
40 those recommended in this document to mitigate impacts on the PM, and PM NAAQS.
41 Emissions of NO, on the other hand, can increase under some of the burning conditions
42 used to decrease emissions of other pollutants.
43
44 The effects of fire emissions on the public welfare aspects of the NAAQS for PM are
45 addressed in terms of visibility impairment and regional haze. The policy also addresses
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1 the treatment of fire emissions to meet other CAA requirements, such as prevention of
2 significant deterioration (PSD) and conformity with SIPs or TIPs.
ESMP Policy Draft C, 5/15/02 II - C - 51
1 AIR QUALITY POLICY ON
2 AGRICULTURAL BURNING
3
4 RECOMMENDATION FROM THE
5 AGRICULTURAL AIR QUALITY TASK FORCE
6
7 TO
8 U.S. DEPARTMENT OF AGRICULTURE
9 November 10, 1999
10
11
12 EXECUTIVE SUMMARY
13
14 The AAQTF Agricultural Burning Policy recommends States/Tribes adopt a Smoke
15 Management Program (SMP) to reduce the public health and welfare impacts of using
16 burning in support of agricultural production. The SMP is implemented through an
17 Agricultural Burning Manager (ABM)—the air quality agency or designated authority
18 responsible for managing agricultural burning at the state, local, or tribal level. The
19 policy is founded on two basic principles: (1) allow the use of fire as an accepted
20 management practice, consistent with good science, to maintain agricultural production;
21 and (2) protect public health and welfare by mitigating the impacts of air pollution
22 emissions on air quality and visibility. The recommended SMP is two-tiered. De
23 minimus fires, as established by the ABM, are exempt.
24
25 Tier One: Tier 1 is a voluntary program for areas where agricultural burning rarely
26 causes or contributes to air quality problems. The SMP establishes conditions (time of
27 day and year, meteorological conditions, safety parameters, type of burn, maximum
28 number of acres, etc.) under which agricultural burning can occur. It is essentially a
29 permit by rule.
30
31 Tier Two: Tier 2 is a more structured program than Tier 1 and is designed for areas
32 where agricultural burning contributes to Particulate Matter National Ambient Air
33 Quality Standards violations or visibility impairment in Class I Federal areas. (Areas set
34 aside under the Clean Air Act to receive the most stringent protection from air quality
35 degradation.) The SMP would include a process for authorizing/granting approval for
36 agricultural burns and establish criteria for burn/no-burn decisions. Detailed permitting
37 requirements such as a real-time meteorological assessment for bun decisions, air quality
38 monitoring, public notification, and enforcement requirements would likely be included
39 in a Tier 2 SMP.
40
41 The policy also recommends additional research in the following areas: the ability to
42 predict downwind concentrations of particulate matter utilizing various modeling
43 techniques; evaluating the applicability of current sampling techniques to agricultural
44 burning; determining accurate emission factors; evaluating techniques to reduce
45 emissions of material determined detrimental to human health and visibility; and
46 developing alternatives to agricultural burning.
ESMP Policy Draft C, 5/15/02 II - C - 52
1
2 The Western Regional Air Partnership
3 Policy on Categorizing Fire Emissions
4 November 15, 2001
5
6 EXECUTIVE SUMMARY
7
8 The Western Regional Air Partnership (WRAP), as the successor to the Grand Canyon
9 Visibility Transport Commission (GCVTC), is charged with implementing the GCVTC
10 Recommendations as well as addressing broader air quality issues, such as the Regional
11 Haze Rule. The Regional Haze Rule (Rule), issued by the Environmental Protection
12 Agency (EPA) in July 1999, outlines the requirements for states and tribes to address
13 regional haze in Federal Class I areas, and sets the goal of reaching natural background
14 conditions in Federal Class I areas by 2064. EPA recognizes the WRAP as the Regional
15 Planning Organization that is developing the guidance and means to implement the Rule
16 in the WRAP region.
17
18 There are a number of sources that the EPA has identified as potential contributors to
19 natural background conditions, one of which is fire. The Regional Haze Rule Preamble
20 stipulates that fire of all kinds contributes to regional haze and that fire can have both
21 natural and human-caused sources. The Preamble further states that some fire that is
22 human ignited may be included in a state’s or tribe’s determination of natural background
23 conditions.
24
25 The WRAP Fire Emissions Joint Forum (FEJF) was established to develop policy and
26 technical tools to address smoke effects caused by wildland and agricultural fire on
27 public, tribal, and private lands. Due to the limitations of the current visibility monitoring
28 technology to determine fire impacts, the FEJF was charged with addressing fire
29 emissions’ contribution to natural background conditions. The FEJF formed the Natural
30 Background Task Team (NBTT) to develop a methodology to categorize fire emissions
31 as either “natural” or “anthropogenic”; thus providing the basis for fire’s inclusion in
32 natural background condition values and ultimately, the tracking of reasonable progress.
33
34 This Policy has been developed over an 18-month period by the NBTT; a group made up
35 of state, tribal, and federal agency representatives, as well as those from industry,
36 agriculture, academia, and environmental organizations. During this process, the NBTT
37 solicited public input regarding both technical and policy issues. The resulting
38 Recommended Policy for Categorizing Fire Emissions was granted consensus approval
39 by the FEJF on August 30, 2001. The WRAP granted consensus approval for the Policy
40 on November 15, 2001. As part of the WRAP consensus approval action, the Initiatives
41 Oversight Committee (IOC) Transmittal Letter to the WRAP was modified and
42 incorporated into this Policy as Appendix C.
43
44 The Policy is comprised of two main sections: Classification Criteria and Classification
45 Program Management. The Classification Criteria section determines the “natural” and
46 “anthropogenic” sources of fire that contribute to regional haze, as stated in the Preamble
ESMP Policy Draft C, 5/15/02 II - C - 53
1 to the Rule. The Program Management section expresses the prerequisites that enable
2 classification to be effective and equitable. Although the Program Management section
3 addresses prerequisites that need to exist, it does not describe how they will be brought
4 about. This work is currently underway in the FEJF as well as in other WRAP Forums.
5
6 The Classification Criteria clarify the relationship between what would be defined as a
7 “natural” fire emissions source and what would be defined as an “anthropogenic” fire
8 emissions source, thereby addressing the complex relationship EPA acknowledges in the
9 Preamble to the Rule. Under the Policy, most fire emissions sources are classified
10 “anthropogenic”, which is in keeping with the Rule’s primary objective of the
11 development of long-term strategies for reducing emissions of visibility impairing
12 pollutants. However, some fire emissions sources are classified as “natural” in
13 recognition of fire’s inherent occurrence as part of the landscape.
14
15 The Program Management section supports the classification process by iterating that all
16 types of fires must be managed to minimize visibility impacts in order to assure equity
17 among the different fire source types and other air pollution sources. In cases where a fire
18 is classified as “anthropogenic”, its emissions will be controlled in order to demonstrate
19 reasonable progress toward the 2064 natural conditions goal. The Program Management
20 section also recognizes that to determine fire emissions’ contribution to visibility impacts,
21 emissions from all fires will be tracked. This across-the-board tracking is also necessary
22 to allow the classification process to function uniformly across the WRAP region.
23
24 The Policy will provide states and tribes an equitable and practical method for
25 determining which fire emissions will be considered part of the natural background
26 conditions in Federal Class I areas. In so doing, the Policy will enable states and tribes to
27 address natural reductions of visibility from fire as well as identify those fire emissions
28 that need to be controlled to achieve progress toward the 2064 natural conditions goal.
29 The FEJF is developing policy and technical tools that will support this Policy and its
30 implementation, such as guidance on Enhanced Smoke Management Plan elements,
31 recommendations for creation of an annual emissions goal, availability and feasibility of
32 alternatives to burning, recommendations for managing fire emissions sources, guidance
33 for feasibility determinations, a methodology for tracking fire emissions, and a stepwise
34 progression for the Program Management elements of the Policy.
35
36 POLICY STATEMENTS
37
38 Classification Program Management
39
40 G. All fires must be managed to minimize visibility impacts.
41
42 H. All emissions from fires classified as an “anthropogenic” source will be controlled to
43 the maximum extent feasible subject to economic, safety, technical and
44 environmental considerations.
45
46 I. Emissions from all fire will be tracked.
ESMP Policy Draft C, 5/15/02 II - C - 54
1
2 Classification Criteria
3
4 E. Prescribed Fire is an “anthropogenic” source, except where it is utilized to maintain
5 an ecosystem that is currently in an ecologically functional and fire resilient
6 condition, which is classified as a “natural” source.
7
8 F. Wildfire that is suppressed by management action is a “natural” source. Wildfire,
9 when suppression is limited for safety, economic, or resource limitations, remains a
10 “natural” source. Wildfires managed for resource objectives are classified the same as
11 prescribed fires.
12
13 C. Native American cultural burning for traditional, religious, and ceremonial purposes
14 is a “natural” source.
15
ESMP Policy Draft C, 5/15/02 II - C - 55
1 Wildland Fire:
2 Elements of a Basic Smoke Management Program
3 Draft Report
4 July 10, 2001
5
6 DIGEST
7
8 A. Authorization to Burn
9
10 A1. Legal Authority to Authorize a Burn (page 14)
11 Recommendation: The regulatory authority should establish a means or system
12 to authorize a prescribed burn. The information concerning all approved burns
13 needs to be made available for emissions tracking and inventory purposes.
14
15 A2. Instrument or Tool Used to Evaluate a Burn (page 15)
16 Recommendation: The level of effort or extent of authorization should be based
17 upon the air quality impact (public health, NAAQS, visibility, and nuisance)
18 prescribed burning may have on an area. It is recommended that the regulatory
19 authority work with the land owners/managers to develop criteria for what level
20 of authorization should be required (based on acreage, emissions, potential
21 impact, etc.)
22
23 A3. Criteria to Approve a Burn (page 16)
24 Recommendation: Regulatory authorities should coordinate when burning is
25 close to jurisdictional boundaries.
26
27 B. Minimizing Air Pollution Emissions
28
29 B1. Burner Qualifications (page 19)
30 Recommendation: It is recommended that regulatory authorities consider a
31 minimum level of qualification for individuals conducting or approving burns.
32 This will help ensure that techniques for minimizing air pollutant emissions are
33 evaluated.
34
35 B2. Alternatives to Burning and Their Incentives (page 20)
36 Recommendation: It is recommended that alternatives to burning be evaluated
37 on all burns. These evaluations should be based upon all available alternatives
38 that are economically feasible to implement and that minimize other
39 environmental impacts while meeting land management objectives.
40
41 B3. Emission Reduction and Impact Techniques (page 21)
42 Recommendation: Emission/impact reduction techniques should be included on
43 all burns. These techniques should be economical to implement and minimize
44 other environmental impacts.
45
46 B4. Impact Reduction (page 22)
ESMP Policy Draft C, 5/15/02 II - C - 56
1 Recommendation: Regulatory authorities should implement regulations that
2 state that a person may not cause or permit any emission that is injurious to
3 human health or welfare, animal or plant life, or property, or that would
4 unreasonably interfere with the enjoyment of life or property or intrude into any
5 smoke sensitive area. Regulatory authorities may need to implement setback
6 requirements for tribes’ sacred sites.
7
8 B5. Impact Reduction Contingency Plans (page 25)
9 Recommendation: Land owner/managers should have specific contingency
10 plans that will be implemented if smoke impacts occur or meteorological
11 conditions deviate from the desired condition.
12
13 B6. Monitoring Smoke Impacts (page 25)
14 Recommendation: Regulatory authorities should require that real and potential
15 smoke impacts be monitored while emissions are produced.
16
17 B7. Emission Reduction Tracking and Documentation (page 26)
18 Recommendation: Regulatory authorities should require documentation of
19 emission reduction techniques and estimates of their resulting emission
20 reductions.
21
22 C. Smoke Management Components of Burn Plans
23
24 C1. Recommendation: Federal land managers should include smoke
25 management components in burn plans as described in the Interim Policy.
26 Regulatory authorities should assist private landowners in preparing smoke
27 management components of burn plans for large fires that have the potential to
28 impact smoke sensitive areas. (page 31)
29
30 C2. Evaluate Smoke Dispersion (page 31)
31 Recommendation: Burn plans should include methods for evaluating smoke
32 dispersion impacts to smoke sensitive areas.
33
34 C3. Public Notification and Exposure Reduction Procedures (page 32)
35 Recommendation: Burn plans should include a notification process that is
36 responsive to potential or actual smoke impacts. Burn plans should also include
37 documentation procedures and contingency actions to be taken during smoke
38 intrusions.
39
40 C4. Air Quality Monitoring (page 33)
41 Recommendation: State ambient air quality monitoring networks and on-site
42 visual observations should be used to monitor smoke impacts. In addition, land
43 owners/managers and the regulatory authority should establish site-specific air
44 monitoring networks or practices.
45
46 D. Public Education and Awareness
ESMP Policy Draft C, 5/15/02 II - C - 57
1
2 D1. General Public Education Programs (page 36)
3 Recommendation: Where appropriate, land owners/managers and regulatory
4 authorities should implement educational programs that are as aggressive as
5 possible. The level of effort should be based on the special needs of each area.
6
7 D2. Informing the Burn Community (page 37)
8 Recommendation: Regulatory authorities should provide training to the land
9 owners/managers regarding SMPs, and any other permit or rule requirements.
10
11 D3. Public Involvement in Planning Process (page 37)
12 Recommendation: Land owners/managers and regulatory authorities should
13 adopt policies to use aggressive outreach methods to solicit early and effective
14 public involvement in the planning and regulatory development process.
15
16 E. Surveillance and Enforcement
17
18 E1. Standards, Trigger Levels, Alerts, Requirements for Enforcement(page 40)
19 Recommendation: The regulatory authority should clearly establish criteria that
20 state when surveillance and enforcement should be conducted. It is recommended
21 that the criteria be established in statutory rules.
22
23 E2. Types of Monitoring and Surveillance (page 42)
24 Recommendation: Surveillance and enforcement should be tailored to achieving
25 compliance with applicable rules and laws.
26
27 E3. Enforcement Actions and Penalties (page 43)
28 Recommendation: Enforcement and penalties should be focused on repeat
29 violators and instances of NAAQS exceedances (or significant contributions to
30 NAAQS exceedances) or established visibility criteria exceedances/violations.
31 The regulatory authority should work with the land owners/managers to develop
32 criteria for what level of NAAQS and/or visibility monitoring is needed based on
33 acreage, emissions, potential impacts, etc.
34
35 F. Program Evaluation and Reporting
36
37 F1. Reporting (page 46)
38 Recommendation: SMPs should require annual reports for areas with high levels
39 of burning. The annual reports should serve as a “report card” and include
40 summaries of burn activity, burn restrictions, air quality data, significant smoke
41 intrusions, and complaints. Land owners/managers should provide adequate fire
42 information to regulatory authorities so they may develop accurate annual
43 statewide emission inventories.
44
45 F2. Periodic Evaluation (page 47)
ESMP Policy Draft C, 5/15/02 II - C - 58
1 Recommendation: Each element of the SMP should be evaluated as often as
2 needed, but at least once every three to five years.
3
4 G. Optional Air Quality Protection
5
6 G1. Recommendation: Regulatory authorities and land owners/managers should
7 continually look for and investigate optional techniques, strategies, programs, and
8 alternatives to better protect air quality and reduce visibility impacts. (page 49)
9
10 G2. Special Protection Zones and Additional Requirements (page 49)
11 Recommendation: Consideration should be made to establish special protection
12 zones around smoke sensitive areas to provide additional air quality protection
13 requirements. Tribal religious areas should be considered for special protection.
14
15 G3. Performance Standards (page 50)
16 Recommendation: Performance standards should be established that trigger
17 additional requirements for issues such as visibility impacts, emissions,
18 complaints, and public nuisance.
19
20 G4. Additional Smoke Management Requirements if Performance Standards
21 Have Been Exceeded (page 51)
22 Recommendation: Regulatory authorities should establish procedures for when
23 performance standards are exceeded.
24
25
26
ESMP Policy Draft C, 5/15/02 II - C - 59
June 15, 2002 ESMP Reviewer Comment
Section # Page Line Comment/Suggested Wording Reviewer
# # /Cite
General On the whole, the “Draft WRAP Policy, Enhanced Smoke Management Programs for Alston
Visibility and Regional Haze” appears to be a well-rounded document for improving our
ability to manage smoke for its visibility, as well as its health and nuisance, affects. As
with any management plan, future developments will change our ability to characterize
and manage smoke, and the Draft Policy correctly points this out in both implementation
examples and reminders of future SIP/TIP revisions. This evolving capability may be
especially important for agricultural burning, where smoke management may be new to
many managers. The proposed Draft Policy does not appear to represent a radical change
from the current program we are operating under in Arizona (although there are some
new elements). As a manager for both a Class I area and a forest ecosystem that requires
periodic fire, this Draft Policy appears to offer a balanced approach and a valuable tool.
General Good work. When dealing with so many unique situations a guidance that provides Campbell
information without being prescriptive is realistic. This document should provide
States/Tribes with an organized plan, many possible implementation methods and lots of
good background information to support their program.
General Very well done and clear document. Good options/alternatives and guidance. Evans
General The title of the policy and throughout the document the term “visibility and regional Finneran
haze” is used together. Sometimes the term “visibility impairment and regional haze” is
used. Other times “visibility impairment” is used alone. There needs to be some
explanation/definition at the start of the policy as to DISTINCTION between these two
terms, or else go with one term consistently in the document. (The distinction implies
that “visibility” is concerned about nearby plume impacts, while “regional haze” is more
about long-range transport and cumulative impacts.) Note that section 309 for fire uses
the term “visibility impairment” and not both.
General My review of the draft ESMP has been enlightening and has also resulted in a review of Frandsen
Utah’s Smoke Management Plan. Once finalized, the ESMP will probably become an
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integral part of the overall smoke management plan for this state.
General A section that distinguishes the differences between tribes and states with respect to the Gruenig
Regional Haze Rule and other items is necessary. For example, under Unit V, Section A
of the Rule, it states “unlike States, tribes are not required by the TAR [Tribal Authority
Rule] to adopt and implement CAA plans or programs, thus tribes are not subject to
mandatory deadlines for submittal of implementation plans.” The EPA, as well as other
readers of the document, must be alerted to this difference along with others. Such a
section should be mandatory in all reports assembled by the WRAP to avoid any
misimpression by the reader who will see words such as “must” and “required” when the
document refers to both states and tribes.
General Issuing the document as a “WRAP Policy” is very troubling. According to Webster’s Gruenig
General Dictionary, a “policy” is “a definite course or method of action selected from among
alternatives and in light of given conditions to guide and determine present and future
conditions.” Policy therefore implies regulation, which allows for little deviation from
the selected course. Throughout the document, there are words “must,” “obligation,” and
“will” which evidence this lack of deviation from the proposed ESMP. It would be more
appropriate to draft the document as a set of guidelines or recommendations for states and
tribes to adopt. As previously mentioned, there is a clear distinction between states and
tribes with the latter not being subject to the same requirements as the former (tribes may
even adopt additional elements under their respective ESMPs to address such items as
sacred and cultural needs). As an example, Section 2.5, lines 36-39, attributes the ESMP
elements listed in Section 309 as requirements for both the states and tribes. If one reads
the header for the section under which these requirements fall under, it reads
“Requirements of the first implementation plan for States electing to adopt all of the
recommendations of the Commission Report.” By clearly listing “States,” this is
indicative of the entire section being inapplicable to tribes. This error of attributing
requirements of states to tribes is frequent throughout the document and must be
corrected. Otherwise, the document will give a false impression to the reader about what
tribes must adhere to under a TIP.
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Ge
I had an opportunity to review the ESMP along with comments drafted by Kevin Rose Lee
regarding the ESMP. I concur with Kevin's comments regarding the need to clarify the
differences between states and tribes with regards to the requirements in the RHR. Tribes
are not subject to the same requirements as States; however, the ESMP implies that both
states and tribes are subject to the same requirements, timelines, etc. It is important that
this document explicitly explain the intended difference.
Also, I question the need for this document to be considered a WRAP Policy... it seems
that this document is providing guidance; so wouldn't it be more appropriate for this to be
the forth as a opportunity to review the document.
put document guidance document from theand tribes. general I think the information in
Thank for the will be useful to both states WRAP? In
General Should include a map of the Class I areas early in the document. Main
General Interagency public response and notification process should be implemented via the Main
regional or central authority prior to seasons and years with anomalous or above-average
smoke concerns.
General If not already in place, a centralized website (i.e., Southwest Predictive Services) should Main
contain daily forecasts of wind, smoke and air mass dispersal, with current models.
Additionally this site could post regional information on combined airshed-smoke
impacts and burning schedules for planning and smoke abatement purposes.
General The author(s) of the document should re-visit Unit V of the Regional Haze Regulations McKernan
(RHR) Implementation of the Regional Haze Program in Indian Country in which it discusses how the
rule is to be implemented in Indian Country in light of the Tribal Authority Rule,
Executive Orders on Tribal consultation. The document implies erroneously throughout,
especially when citing the federal register, that Tribes are subject to the same
requirements as states in terms deadlines for implementation, TIP approvals, reporting
progress, etc. Although it is noted that there was effort to include Tribes in the language
of the proposed policy, some of this inclusion steps beyond the scope of the RHR. There
are numerous occurrences of this throughout the document so rather than address them
all, there is an example of a few of the errors.
General Since WRAP has no authority to establish “policy” the document would be more Mignella
appropriately titled “WRAP Model ESMP” or some equivalent.
General The document should be reorganized – WRAP should be introduced, as should the Mignella
purpose of the document (see Section 2.2) BEFORE the text of the suggested ESMP.
General The draft policy document is fairly comprehensive in scope and applicability to fire Mitchell
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sources that could affect visibility in mandatory Class I areas. Consider a thorough
editing to remove repetitious language (some specifics are addressed below). Repeated or
similar language appearing occasionally throughout the document is distracting and
weakens the impact of the document (i.e., gives the impression of “filler” or “fluff” rather
than “substance”). Being more concise should help readers to focus on substance. If the
intent of repeated language is to provide additional emphasis to those entries, perhaps a
new “guiding principles” section is needed where these items can be listed and simply
referred to in the document, as needed.
General Great work. The members of the ESMP Task Team as well as the ESMP Task Team Potter
facilitator should be commended for developing such a clear and concise document. The
structure of the Policy was easy to follow making the document very easy to read and
review.
General The reference footnoting throughout the document was excellent and adds to the Potter
credibility of the Policy.
General Thank you for emphasizing state/tribal flexibility at several locations throughout the Potter
document. I really like the separation of the “implementation guidance” into an
Appendix, which reinforces the emphasis throughout the Policy that it is not prescriptive
regarding implementation. The “implementation guidance” sections of the document as
well as Appendix C should prove to be a useful part of the document for states/tribes in
the development of their ESMPs.
General I believe the word “ozone” should be capitalized throughout the entire document for Potter
consistency.
General It is evident that much work went into this product. Very good job! McLeod
From the States side of the house it appears that there was a lot of representation. I’m
sorry to say that Tribal involvement was minimum at best. Since Alaska joined the
Board I figured there would be more input from that State and Tribes. No reference was
made to Tribal Jurisdictional conflicts and what to do in those cases. Also no reference
was made to the Tribal Authority Rule or “Tribal Treatment-As-States” (term not widely
accepted throughout Indian Country), which in many cases would exempt Tribes from
deadlines that States are required to conform to. Also as you can see from my comments
“Federal Land Managers” were not included in this product, are they being treated
separately from the rest of the Western Regional Air Partnership?
General All Where the terms SIPs/TIPs appear change to read SIPs/TIPs/FIPs. Where the terms McLeod
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states/tribes appear change to read states/tribes and FLMs
General I do not see anything new in this policy from what already exists in other documents. I Riley
don’t see, from a state perspective, how this policy will help me develop an ESMP any
better than I already had from existing documents. The document still needs to be more
focused on visibility of class I areas.
General A tremendous job by the ESMP-TT! Congratulations! Sandberg
General Fatally flawed by ignoring emission tracking Sandberg
General The intent of the regional haze rule is to create a Shipp
coordinated program that addresses both NAAQS and visibility 64 FR
issues. The ESMP requires a statement regarding how this 35766, §
coordination occurs. The ESMP should state that the effect 51.308(c)
of the regional haze SIP on PM2.5, PM10, ozone and other (1)(2)
SIPs will be addressed in the regional haze SIP.
Conversely, the effect of PM2.5, PM10, and ozone SIPs on
regional haze SIPs should also be addressed in the ESMP.
General The May 24, 2002, Draft WRAP Policy on Enhanced Smoke Shipp
Management Programs for Visibility and Regional Haze is well
written. Because it generally reflects the key elements of
California’s Title 17 smoke management program, we believe
it will be useful to States/Tribes in addressing smoke
impacts from agricultural and prescribed burning operations
as required by the Regional Haze Rule.
General The Section 308 portion of the rule is structured to give Shipp
States/Tribes the option to first assess baseline mandatory 64 FR
Class 1 area visibility, determine the need for visibility 35766, §
improvement and maintenance, and finally identify various 51.308
measures to improve visibility for these areas. The Policy (d)(1),(2
should recognize that States/Tribes may choose to collect ),(3)
and analyze emissions and visibility data before they
determine if additional smoke management efforts are
necessary.
General The document is very well written. It provides excellent rationale for the comments Doc Smith
and suggestions in the policy. The WRAP Policy gives states and tribes a great deal of
flexibility in development of ESMPs. It provides a range of options and good rationale
and guidance to include in the ESMPs.
Outreach Process II - 295
General The WRAP Policy could allow for differences in application of constraints across and Doc Smith
between states/tribes that might be considered inequitable.
General The WRAP Policy is an excellent approach but will require oversight of plans by EPA. Doc Smith
General Thank you for the opportunity provided to CDF to review the WRAP Policy. However, Stephens
please note that time did not permit an in depth review that includes reference materials
due to the limited time allotted for review.
General Good document; I did not see anything that would be detrimental to the agricultural Wagoner
community. Thanks for your hard work.
General The general interpretation of an ESMP is good, and the draft policy is excellent. Woodard
Gruenig
Fn. 25 8 This citation is incorrect. It should be § 51.309(d)(6)(i), not § 51.309(6)(i).
Gruenig
Fn. 32 11 The language in the cited document mentioned that all types of fire (i.e., prescribed fire,
wildfire, and agricultural burning) are to be treated equitably which does not necessarily
include facilities and properties
Gruenig
Fn. 50 14 If it is intended that the language remain the same, then the first few words should read as
“[the implementation].” Using the exact language in the citation, implementation is
capitalized.
Gruenig
Fn. 53 15 The citation appears to be incorrect and should be more appropriately listed as
§ 51.308(g)(4)
Gruenig
Fn. 56 15 The first word of the quoted citation should read as “[e]nhanced”
Gruenig
Fn. 57 15 While the citation does speak about complying with reasonable progress goals, there is no
mentioned of ESMPs until § 51.309(d)(6)(iv)
Executive i - ii This section pulls together the main ideas and elements included in the draft policy. For Mitchell
Summary the editing suggested above, consider discussing each of the Executive Summary “topics”
in only one section of the draft document, rather than spread throughout the document.
Exec Summ i 9-12 The Regional Haze Rule (Rule) requires States/tribes to Shipp
develop State Implementation Plans/Tribal Implementation 64 FR
Plans (SIPs/TIPs) for addressing regional haze in the 35767, §
Nation’s 156 mandatory Class I areas. 51.308
(d) (3)
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Transport Region States, as defined in the Rule, have two (iii) (v)
options: 1) States/tribes may choose to incorporate the (E)
Grand Canyon Visibility Transport Commission’s (GCVTC)
Recommendations into their regional haze SIPs/TIPS (Section 64 FR
309); 2) or they may choose to develop the aspects of their 35771, §
regional haze SIPs/TIPs per the nationally applicable 51.30 (b)
provisions (Section 308). (2)
(Note to editor: some of this language pulled from page ii,
starting at line 9.) 64 FR
35771, §
Sections 308 and 309 of the Rule require all SIPs/TIPs to 51.30 (d)
consider smoke from agricultural and forestry management (6)
practices. While Section 308 does not prescribe any
specific programmatic elements for managing smoke. Section
309 of the Rule does require the implementation of an
Enhanced Smoke Management Program to address smoke
management elements. (provide footnotes and citations).
(Note to editor: this language pulled from page ii,
starting at line 13.)
Gruenig
Exec Sum. i 10 Should include “and tribes” after states to balance the inclusion of “Tribal
Implementation Plans” that is already contained within the sentence (i.e., a state cannot
have a Tribal Implementation Plan)
Exec. Sum. i 10 The sentence implies that states have Tribal implementation plans. The sentence should McKernan
only mention SIPs since the sentence opens with “All states have the obligation…”.
Executive i 10 Since basis of document focuses on Class 1 should be defined here as well as in Dykzeul
Summary Appendix. See separate comment sheet for “Traditional Class 1” comments.
Exec. i 12- This section may prove to be confusing for a first time reader of the document. There Stephens
Summary 15 seems to be two issues expressed in this section. One is what defines an adequate ESMP,
which is presumed to be one that includes all nine elements. The second is what is
needed to satisfy the requirements of the “Rule.” Perhaps this section could be reworded
for clarity.
Executive i 33 regional haze or NAAQS Shipp
Summary
Exec Summ i 14 Note that this plan is “available” for states and tribes to include in their SIP/TIP. Some Alston
governments may wish to alter it somewhat to fit their specific needs. The words “shall”
Outreach Process II - 297
and “will” appear many times in the document. Many stakeholders at the state and tribal
level are outside the WRAP process, and are suspicious that the organization will dictate
their own policies. Sensitive wording (“can” instead of “shall”, or “will”) can show that
we really are “here to help.”
Exec Summ i 15- Stating the nine ESMP elements up front is very good. Shipp
25
Exec Summ i 27 “According to the Regional Haze Rule,…” Baldwin
Exec Summ i-ii 1-36 Excellent work. Generally sums up the entire product as written. McLeod
Exec Summ ii 1-7 I think it is good to remind readers that the ESMP Policy is to address visibility and Campbell
regional haze.
Exec Summ ii 2 You explain better in the document why only mandatory Class 1 areas. This did bring up Kuehn
a red flag, why not all Class 1 areas.
Exec Sum ii 2 “Class 1 areas, but rather focus on the minimization of emissions and impacts to Dykzeul
population centers as it should be for public safety”.
9-15 Good idea to provide brief information on Section 308 and Section 309 and how the Campbell
Exec. Summ ii ESMP Policy fits into this.
Exec Summ ii 9-15 Move to page i as noted above. Shipp
Exec Sum ii 10 The opening sentence addresses how states address RHR implementation then follows McKernan
with the inclusion of “state/Tribe, SIP/TIP” language for the rest of the paragraph
implying that Tribes must follow one of the two options. As stated in Unit IV C 13 of the
RHR, Tribes may or may not follow the 308 or 309 process based on the appropriateness
and scope of the implementation and that if EPA finds the Tribes lack of a program to be
affecting visibility that EPA will work with the Tribe on federal implementation.
Exec Sum ii 14 “Advanced??” Used several places in doc – why not “supported” Implies WRAP is Hirami
pushing this despite all the references to States/Tribes that these are “suggested” and
“recommended”.
Exec Summ ii 15 Again you explain better in the document why we chose to include 308 when it is not Kuehn
required to have an ESMP under the rule. I just thought this was confusing and if they do
not read the entire document, will not understand that we are recommending that 308
states adopt an ESMP.
Exec Summ ii 23 Delete the word “then” after the word “assist”. Shipp
Exec ii 23 Section 4 provides direction for states/tribes to assist then,……. McLeod
Summary Should read “Section 4 provides direction for states/tribes to assist them,…….
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Executive ii 23 Section 4 provides direction for states/tribes to assist then with ESMP implementation. Main
Summary
Exec Summ ii 24 Insert a space after the period. Shipp
Exec Summ ii 38 A brief reference to the stakeholder groups involved in designing the ESMP would be Alston
valuable in showing the viewpoints considered in its formulation.
Section 1 1 5 Similar to above comment, states don’t have TIPs McKernan
Gruenig
Section 1 1 5 Should include “and tribes” after states to balance the inclusion of “Tribal
Implementation Plans” that is already contained within the sentence (i.e., a state cannot
have a Tribal Implementation Plan)
1 1 6 State/Tribe change to State/Tribe and Federal McLeod
1 1 7 (SIPs/TIPs) change to (SIPs/TIPs/FIPs) McLeod
1 1 14- This language is inappropriate and should be deleted. WRAP has no jurisdiction to Mignella
17 require any state or tribe to do anything.
1. 1 15 WRAP states and tribes “must” include an ESMP only if they are using § 309. This is Alston
explained on page 16. This line gives the impression that the WRAP ESMP is the only 51.309(d)(6)(i
option. It should instead be offered as “a comprehensive vehicle that WRAP states/tribes v and
may include in their SIPs/TIPs to meet the requirement for an ESMP under § 309, and to 51.308(d)(3)(i
manage smoke (both agricultural and forest management) under § 308. v
1, 1 16 This sentence includes a statement indicating states must include ESMP elements in their Stephens
SIP to meet the requirements of the Rule. On page 4 lines 33 and 34, reference is made
to ESMP policies that may be incorporated into regional haze SIPs and submitted to EPA
in order to meet the requirements of the rule. For consistency between these two sections
please clarify to the reader if the inclusion of an ESMP Policy (with elements) is
mandatory in order to be in compliance with the Rule.
1 1 16 States/tribes must change to States/ must and Tribes and EPA should McLeod
1 16 The sentence states that Tribes “must” implement (see above comment) McKernan
1 1 16 SIPs/TIPs change to SIPs/TIPs/FIPs McLeod
1.1 1 21- The tone of this section suggests that WRAP is a regulatory entity. Since it is not, a more Mignella
27 appropriate wording would be something like: “The elements of the MODEL ESMP set
out in this document were drawn from the Regional Haze Rule, . . . . The following list
describes the specific elements of a model ESMP as envisioned by the WRAP:”
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1.1 1 27 Visibility in…. change to all McLeod
1.1 1 32 change: Evaluation of Smoke Trajectory and Dispersion Sandberg
1.1 1 34 Add: Regional EPA Offices should provide this dispersion modeling to Tribes that McLeod
do not possess the technical capacity to protect Human Health and visibility from
large scale burns both on and adjacent non-Indian lands.
1.1 1 36 add to end of sentence: [... or chemical treatments.] or Sandberg
alternative fire or vegetation management techniques that obviate need for fire.
1.1 2 8 Add: Tribes that do not have an air quality program must insure that the Bureau of McLeod
Indian Affairs or other Federal agency, i.e., EPA, complies with this element.
1.1 2 11- To put the statement more properly into the context of surveillance and enforcement, I Evans
12 suggest the statement be reworded as follows: “An oversight mechanism that assures
adherence to smoke management efforts as defined by the SIP/TIP.”
1.1 2 12 SIP/TIP change to SIP/TIP/FIP. Add: If no TIP in place some mechanism for McLeod
oversight on Tribal lands should be identified, albeit; EPA oversight.
1.1 2 15 Adequate for what purpose? Meet reasonable progress? Riley
1.1 2 16 Add: This should be a joint effort between Tribal/BIA forestry departments and McLeod
Tribal air quality programs or Tribal Health and Human Services Departments.
1.1 2 21 add: Emission and Activity-Level Tracking System Sandberg
1.1 2 21 State/tribes change to state, tribes and Federal Land Managers (FLMs) McLeod
1.1 2 21 What about Mexico and Canada? Kuehn
1.2 2 25- Please consider clarifying that the Regional Haze Rule only requires 7 elements and not Baldwin
31 the 9 suggested by this document.
1.2 2 25- This section states that per the Rule, states will consider efficiency, economics, law, Stephens
31 emissions reduction opportunities, land management objectives, and reduction of
visibility impact as each determines the implementation of ESMP elements. CDF is
encouraged that recognition has been given to other factors such as land management
objectives, economics, and efficiency along with emission reduction opportunities for
implementation of the ESMP. Maintaining flexibility in our approach to fuel hazard
reduction is of high importance to our Department, in light of the many constraints that
impact our ability to find windows of opportunity for prescribed burning.
1.2 2 25 Very awkwardly stated, although this is not my doc Hirami
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1.2 2 25- Reword as: “The Model ESMP offered by the WRAP provides that states and tribes, as Mignella
31 appropriate under relevant federal requirements, incorporate all nine of the above noted
Model ESMP elements into their SIP or TIP. . . . . As set out in the [Regional Haze]
Rule, . . . . . Also, IN SUPPORT OF THE GCVTC Report goals, states and tribes should
consider these . . . .”
Section 1.2 2 25 Tribes may not need to incorporate all nine of the ESMP elements if they are not McKernan
applicable or appropriate.
1.2 2 26 The document incorrectly cites 64 FR 35771, § 51.309 (d) (6) (iv), by McKernan
including the states/tribes language
1.2 2 25 Is that states/tribes change to states/tribes and FLMs McLeod
& Per the Rule, states/tribes change to states/tribes and FLMs
2.1 2 26 for states/tribes change to for states/tribes and FLMs
38
2.1 2 37 The abbreviation “ESMP Policy” here defined is not used consistently through the Alston
document, and it is difficult to distinguish an ESMP in the general sense from the WRAP
ESMP proposed here. Suggest a wording change throughout the document from “ESMP
Policy” to “WRAP ESMP” or “WRAP ESMP Policy” for the latter, and checking all
instances of the acronym to determine proper reference.
2.1 2 37- Reword as: “The Model ESMP . . . .” [incorporate same changes as noted for Section Mignella
40 1.2]
Five (5) references are cited that were used in developing the draft ESMP Policy. Mitchell
2.1 2 40- However, in consideration of two (2) other contributing documents cited several times
43 elsewhere in the draft ESMP Policy, it seems appropriate to include these in this section
in addition to the 5 documents that are already cited. These other 2 documents are the
3 1-4 EPA’s “Interim Air Quality Policy on Wildland and Prescribed Fires” and the “Air
Quality Policy on Agricultural Burning”. If this revision is deemed inappropriate, the
draft document should make a clear distinction between how these two groups of
referenced documents were utilized in developing the draft policy. [Note: Look at mixed
bag of references in section 1.1 on page 1.]
Gruenig
2.1 2 42 A citation should be provided for the Recommendations in the footnotes on this same
page
Gruenig
2.1 3 3 A citation should be provided for the Regional Haze Rule in the footnotes on this same
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page
2.2 3-4 Very good section. This section may be critical to states/tribes that utilize the ESMP Campbell
Policy to develop their ESMP. This provides information that may be useful to gain all
stakeholders’ support of an ESMP for the SIP/TIP.
2.1 3 6 for states/tribes change to for states/tribes and FLMs McLeod
2.1 3 6-16 Reword as: “The Model ESMP is offered by the WRAP as a mechanism for states and Mignella
tribes to implement the requirements and goals of the Regional Haze Rule. This Model
ESMP is includes nine programmatic elements that are intended to be adopted in relation
to efficiency and economic considerations, applicable legal requirements, emission
reduction opportunities, . . . .” [incorporate other changes as noted in above sections,
again correcting for “ESMP Policy” by substituting Model ESMP].
2.1 3 6-16 This paragraph contains 3 sentences that have already been stated one or more times in Mitchell
the first five pages of text of the draft policy. There is no elaboration of any of these
statements here, just a repeat of things already said.
2.1 3 12 a state/tribe change to a state/tribe or FLM McLeod
13 haze SIP/TIP, change to haze SIP/TIP/FIP,
13 particular state/tribe change to particular state/tribe or FLM
14 to states/tribes change to to states/tribes and FLMs
2.2 3 20 Very awkwardly stated, although this is not my doc Hirami
2.2 3 20 for states/tribes change to for states/tribes and FLMs McLeod
26 for SIP/TIP change to for SIP/TIP and FIP
26 delete: the
27 delete: possibility of
28 add: sources, except in the case of a FIP
2.2 3 20- Incorporate changes as noted for Section 2.1 Mignella
28
2.2 3 24 Suggest revised language to read, “…to protect visibility in any area, including Class II Mitchell
areas or non-mandatory Class I areas.” This change would seem appropriate given that
states/tribes can utilize this policy for whatever air quality management purpose they
choose.
2.2 3 27 EPA intervention? EPA must review all SIP/TIPs. Are we fearful of intervention in Riley
every situation, or just regional haze?
2.2 3 30- Move this text to first section – delineation of purpose should be in first paragraph of Mignella
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38 document. Delete “WRAP Policy” – replace with “Model ESMP”
2.2 3 36 that states/tribes change to that states/tribes and FLMs McLeod
2.2 4 2 “integration of current emission…” continuing…”with the future implementation…” Dykzeul
2.2 4 5-10 Reword as: “The elements included in the ESMP have been selected IN AN ATTEMPT Mignella
TO address direct visibility impacts and regional haze in . . . .”
2.2 4 8& To stay consistent with the terms utilized in the Rule the word “percentile” should be Potter
10 changed to “percent”.
Gruenig
2.2 4 15 Either use a colon after “Rule” or place the quote in lines 17-19 in a footnote
2.2 4 21- The bulleted statement about the development of the ESMP Policy is less than Mitchell
27 comprehensive and it is not clear why it is structured in this way. A simple sentence
could capture the essence of the statement and make it more inclusive, such as, “This
ESMP Policy has been developed to embody appropriate regulatory and policy
requirements and to provide a predictable regulatory landscape that can be reasonably be
implemented by states and tribes.
2.2 4 29- These two paragraphs could be combined and revised to be more concise. Much of the Mitchell
43 content has already been discussed earlier in the document, including the fact that the
ESMP Policy adds consideration of visibility protection to the EPA Interim Air Quality
Policy and the Air Quality Policy for Agricultural Burning. The statements regarding
WRAP “advancing the ESMP Policy as sound air quality policy” are overused (not just
here, but throughout) and advises states/tribes that EPA will approve SIPs/TIPs that
contain the ESMP Policy elements. Unless the WRAP has official “buy-in” from the
EPA on use of the policy, the ESMP Policy should be careful in how it addresses EPA
approvability of state or tribal submittals. One of the main points of this discussion is the
“flexibility” the policy offers for states/tribes to adapt the policy to current or emerging
needs, but too many words are used to describe this attribute and the word “flexibility” is
not to be found.
2.2 4 40 I suggest using “requirements” instead of “barriers” as the latter is more value laden. Potter
2.2 4 Foot To be consistent with other footnotes that cite portions of the Rule the footnote should be Potter
note modified as follows “64 FR 35764, §51.301”. 64 FR 35764,
15 §51.301
2.2 4 27 • by states/tribes. change to by states/tribes and FLMs. McLeod
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2.2 4 32,3 Change wording to read: ESMP Policy to states/tribes and FLMs as sound air quality McLeod
3,& policy to address visibility and regional haze in mandatory and non-mandatory Class I
34 areas. As such, the ESMP Policy may be incorporated into regional haze SIPs/TIPs/FIPs
submitted to EPA in order to meet the requirements of the Rule.
2.2 4 39- Change wording to read: recognizes the difference among states/tribes/FLMs with McLeod
41 regard to air quality issues, emissions information, fire source sectors, and state
legislative or tribal governmental barriers. The WRAP also recognizes that the
SIPs/TIPs/FIPs will be revisited and revised, per the schedule
2.2 4 40 This paragraph provides excellent context for the WRAP ESMP Policy. I suggest adding, Alston
“The WRAP also recognizes the various statutory mandates under which land managers GCVTC Rept,
operate. p. 50 #8
2.2 Purpose 4 42 specified in the Rule, giving opportunities to refine their ESMP to reflect technical and Main
scientific advancement and policy changes updates.
2.3 5 3 fire in mandatory change to fire in mandatory and non-mandatory McLeod
2.3 5 3 The first sentence of this section leads one to think that the policy applies only to “fire in Mitchell
mandatory Class I areas”. The wording should be changed to read, “This ESMP Policy
applies to visibility impacts in mandatory Class I areas from fire anywhere in the WRAP
region.”
2.3. and 2.4.3 5 3-41 Many western ecosystems require periodic fire to maintain ecosystem function and McKinnon
6 1-5 resiliency. Land managers use naturally occurring fire or prescribed fire to maintain the
7 11- function and resiliency of these ecosystems. For these purposes, requiring an evaluation
16 of alternatives to fire would be antithetical to the very purpose of land management plans
seeking to use “natural” fire (as defined in the WRAP Policy on Categorizing Fire
Emissions). Accordingly, the “Alternatives to Fire” element should not be applicable to
fires qualifying as “natural” and the policy should be changed in two sections: 2.3 Scope
and Applicability, and 2.4.3, Alternatives to Fire.
2.3 5 5 Change sentence to read: produces that have impacts in its own mandatory and non- McLeod
mandatory Class I areas, as well as those that have.
2.3 5 11 General comment on agricultural burning: How to incorporate agricultural burning into Frandsen
ESMP could be a complex problem in Utah.
2.3 5 16- A space is needed between these two lines. Potter
17
2.3 5 17 “ESMPs recognize all fires contribute…” This is a very important point! Thanks for Doc Smith
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including it.
2.3 5 20- Minor sources are also an important point. Way too much time and energy could be Doc Smith
26 spent on developing controls for these emissions for little gain.
2.3 5 23 This term “Industrial Property” should be changed or at least described better. Plum Kuehn
Creek owns seven million acres of “Industrial Property”, but we will not be exempt.
2.3 5 23 Again question “industrial property” Dykzeul
2.3 5 24- Rephrase this sentence as follows “However, states/tribes may choose to consider … Potter
26 determining the applicability of an ESMP for visibility and regional haze.
2.3 5 31- The text of the document includes statements that contradict this one. To clarify and Mignella
32 make correspondent with other sections, reword as: “This variability emphasizes the
need for application of an ESMP framework that is also flexible while still addressing
relevant EPA requirements.”
2.3 5 32 This line is not clear to me. Is this the meaning? “…of a consistent smoke management Alston
framework, and applying ESMP in the WRAP region.”
2.3 Scope 5 34- Excellent idea of using projected or actual visibility impact of various source sectors Bernards
and App 40 within an individual state as a means for determining how a source is regulated.
2.3 5 34- This text is inconsistent with the sentence noted on lines 31-32 (rewording provided Mignella
39 above).
2.3 5 38 Delete the word “mandatory”, as this phrase is not in specific reference to the Rule. Potter
2.3 6 5 Change the word “submittal” to “approval”. Potter
2.3.1 6 7-26 The fire categorization section should briefly detail the WRAP fire categorization policy, McKinnon
namely which types of fires are natural and which are anthropogenic. It should also
discuss how ESMP will affect values other than suppression efforts—particularly
“natural” fire use for the purpose of maintaining and restoring fire-adapted ecosystems.
For example, will visibility considerations be conditionally added (as in the case of
suppression) or more restrictively applied to natural fire?
2.3.1 6 9-13 The Tribe does not support the WRAP Fire Categorization Policy. If the Tribe is to Mignella
support the WRAP’s ESMP document, references incorporating provisions of the Fire
Categorization Policy must be deleted from the text.
2.3.1 6 11 Insert the words “Preamble to the” prior to “Rule”. Potter
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2.4 7 13 I would re-word this, “Alternatives to fire (not alternative methods of burning)” It is Kuehn
confusing, at least for my pea brain.
2.3.1 6 15- I would suggest a change in wording: Campbell
17 According to the Wrap Fire Categorization Policy, wildfire that is suppressed by
management action is a “natural” source, and all fires must be managed to minimize
visibility impacts.
2.3.1 Fire 6 15- Should also mention the use of wildland fires managed to accomplish resource benefits. Main
Categ. 22
2.3.1 6 16 reword line as: “management action is a ‘natural source’ but nevertheless, must be Mignella
managed to minimize visibility”
2.3.1 6 16 insert: management action and wildland fire use to sustain ecosystems. Sandberg
2.3 6 18, The 2001 Federal Wildland Fire Management Policy says that the “appropriate Woodard
19 management response” to a wildfire must consider the “values to be protected.” Values
to be protected include environmental values, among several others. EPA has identified
visibility as an environmental value.
2.3 6 19- Generally agree with the concept that we have to manage the whole and not just the parts. Frandsen
20 We really need to recognize the overall need to manage the vegetation to meet the land
management objectives (private, state or federal), and this could greatly enhance or
hinder the smoke and haze issue. The anthropogenic approach where applicable is
needed.
2.3.1 6 19- The Tribe patently rejects this provision. Wildfire suppression action should NOT Mignella
22 include considerations for visibility unless these relate to public safety.
2.3.1 6 25 Question relative to natural background? How are Tribes addressing these conditions? McLeod
To what extent does this description of values to pertain to Tribes w/o air quality
programs or baseline data, i.e., differing geological & topographical conditions on Tribal
lands?
2.4 6 33 This sentence is not clear. Two suggested modifications are 1) delete the word Potter
“Additional” and start the sentence with “Suggestions” or 2) change the beginning of the
sentence to read “In addition to the elements descriptions that follow, suggestions…”.
2.4.1 6 39 Source. Change Four to read Five if acceptable McLeod
6 39 “…..source and management objectives.” Dykzeul
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Section 2.4 6-8 The 9 elements of an ESMP are very good. Woodard
2.4 7 1 Should add that States/Tribes have the option to adopt existing burn qualifications Hirami
programs rather than developing a new quals program.
2.4.1 7 1 ; and delete and McLeod
2.4.1 7 1 How much discussion took place on burner qualifications? Making this a requirement Gossard
would add to the vast amount of training already required to be a burn boss (and we
already get complaints on the existing amount of training. Also, how would this be
applied to the agricultural burners?
2.4.1 7 2 Add: ; and regional burn schedules communication between states/tribes and McLeod
FLMs.
2.4.2 7 9 Add: Communication between major burners, i.e., states/tribes and FLMs could be McLeod
another invaluable tool.
2.4 7 11- The alternative to fire may also be required as part of federal NEPA assessments. Frandsen
16
2.4.1 7 13 “….to fire, for reduction of fuels and potential emissions for forest health.” Dykzeul
7 13 Alternatives to fire need to be addressed at the decision making level (i.e. for the Federal Gossard
2.4.3 agencies it would be while they do their LUP). This is where the decision on burning vs.
alternatives takes place.
2.4.1 7 13 For clarity, change the opening line to “Alternatives to fire (not the alternative methods of Alston
burning discussed in (1) above)…”
2.4 7 14- It is not clear to whom the information is to be provided. Please clarify. Potter
15
2.4 7 15 Under Alternatives to Fire, it would be more appropriate to refer to “Land managers” Mitchell
rather than “Burners” when requiring an assessment of the feasibility of using alternatives
to fire. Land managers generally have a broader perspective of land management
techniques than would be expected of those whose jobs are related directly to the use of
fire.
2.4 7 21- Please provide the appropriate cite(s) for those interested in finding out what EPA Potter
22 requires for a certifiable SMP.
2.4 7 30 The use of “extensive modeling” is questionable in terms of the Air Quality Monitoring Mitchell
component. More explanation of this need would help enlighten readers on the intended
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use of modeling in this sense.
2.4 7 31 I suggest changing the word “less” to “little” to improve the readability of the sentence. Potter
2.4 7 31 reword as: “of smoke behavior as assessed visually. Minimal procedures . . . .” Mignella
5. Air 7 32/3 Minimal procedures would be most likely in areas of less burn activity or when farther Main
Quality 4 negligible smoke impacts occur to away from Class I areas.
Monitoring
2.4.5 or 2.4.6 There is no discussion of reporting the results of smoke monitoring. It could be discussed Alston
under “Air Quality Monitoring” (2.4.5) but may be better addressed under “Surveillance
and Enforcement” (2.4.6) since it will depend on the organizational structure developed
therein.
2.4.5 7 32 Activity or when farther away from Class I areas. change to read: activity; on Tribal McLeod
& lands where no capacity exist to monitor smoke impacts or when farther away from
33 Class I areas.
2.4.6 7 36 Relationship add: relationship and communication McLeod
2.4 7 42 Suggest changing to “Voluntary (burner self-enforcement)” Finneran
2.4 7 43 Suggest changing “Meteorologist” to “Coordinator” Finneran
2.4 7 43 Source sector regulator - Funding and mgt was not delineated in the “Funding” section. Hirami
Can’t assume that sources can provide if States/Tribes mandate this.
2.4 7 46 Suggest changing to “Mandatory (centralized authority)” Finneran
2.4.6 7 46 • Centralized regulatory authority Not acceptable to Tribes unless EPA assumes McLeod
this role. Maybe reword to: Centralized regulatory authority that includes
states/tribes and FLMs.
2.4 8 1-2 Delete these extra lines. Potter
8 14- New “authority” seems potentially restrictive to private sector who have continued a Dykzeul
24 static level of burning with emission improvements to now be competing with “marked
increases of federal prescribed fire treatments”.
2.4 8 14- A couple other factors that may be important to consider in terms of burn authorization Mitchell
16 requirements would be the frequency of burning and the timing of burning. These factors
are important considerations for eliminating visibility impacts at times of visitor use of
affected Class I areas.
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2 8 17 The proximity of non-attainment areas may also have a bearing on the type of burn Shipp
authorization system that….
2.4.8 8 17 May use change to will McLeod
2.4 8 17 Since Class I areas are not mentioned in this section, it would be appropriate to revise the Mitchell
second sentence to read, “The proximity of mandatory Class I areas and non-attainment
areas…”.
2.4.8 8 18 .Four broad levels change to. Five broad levels McLeod
8. Burn Auth. 8 21- Give brief description of levels or refer reader to Appendix C Section 8. Burn Main
24 Authorization
2.4.8 8 25 • Add bullet: Establish a burn coalition authority; tribes/states and FLMs McLeod
2.4 8 26 This Section on Regional Coordination should include reference to an equitable or agreed Hirami
upon manner for coordination.
2.4.9 8 31 Based add: on jurisdictional authority, McLeod
2.5 8 37 “SIPs/TIPs ‘must include…’” again inaccurately assumes TIPs meet the same McKernan
requirements as SIPs
Gruenig
2.5 8 42 A citation should be provided for locating the smoke management components in both
the EPA Interim Policy and AAQTF Recommendation of Air Policy
2.5 9 11 Modify the sentence to read “…repeatedly in the Preamble to the Rule and Rule as …”. Potter
Gruenig
2.5 9 12 Either use a colon after “goal” or place the quotes in lines 14-16 and 20-22 in footnotes
2.5 9 25 Change “managing” to “manage” and “minimizing” to “minimize” to improve the Potter
readability of the sentence.
2.5 9 25 typo: “necessary to managing smoke effects . . .” Mignella
2.6 9 31 I suggest using “requirements” instead of “barriers” as the latter is more value laden. Potter
9 40 ?…. Should be balanced by fair historical use. Dykzeul
2.6 9 42 What are the “above items” being referenced? Please clarify. Potter
2.6 10 2 Consider adding after the word “cost” – the word “incentives.” The rationale is that a Frandsen
mechanical treatment may be an alternative to prescribed burning and resulting haze, e.g.
chipping vs. burning. An incentive to do the more expensive method may be the
motivator to use the alternative source.
Outreach Process II - 309
Gruenig
2.6 10 4 A blank line should be inserted after line 4
2.6 ESMP 10 4 What are the economic gains from improved habitats, functioning watersheds, species Main
Consids. Gen diversity and healthy ecosystems? May want to consider some of the benefits of pro-
Description eral active management (hazardous fuel reduction, ecosystem health). Fire use for resource
benefit vs. catastrophic wildfire.
2.6 10 4-5 A space is needed between these two lines. Potter
2.6 10 4 Add “Can incentives be developed to utilize material from the site? Carbon Doc Smith
sequestration of products such as lumber, chips, wood fiber. Can incentives be developed
to burn in a more efficient manner while utilizing the material from the site such as
burning to produce electricity?
2.6 10 5-7 Some discussion of the needs and restrictions under the Wilderness Act should be added Mitchell
to this section on Law as a good example of Federal law that must not be violated.
2.6 10 5 Change sentence to read: Law: Are there state , local rules, Tribal Ordinances, or McLeod
statutes that prohibit mechanical treatments
2.6 10 5 Suggest “Legal” instead of “Law” Finneran
2.6 10 5 Re write this as Law: Are there federal, state or local rules… Then take out designated Gossard
and wilderness from line 16. The reason for this is that wilderness is not a Land Management
16 Objective but rather a legal designation established as law by Congress.
2.6 10 7 I suggest adding, “or to protect wilderness values under the Wilderness Act,” since that is Alston
another overarching issue many land managers must deal with (regardless of whether the
area is Class I or II).
2.6 10 9 these are fire alternatives NOT emission production techniques Sandberg
2.6 10 9 eliminate mention of chemical/biological. disproved in 1966 Sandberg
2.6 ESMP 10 9 Emission Reduction Opportunities: Where are the best and worst places opportunities to Main
Consids. consider reducing emissions through mechanical, biological, or chemical means?
Description
2.
2.6 10 13 ?…. Or a combination of mechanical treatments and maintenance burning. Dykzeul
2.6 ESMP 10 15 Land Management Objectives: Addition: Are the current Land Management Plans (Land Main
Consids. Use Plans, Forest Plans, Habitat Plans, Comprehensive Conservation Plans, Fire
Description Management Plans etc...) sufficient for management of fuels. Revision may be
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necessary.
2.6 10 16 Add after e.g., Tribal cultural values McLeod
2.6 10 19 Change sentence to read: e.g., Tribal cultural activities sites, areas targeted fro McLeod
commodity production or water shed protection.
2.6 10 19 Add “Are there places that restoration of ecosystem function may have a high priority?” Doc Smith
Add “In some cases will increases of wildfire emissions result from lack of prescribed
fire. Perhaps the treatment of some 30% of an area may stop wildfire from burning 100%
of an area.”
3. 10 Move this whole section to be a new Section 1. It helps to put the rest of the document Shipp
Background into context. Renumber all the other sections to follow.
3.0 10 24 Odd place to put the background info for this doc – but its not my doc. Hirami
Gruenig
3.1 10 34 A citation should be provided for locating the GCVTC Recommendations
Gruenig
3.1 10 37 Either use a colon after “basis” or place the quote in lines 39-40 in a footnote
3.1 11 FN What about Alaska? Should be mentioned that another 227 bands/tribes exist in Alaska. McLeod
37
3.1 11 4 Insert the words “Preamble to the” prior to “Rule”. Potter
3.1 11 7 Change the word “will” to “should”. Mitchell
3.1 11 10 “…. Acknowledged Federal land managers…..” Dykzeul
3.1 11 12 Change the word suppression to exclusion. This would alleviate any notion that Gossard
suppression is a bad thing.
3.1 11 22 I would change “to identify regional or common air management issues, develop and Gruenig
implement strategies to address these issues, and formulate and advance western regional
air policy positions” to “with identifying regional or common air management issues,
developing and implementing strategies to address these issues, and formulating and
advancing western regional policy positions”
3.1 11 Foot I believe the correct cite is “64 FR 35748”. Potter
note 64 FR 35748
32
Gruenig
3.1 11 Fn. The figure corresponding to the number of tribes within the WRAP region is inaccurate.
37 With the inclusion of Alaska, the number of tribes is well over 400.
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3.1 11 Foot If this information is so important can it be incorporated into the text of the document? A Potter
note 13-line footnote seems a little excessive and tends to throw the reader off from the train
39 of thought in the document if one stops to read it.
Gruenig
3.1 11 Fn. In the second sentence, “tribe’s” should read “tribes’”. In other words, the current
39 apostrophe is misplaced
3.1 11- 20- move text forward in document – make as part of introductory text Mignella
12 26,1
-2
3.1 12 10 Either use a colon after “Rule” or place the quote in lines 12-14 in a footnote, perhaps just Gruenig
citing back to footnote 27 where it is already included
3.1 12 17 Reword as: “model tools to facilitate implementation of the Regional Haze Rule in the Mignella
area comprising the WRAP region.” WRAP does not establish “policy” as per EPA.
3.2.1 12 FN I believe there is an extra comma after “p.” that should be deleted. Potter
43
Gruenig
3.2.1 13 3 Place a blank line after line 3
3.2.1 13 3-4 A space is needed between these two lines. Potter
3.2.1 Current 13 5-7 An integral part of both the EPA Interim Policy and the AAQTF Recommendation on Air Main
Smoke Quality Policy is the clear guidance to consider the visibility effects of burning when
Management planning burning operations, and to consider alternatives to burning as well as the of use
Guidance of other emission reduction practices.
3.2 13 18- This text is somewhat misleading. A clearer wording is: “ To date, EPA has not Mignella
19 comprehensively integrated regional haze considerations outlined in the Rule with its
own Interim Policy. However, in September, 2001, EPA issued its “Draft Guidance for
Estimating Natural Visibility Conditions Under the Regional Haze Rule.” This
document clarifies EPA’s vision of the regulatory treatment of fire emissions in relation
to regional haze considerations.” Why is this document never referenced in the WRAP
document?
3.2.2 14 3 The idea of a centralized authority making decisions on which fires can be burned and Gossard
which can’t, will meet some resistance. I know several land managers who take the
position that a “centralized authority” can make calls on air quality but have no place
making go – no/go decisions for specific projects. If air quality is going to be a problem,
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they will work out which fires get done and which don’t.
3.22 14 7 Add the word “only” after “surveys”. Mitchell
3.22 14 8-10 In this second half of the sentence that began on line 7, are smoke management programs Mitchell
for private rangeland burning less common than agricultural smoke management
programs in the WRAP region? If so, then this statement should be clearly made. The
way this sentence is currently structured, the meaning is vague and open to
misinterpretation.
3.2.2 14 14- This sentence needs to be more specific. It now reads “Since air quality problems have Mitchell
16 common precursor pollutants…”, and it is too general to be useful or correct.
3.2.2 14 18- Hasn’t all this been stated before? Suggest that only new language/ideas be retained, if Mitchell
24 any.
3.2.2 14 20 Insert the word “an” before “ESMP”. Potter
3.2.2 14 21 Clarify that this only applies to section 309. Riley
3 14 28 Re-title the background information that is provided directly under section 3.3 starting at Shipp
Background line 28 to “3.3.1 Rule Requirements to Address Fire”
3 14 28 Edit this section as follows: Shipp
Background Section 309 of the Rule requires states/tribes to address
visibility impacts to mandatory Class I areas due to
emissions from fire activities. Section IV, Treatment of
the GCVTC Recommendations, of the Rule Preamble emphasizes
“ t he implementation …
3.3 14 32 This is the first time the acronym BACM is used in the document. Please insert the words Potter
“Best Available Control Measure (BACM)” for those who are unfamiliar with the
acronym.
3.3 Rule 14 32 Spell out BACM Best Available Control Measures Main
3 14 37 Move this paragraph in front of the prior paragraph. Shipp
Background
3.3 14 FN The correct title of this document is “Prescribe Burning Background Document and Potter
51 Technical Information Document for Prescribed Burning Best Available Control See Comment
Measures” and can be found at http://www.epa.gov/cgi-bin/claritgw?op-
Display&document=clserv:epa-cinb:1681;&rank=4&template=epa.
3.3 14 FN Delete “EPA’s … May 2002” and replace with “67 FR 30418, May 6, 2002.” Potter
52 67 FR 30418,
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May 6, 2002
3.3 14 FN EPA published its proposed approval of the “Annex” in the Federal Register on May 6, Alston
52 2002
3.3.2 & 3.3.3 15 & These sections are great. It is helpful to provide the WRAP’s endorsement of this policy Campbell
16 as a tool to address the requirements of the Rule.
Gruenig
3.3 15 4 A citation should be provided for locating the requirements mentioned for both 308 and
309
Gruenig
Section 3.3 15 4 Because a number of specific items are mentioned in the sentence, a citation should be
provided.
3.3 15 4-5 The last sentence in this section could be deleted without any harm to the policy, since it Mitchell
has been said in a fashion several times already.
3.3.1 15 7 missing element of ESMP Sandberg
3.3.1 15 7 should include parametric monitoring Sandberg
3.3.1 15 14- Change the word “tracking” to “track”, insert “determine the” prior to “effectiveness”, Potter
15 and change “calculation” to “calculate”.
3.3.1 15 15 visibility conditions, as well as, modeling for PM10 and PM2.5 SIPs Shipp
Gruenig
3.3.1 15 16 A citation should be provided for locating the requirements mentioned
3.3.1 15 18 This paragraph is a critical issue – glad you addressed it! Alston
3.3.1 15 24 I would suggest adding the scheduled completion date of the emissions tracking Campbell
guidance.
Gruenig
3.3.2 15 30 I would suggest placing “Section” and “309” on the same line for better appearance
3.3.2 15 34 It may be helpful to readers’ understanding of this statement by providing an example at Mitchell
the end to read, “(e.g., regulation of agricultural activities is statutorily prohibited in
many of the WRAP states).”
3.3.2 Sect 15 38 I suggest changing “annual emissions goals” to “annual emission goals” which is Bernards
309 consistent with RHR.
3.3.2 16 4 Emissions Tracking should be in all lowercase letters. Potter
3.3.2 16 4 I would suggest adding the scheduled completion date for the ERT tracking guidance. Campbell
3.3.3 16 8-10 Delete second sentence of paragraph (maybe the 6th reference to WRAP advancing the Mitchell
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ESMP Policy…).
Gruenig
3.3.3 16 14 To accurately reflect the quote, “state” should be “State”
3 16 14- Switch the order of the two sections of rule that are stated. Shipp
Background 23
3.3.3 16 14- “[/tribe]” inaccurately inserted, this is not how 64 FR 35767, § 51.308 (d) (3) (iv) McKernan
23 reads. EPA did not overlook Tribes in this rule. Had
Tribes been intended to be subject to all provisions of the
RHR the word Tribe would be explicit in language.
Gruenig
3.3.3 16 17 To accurately reflect the quote, “states” should be “States”
3.3.3 16 25- FLMs should be required to coordinate burn activity with tribes and states to insure good McLeod
30 modeling results.
3.3.3 16 29- Last sentence should be revised/deleted in consideration of judging EPA’s “approve- Mitchell
30 ability” of ESMP Policy adoption by states/tribes.
3. 16 32 Move section 3.3.4 to begin immediately under the section heading of 3.3 The Regional Shipp
Background Haze Rule. Again, it helps to put what follows into context.
3.3.4 16 37 Delete the “;” after techniques and modify to read “…techniques to demonstrate Potter
reasonable…”.
3.3.4 I suggest changing “identification of necessary emission reduction techniques;” to Bernards
SIP/TIP 16 37 “identification of necessary emission reductions; identification of control strategies to
achieve emission reductions; demonstration of …”
3.3.4 17 1 The 5-year review is conducted by the states/tribes and submitted to EPA. Modify this Potter
section to read “5-year state/tribe review of reasonable…”
Gruenig
3.3.4 17 2 A citation should be provided for locating the steps of the SIP/TIP process
3.3.4 17 7 Add: , and FIPs should be treated same. McLeod
Gruenig
3.3.4 17 11 A citation should be provided for locating the deadline date of December 31, 2003
3.3.4 17 12 Replace the dash with the word “through” to improve the readability of the sentence. Potter
Gruenig
3.3.4 17 11 This is an inaccurate characterization that tribes must comply with the deadline of
December 31, 2003
3.3.4 17 12- This is an inaccurate characterization that tribes must comply implement all TIP measures Gruenig
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13 between December 31, 2003 - December 31, 2018
Gruenig
3.3.4 17 13 Placing two footnotes together is confusing. The material cited in footnote 64 should be
embedded into footnote 63
3.3.4 17 13- This sentence should be revised to read “Further, all mandatory Class I areas in the Potter
14 GCVTC Transport Region other ... may be addressed..."
3.3.4 17 14 Add: Tribes are exempt from the 2008 deadline based on EPA guidance, unless McLeod
application for TAS is approved by EPA and covers the regulatory module of an air
quality program.
Gruenig
3.3.4 17 14 A citation should be provided for locating the reference to mandatory Class I areas other
than the Colorado Plateau 16
Gruenig
3.3.4 17 19 A citation should be provided for locating the information relating to PM 2.5
Gruenig
Section 3.3.4 17 19 This is an inaccurate characterization that tribes must comply with the December 31,
2008 deadline for 308 TIPs
3 17 20 Add footnote with citation at bottom of page. Shipp
Background 64 FR
35765, §
51.308
(b)
(1),(2)
Gruenig
3.3.4 17 20 A citation should be provided for locating the information relating to PM 2.5 and
mandatory Class I areas
3.3.4 17 21 Add: Tribes are exempt from deadlines. McLeod
4 17 26- Insert the word “appropriate” after “the” and change “of” to “for”. Potter
27
4.1 17 33 through its SIP/TIP, add: and TAS delegation granted for tribes by EPA, McLeod
4.1 17 35 In the example of other entities that could implement the ESMP in an area, other state Mitchell
agencies should be added to the list (like a Department of natural resources or forestry)
and perhaps the policy could elaborate briefly on when it might be appropriate to delegate
such a function to a non-governmental agency, as provided for in the draft Policy.
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4.1 17- It would seem appropriate that the regulatory authority’s responsibilities would include Mitchell
18 consultation with FLMs of affected Class I areas, but there is no reference to this need in
the Policy.
4.1 18 4 Add: Tribes will require dedicated funding allocation to provide from McLeod
implementation of ESMPs.
4.1 18 6 What is meant by “The greater the impact to visibility in mandatory Class I areas”? Does Mitchell
this include consideration of the timing, frequency, magnitude, extent, and duration of
impacts to Class I areas? How is this determined and by whom?
4.1 18 6& Delete the word “mandatory” in these two locations, as these phrases are not in specific Potter
9 reference to the Rule.
4.1 18 10 Add after oversight and, Tribal funding McLeod
Gruenig
4.1 18 17 There should be no quotation marks for a blocked quote
4.1 18 17- This is the only quotation that is indented within the text that has quotation marks around Potter
24 it. For consistency, delete the quotation marks.
4.1 18 26 This sentence is unclear. Add examples to illustrate or reword. Mignella
18 38- Since we are protecting the users of the Class 1 areas, there should be some option or Dykzeul
43 considering who is benefiting from these recommendations….. even small fees for Class
1 users.
4.2 18 38- Subsections (B - Grants and/or Appropriated Funding), and (C - Provisions of Resources) McKinnon
19 45 of the Funding Mechanisms section need a level of specificity equal to that in (A - Funds
2-29 obtained from users of prescribed fire). Which grants and from whom? Appropriated
funds to which programs in which agencies? Specific funding sources should be
identified. The lack of detail in (B) and (C) combined with the detail of (A) suggests that
users of prescribed fire are currently the preferred funding source for ESMP. Rather than
instituting funding requirements from the “bottom up” as section (A) seems to suggest
(with burn-plan- by-burn plan fee collection), this section should seek a more effective,
efficient, and administratively inexpensive alternative that draws ESMP funding from
National Fire Plan fuels reduction funding as it is allocated to federal, state, and tribal
agencies each year.
4.2 18, 2- Funding mechanisms: While charging for emission or acres may be a way to cover Frandsen
19 29 funding options, it could penalize prescribed fires and inhibit action; that could result in
wildfire adding more haze to an already overloaded system. Let’s not tax the system and
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make a larger problem.
4.2 19 Funding sources identified - shouldn’t States/Tribes be considered a funding source as Hirami
well?
4.2 19 3 Federal agencies cannot move money thru a MOU. We have to develop interagency Gossard
agreements to move money.
4.2 19 5 There is also an option to pay fees with no per acre addition. Doc Smith
4.2 19 5-19 Fee language referencing per acre assessments is not appropriate. The ESMP overall goal Stephens
is emissions reduction/visibility enhancement. Any fee focus should be on emissions not
acres. All acres are not the same and do not necessarily receive the same amount of or
level of fire treatment – i.e. understory burns, maintenance burns, as well as mosaic
burning where large islands and fingers of vegetation are purposely left unburned within
a burn project’s acres or perimeter. As the focus should be emissions affecting visibility,
acres are different in terms of fuel type, fuel loading, as well as emission reduction
techniques used and pretreatment specified. Therefore, potential emission yield varies
widely and per acre fee assessment is not valid or rational. Our Department has strong
concerns over any funding mechanism policy statement encouraging this direction.
Suggest that State Regulators seek additional general fund appropriations from their
respective State Governments.
4.3 19 31 General: Include that States/Tribes must identify significant contributors. Are the Hirami
degrees of implementation equitable across contributors to visibility impairment and RH?
4.3 19 31 Would change the title to “Implementation Criteria and Considerations”. Finneran
4.3 19 33- The second sentence of this paragraph makes it sound like you can pick and choose from Potter
35 the nine elements, which I don’t think is the correct interpretation of the Policy. Please
modify the sentence to read “…may develop its ESMP with these elements …”
4.3 19 37 Although ESMP elements can be applied differentially, they should still be applied Alston
consistent with the equity considerations on page 18. This could be emphasized by
changing wording to “geographical areas, consistent with equitable treatment of sources.”
4.3 19 37 Suggest revising the sentence as follows: “Since fire sources that contribute to regional Finneran
haze may be from different geographical areas, the partitioning of a geographic area may
be considered under this policy.”
4.3 19 41 This sentence suggests a state/tribe can determine that a fire source is “not a contributor” Finneran
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to visibility impairment and regional haze. This seems contrary to the regional haze rule,
which suggests ALL FIRE contributes to regional haze to some degree. Therefore, I
would delete this sentence and the remaining sentences in the paragraph starting on line
41. The following is suggested language: “Although this policy recognizes that some
fire sources may contribute less to regional haze that other fire sources, there is a
presumption that states and tribes should consider the adoption of all 9 elements of the
ESMP as a starting point when developing their SIP/TIP. The exception to this may be
where a state/tribe is currently without any smoke management program in place. Only
after careful consideration of the factors listed in Section 2.6 of this policy, and the
criteria listed in this section, should states/tribes choose not to apply any of the 9 ESMP
elements.”
4.3 19- 41- This paragraph is a repeat of previous statements. Mitchell
20 45
4.3 19 to Section 4.3 “Implementation Options” needs major reworking. WE HAVE MAJOR Finneran
22 CONCERNS ABOUT THIS SECTION. This part of the document is critical because it
lists criteria for states/tribes to determine which of the 9 ESMP elements might not be
included in the SIP/TIP. We question the need for the statement “preventing the over-
regulation of a fire source” on pg 19, line 41. We think emphasis is needed on the
importance of implementing ALL OF THE 9 ESMP elements whenever possible. Not
only is this message absent, but the 3 “thresholds” described in pages 19 to 22 are unclear
as to how they would be applied by the state/tribe in evaluating ESMP elements. While
the intent in this section is to be non-prescriptive, vague references to stationary source
requirements are not going to help states/tribes in ESMP implementation. The following
comments attempt point out the problems in this section, and also suggest new language.
4.3 20 1 Change ESMP is to read ESMP in McLeod
4.3 20 1 The wording should be: Campbell
The application of the ESMP isin this way…
4.3 Imp Ops 20 1 The application of the ESMP is in this way would be at the discretion of the state or tribal Main
regulatory authority.
4.3 20 1 Change ESMP is to read ESMP in McLeod
4.3 20 2 Add after tribal or Federal regulatory authority. McLeod
4.3 20 1-2 This is a great sentence. However, I think it has been placed incorrectly at the end of this Potter
paragraph and should be moved to the end of the first paragraph in Section 4.3.
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4.3 20 2 Add after tribal or Federal regulatory authority. McLeod
4.3 20 4 The reference to the WRAP Fire Categorization policy in this paragraph makes no sense. Finneran
How exactly does the ESMP policy tie into that policy? This either needs to be
explained, or the paragraph deleted.
4.3 20 4-11 See notation above relating to Section 2.3, page 5. Mignella
4.3 20 5 Safety before economic….. Dykzeul
4.3 20 6 Add after state to state, tribe to tribe, McLeod
Gruenig
4.3 20 6 “tribe to tribe” should be added to the sentence
4.3 20 13 Suggest changing the paragraph to read “Three sets of criteria are offered to help Finneran
states/tribes determine how comprehensive of a program is needed. These criteria are not
prescriptive, but rather are meant to assist states/tribes in evaluating the need to adopt all
9 ESMP elements. Any decision not to adopt certain ESMP elements must be explained
and justified by the state/tribe.”
4.3 20 13- Change sentence to read: Three possible pathways are offered to help a state/tribe/FLM McLeod
14 evaluate how comprehensive a program needs to be in their jurisdiction and to determine
4.3.1 20 21 I would change the title to “Reasonably Attributable Contribution” Finneran
4.3.1 20 21- This section is difficult for me to understand. I think you should make an effort to Doc Smith
40 reword this section so it is easily understood.
4.3.1 20 23 Suggest revising the paragraph to read: “Under this approach, there is clear evidence that Finneran
a certain fire source may contribute to regional haze, based on computer modeling, air
quality monitoring, emissions calculations and meteorological trajectories. In such cases,
the full application of all 9 ESMP elements should be considered.”
4.3.1 20 25 involving the analysis of air monitoring data Shipp
4.3.1 20 29- Fire is not analogous to a stationary source, nor does EPA deem it to be such. Therefore, Mignella
30 the comparisons provided should be revised.
4.3.1 20 29 The list of “emission control considerations” listed here needs considerable explanation Finneran
as to how these stationary source requirements would be applied in the “real world” to
smoke management programs. For instance, the bullet “the recurring nature of a burn on
a particular parcel of land” could be explained in terms of the “fire return interval” in a
particular geographic area. Without a clear description of how each of these bullets
apply to ESMP determination, they add nothing to the section and should be deleted.
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4.3.1 20 31 • Add: The impact to Human Health McLeod
4.3.1 20 32 Should point out that the technology also means fuels treatment technology. Dykzeul
4.3.1 20 32 The ideas in line 32 should be combined with those in lines 35 and 36. Woodard
4.3.1 20 32- What is the relationship of these criteria to the ESMP criteria (section 2.1, page 2)? Use Riley
40 one or both sets of criteria in example(s) rather than prescribing the actual criteria.
4.3.2 20 42 Would change the title to “Situational Factors” Finneran
4.3.2 20 44 Suggest the paragraph to read: “Under this approach, there may be certain circumstances Finneran
where the magnitude and/or proximity of a fire source to Class I areas may necessitate the
full application of all 9 ESMP elements. One example of how this could be assessed is
by comparing to the Prevention of Significant Deterioration (PSD) permitting
requirements for major stationary sources”. [see comments below]
4.3.2 21 all Please explain how this situational criteria came to fruition and what the criteria is based Baldwin
upon.
4.3.2 21 All The emissions and distance criteria identified on this page for a fire source raises many Finneran
questions and concerns. What potential visibility impacts could occur using this criteria?
Is it appropriate apply criteria for year-round point sources to intermittent area sources
like fire? How would examples (a) thru (d) be used by state/tribes in actually evaluating
the 9 ESMP elements? WE HAVE MAJOR RESERVATIONS ABOUT USING THIS
CRITERIA WITHOUT FURTHER DISCUSSION AND STUDY. The table at the
bottom of the page translates emission levels to acres burned. If example (a) were
applied to agricultural burning, 50 tons would equal 2,500 acres. This is a large amount
of burning, and at 50 km major visibility impacts would expected. Even at 150 km the
visibility impact could be very significant. Whether ANY of these distance and emission
level criteria are appropriate to use for a fire source is very debatable. Providing
examples that are not carefully evaluated from a visibility/regional haze standpoint is not
recommended and could seriously undermine the objectives of the ESMP Policy.
4.3.2 21 3-4 A space is needed between these two lines. Potter
Gruenig
4.3.2 21 3 A blank line should be added after line 3
4.3.2 21 3 “trigger the need for an ESMP” Is this option determining if an ESMP is needed or not? Riley
How would I use this for determining level of implementation of each of the 9 elements.
4.3.2 21 4-34 The example provided is a nice concept, but there are significant problems associated Mitchell
with it as there are problems with the PSD program being protective of Class I areas. A
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couple of major issues are: 1) PM 2.5 should be used in addition to, or instead of, PM 10;
and 2) total annual emissions are not as important as shorter-term emissions, especially
for recurring activities near a Class I area. Visibility impacts are not well represented
using annual emissions to derive short-term emissions, especially for a sporadic area
source like fire.
4.3.2 21 6 Change parenthetical statement to read “see table in footnote below”. Potter
4.3.2 21 12 In a-d there you have tons/yr of PM10, but it is not clear if this is per source or all Kuehn
sources.
4.3.2 21 12 All states are within 50 km of a Class I area. How would this be implemented? Doc Smith
4.3.2 21 12- Use these numbers to provide an example for applying this option rather than prescribing Riley
30 the actual details. How do I use this system, emission levels and attainment status and
proximity all have to be yes, or any one of these yes?
4.3.2 21 14 Add after NAAs or PM2.5 McLeod
4.3.2 21 17- Need a requirement level for PM2.5, would these levels established be inclusive of PM2.5? McLeod
30
4.3.2 21 32- Other options – automatically need ESMP or us other options to determine level (4.3.1 or Riley
33 4.3.3).
4.3.2 21 FN Are the numbers of acres burned for agriculture and rangeland really the same? At first Potter
67 glance it looks as if it may be a typo. If the numbers are correct, I suggest varying the
tons/acre consumed to vary the respective acreage burned to arrive at the set emissions
levels for either the agriculture or rangeland example.
4.3.2 22 1-2 Delete these extra lines. Potter
4.3.3 22 4 A good approach to determining ESMP intensity level. Stephens
4.3.3 22 4 Would change title to “Impact Considerations” Finneran
4.3.3 22 4-32 Consideration should be given to allowing FLM observations and feedback to regulatory Mitchell
authorities for helping determine the need for a “stepped up” level of effort in a
state/tribal ESMP.
4.3.3 22 6 Using some measured level of visibility impact in evaluating the need for all 9 ESMP Finneran
(all) elements may be acceptable, if it can be shown that a particular fire source has minimal
impact on regional haze. However, we do not believe setting a one-deciview impact
threshold is consistent with the regional haze rule. Unlike mobile sources and dust
source which have to be found to “contribute significantly to visibility impairment”, the
rule does not allow for a “significance” level for fire sources. Establishing a one-
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deciview impact threshold for fire source is creating basically a de facto “significance”
level. Even if this were allowed under the rule, we see no basis or technical justification
to why one deciview would be acceptable from a visibility standpoint. Therefore, we
suggest this be removed from this section, and suggest the following:
No change to lines 6-12. Starting on line 14: “An impact level could be used by the
state/tribe to determine if the full application of all 9 ESMP elements is not necessary.
Such a level would determined by the state/tribe as where the contribution of fire
sources/pollution (excluding wildfire) to the 20 percent worst days is negligible or
insignificant as to not require full ESMP application. Then delete down to line 21. No
change to line 22 which begins “In order to determine this impact….” and keep this
sentence. [additional language may be needed to complete this section]
Gruenig
4.3.3 22 7 Either use a colon after “areas” or place the quote in lines 9-12 in a footnote
4.3.3 22 14- Question? How are tribes to handle this if they elect ESMPs but have no base line data? McLeod
20
Gruenig
4.3.3 22 17 A citation should be provided for locating the information within the PSD process
requirements
4.3.3 22 19 Insert the word “visibility” between “worst” and “days”. Potter
4.3.3. 22 22- Comment: This holds true especially for Tribes because increased IMPROVE Sites are McLeod
26 being developed on Tribal lands.
4.3.3, 22 23 IMPROVE monitored data, receptor and/or dispersion modeling, Shipp
Appendix C
Page 24, General---IMPROVE data is not an end to itself, there must be some analyses done to use
General it, wherever the document states that improve data is used it should be stated how it is
used. In this case the analyses would use modeling, in other cases the use may involve
statistical or objective analyses.
4.3.3 22 24 Not all IMPROVE data need have a long time lag, especially as related to smoke Alston
management. Nephelometers in the network are calibrated weekly and thus produce
reliable raw data. Although transmissometers are not calibrated frequently, their raw data
is still useful in real-time situations to monitor conditions and establish trends. Add the
word “final” before “IMPROVE.”
4.3.3 22 24 Lag time – 3 months, 1 year, 3 years? Riley
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4.3.3 22 32 Reasonable progress related to improving worst days (no degradation on best days). Riley
General I did not review Appendices A or B Doc Smith
Appendix A 24 21 ..”human activities and man made decisions.” Dykzeul
Appendix A 24 23 ….- One of 2 categories that designates” Currently sounds like only Anthro. Causes Dykzeul
impairment!
Appendix A 24 27 “…. Classification can include both natural and human…” Dykzeul
Appendix A 25 4-5 A space is needed between these two lines. Potter
A 25 15 replace “wildfire” with “wildland fire” (not unwanted) Sandberg
Appendix A 25 23 Remove definition of “deciview”. Finneran
Glossary 25 27 Rename this Ecosystem Maintenance Burning Gossard
Appendix A 25 27- I disagree with this definition. “A prescribed fire or wildfire managed for resource Kuehn
Glossary 29 benefits, in an ecosystem that is currently in an ecologically functional and fire
resilient condition, that is utilized to mimic the natural role of fire.” I noted my
objection during the Categorizing Fire Emission Task team report. My fear is that
managers will burn an area once and call it in “Ecosystem Maintenance” and all
subsequent fires will be “natural.” If it is to be in true maintenance and “Natural”, fires
much mimic the historic role fire had. An example would be an area traditionally ignited
by lightning in July or August and burned on a 5-10 year fire interval. Now we are
burning it in April and maybe on a 20 year interval. This does not mimic the natural role
fire played in that ecosystem and should not be called maintenance and thus “Natural”.
I suggest this: “A prescribed fire or wildfire managed for resource benefits, in an
ecosystem that is currently in an ecologically functional and fire resilient condition,
that is utilized to mimic the natural role of fire including ignition timing and
interval.”
Glossary 25 33 “…. Due to lack of management action.” Dykzeul
Glossary 25 35 “…..functional, “historical” and fire …..” Dykzeul
A 26 1 unit of area treated or other objective unit of accomplishment Sandberg
Glossary 26 25 I’d drop the end of the sentence it’s redundant. …at 212 degrees F. Use “Bone Dry” if Kuehn
you want to replace it.
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Appendix A 27 20 The National Visibility Goal is not the same as the Natural Visibility Goal. The definition Potter
of the National Visibility Goal should read as follows “Section 169A of the Clean Air Act
sets forth a national goal for visibility which is the “prevention of any future, and the
remedying of any existing, impairment of visibility in Class I areas which impairment
results from manmade air pollution.”.
Appendix A 27 27 “….classification can include both…..” Dykzeul
Appendix A 29 9-11 Add: Tribal Authority Rule and McLeod
Treatment as States
Appendix B 30 Add: Tribal Authority Rule and Treatment as States McLeod
http://www.epa.gov/fedrgstr/EPA-AIR/1998/February/Day-12/a3451.htm
Appendix B 30 25 Go to the Fire Emissions Joint Form Forum, then Task Teams, then Natural Background. Main
Appendix B 30 30 Go to the Fire Emissions Joint Form Forum, then Task Teams, then Basic Smoke Main
Management.
Appendix B 30 34 Go to the Fire Emissions Joint Form Forum, then Task Teams, then Natural Background. Main
Appendix B 30 43 Go to the About WRAP, then WRAP Boundaries and Regional Visibility Planning in the Main
West.
General Throughout the document emission goals is used. This is a poor choice of words Shipp
Appendix C implying that projects should have goal of reaching a certain emission level. Goal should
be replaced by cap.
Appendix C Gen Moving these to the appendices works out much cleaner. While the options to use some Baldwin
of the suggestions are there, it is less likely that they can be misinterpreted as mandatory.
Appendix C As I found myself preparing these comments I started to wonder if my comments on Potter
Section 1 in the main body of the text would be confused with Section 1 in Appendix C.
To avoid future confusion consider renumbering the sections in Appendix C as C1., C2.,
etc.
Appendix C The secondary heading (such as “Emissions Reductions Techniques”) in Section 1, 8, and Potter
9 tend to get lost in the text. Consider number the sections as C1.1, C1.2, etc. and
reformatting the headings to make them stand out from the other text.
Appendix C 31 2 Implementation Guidance: It should be stressed for all nine elements of the ESMP that Stephens
any implementation recommendations are just that—recommendations, they are not to be
construed or encouraged (This should be stated) to ever become mandatory or States to
consider making them regulations, as in one size fits all. This is extremely important in
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that all prescribed fire users are not the same. In CDF’s case we are not a land manager
and we conduct fuel hazard reduction burns on private and in certain circumstances other
public lands. We enter into contractual cost-share agreements with these Cooperators.
1 31 14 Insert the words “to be” in between “ESMP” and “included”. Potter
Appendix C 31 17- Consider changing sentence to read: Campbell
18 Emission reduction techniques may be as simple as changing the ignition timing allowing
to allow for more efficient combustion.
Appendix C 31 22 Emission Reduction Techniques: It should be stated that for this strategy as well as the Stephens
other strategies addressed for Line 12, Section 1, Page 31, Actions to Minimize
Emissions from Fire that while States are encouraged to consider the options presented,
they need to understand that not all options specified are available to all prescribed
burners. CDF burns under a variety of legal, sociological and environmental
requirements. For example see next comment.
1 31 27 Insert the word “associated” between “and” and “emissions”. Potter
1 31 29 Insert the word “associated” between “and” and “emissions”. Modify the ending of the Potter
sentence to read “defined in policies developed by FEJF.”
Appendix C 31 31 It is important to note that CDF does not target forestlands for burning or own the lands Stephens
burned so that firewood or firewood access to the public isn’t a viable option, and the
fuels are not generally as accessible, available or cost-effective as a biomass option. CDF
does not enter into cost-share agreements for chemical use and as a fire protection agency
we receive no funding for burn projects and are expected to meet our portion of burn
costs with the resources on hand—personnel, supplies and equipment. Timing of burns is
often constrained by our resource availability and our consideration of wildlife values,
i.e.—nesting seasons.
App C, 1 32 9 Why are burn piles the last resort. They burn hotter and more efficiently. Riley
App C, 1 “ 13 Documents (plural). Riley
1 32 13 Why is “Alternatives to Burning” italicized? Potter
Appendix C 32 15 Smoke Management Guide for Prescribed Wildland Fire, 2001 Edition (in press).70 Main
If possible give future website for publication in footnote.
Appendix C 32 16 There are two reference citations for forest prescribed burning. Please include references Hirami
for Ag emissions reduction techniques as well.
Appendix C 32 17 Burn Manager Qualification: CDF’s Vegetation Management Coordinators do meet our Stephens
Department standards addressing Air Quality/Smoke Management with the NWCG Rx-
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450 Smoke Management Techniques recognized for prescribed fire applications. While
State Regulatory Agencies may consider state approved smoke management workshops,
these Guidelines or the State Regulatory Agencies have no business establishing Burn
Manager Qualifications—WE ARE THE PRESCRIBED FIRE EXPERTS, not air
resource entities. CDF establishes who is qualified to conduct a CDF prescribed burn
project.
C 32 19 Strike the word “create” a burn manager qualification program. The FLMS have an Hirami
extensive/sophisticated quals program that States/Tribal officials in Fire Management
already recognize. The State/Tribal AQ managers should recognize this quals system as
well. States/Tribes should not be encouraged to create another one.
Appendix C 32 19 “…..create a voluntary burn manager….” Dykzeul
32 32 “ ….should acknowledge an “grandfather” ability to recognize experience. Dykzeul
Appendix C 33 4-10 Certification requirements implies that States/Tribes have a qualified person to certify Hirami
burn qualifications.
Appendix C 33 11 1. Actions to Minimize Emissions from Fire Doc Smith
Burn Manager Qualifications
Provide some sort of review of burn manager performance. Perhaps every 3 years,
maybe annually, to rate actual performance and to maintain qualification or certification.
Appendix C 33 12- It would appear that the Policy is focused on controlling (mitigating) the impacts of fire, Stephens
39 be it prescribed or uncontrolled, without considering the positive impacts that an 1992 Old
aggressive prescribed fire management program may have on the problem of haze in the Gulch Fire &
long term. Reducing the uncontrolled release of smoke and particulate associated with others.
large uncontrolled fires is an appropriate mitigation for improving air quality. CDF poses Utilizing
the questions: “Should state and tribal groups consider an aggressive prescribed fire FARSITE
program an integral part of the ESMP and SIP/TIP strategy?” “Should an aggressive spatial growth
prescribed fire program be one of the elements that are looked upon favorably by simulator
controlling agencies?” CDF believes the answer to these questions is yes. Page 33 model—
provides a discussion of “Incentives.” What has failed to be mentioned as an incentive is shows proven
conducting prescribed burns with professionally designed burn and smoke management reduction in
plans—where we choose the time, place and conditions of the burn (good air quality, fire intensity,
smoke disbursement, and meteorological conditions) as opposed to when wildland fires overall size
occur which often are under the poorest of meteorological and air quality conditions. and rate of
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The incentives from such prescribed burns are: 1) The emissions/impacts are reduced due spread.
to choice of burning when we want (best and controlled conditions) versus when nature
decides (worse and uncontrolled conditions) and 2) Emission reductions accomplished
when wildland fires occur and run into a prescribed fire project area.
Incentives foster the concept of pitting one resource value against another, which is not a
beneficial approach. As CDF’s vegetation management burn projects are conducted
foremost for hazardous fuel reduction (* Note lines 19-20) the rewards to communities
are best served by conducting the burn to benefit the public health and safety from
catastrophic wildfire and provides community rewards with retained property values and
natural aesthetics which draw tourists. By encouraging the reduction of burning, the
threat to these community values from fire is omnipresent.
Appendix C 33 22- Does not account for short windows of opportunity to accomplish projects. Dykzeul
28
Incentives 33 28 Opportunities for incentives may be somewhat hampered for forested land managers, Alston
since the GCVTC found that only 30% of such lands were appropriate for mechanical GCVTC
treatment. Another incentive option to consider would be the certification level of the Report, p. 48
burn manager – those who are more highly trained in smoke management techniques
could receive preferential burning opportunities.
Emissions 33 The Rule calls for an annual emissions goal. This may be appropriate for some types of Alston
Goal burning. However, weather conditions and economics may drastically affect the amount 51.309(d)(6)(
of forest and agricultural burning that occurs. Are there any options for structuring the v)
annual goal to account for such inter-annual variability?
1 33 34- This sentence is misleading as written. Please add “for stationary sources of sulfur Potter
36 dioxide” at the end of the existing sentence.
33 38 PAYMENT FROM WHO? Dykzeul
Appendix C 33 41 Emissions Goal: Establishing an emissions goal is not viewed by CDF as an Stephens
objectionable concept. The only concern this raises is the degree to which this may
restrict prescribed burning. For, example, situations may occur where a specific project
may fall short of the Emissions Goal to some degree; however, when the benefits of the
project to other resources and the public are considered substantial, there should be a
mechanism by which the project is allowed to move forward. This decision would be
made in consideration of alternatives to burning methods and burning, plus the factors
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noted in section 1.2 above: efficiency, economics, law, emissions reduction opportunities,
land management objectives, and reduction of visibility impact.
1 33 FN Delete “Annex … May 2002” and replace with “67 FR 30418, May 6, 2002.” Potter
72 67 FR 30418,
May 6, 2002
App C, 2 34 2-4 Add to encourage burner coordination. Cite Frances’ paper? Riley
2 34 7 Insert the words “to be” in between “ESMP” and “included”. Potter
2 34 Add: Increased communication between Tribes, States and Federal Land Managers McLeod
on large burns that could potential affect each entity. This could be accomplished
through tribes/states and FLMs centralized decision-making entities.
34 31 Identify who models dispersion during the planning process. If this is an additional Hirami
requirement for all burners, obviously it must be regulated and enforced in an equitable
manner. Recommend that a statement here clearly state this.
Appendix C 34 31 A more sophisticated approach and more comprehensive effort to evaluate smoke Shipp
behavior would be to conduct smoke dispersion modeling in the planning process for
burning. The modeling would be used to evaluate the smoke impact from a project (s)
and perform impact analyses on the mitigation of smoke emissions under various
atmospheric conditions. This approach may assist in determining cumulative effects of
multiple burns.
App C, 2 34 32 Planning and implementation (i.e., BlueSky, B-Rains, MM5, CEFA) Riley
C 34 37- Same concern about equitability across all burners. Hirami
43
Appendix C 34 43 “rigorous, timely, centralized…” Dykzeul
Appendix C 34 43 This section refers to a centralized decision making system that would make the go/no-go Stephens
determination for burn projects. California is a large state with diverse topography, and
numerous air basins and local Air Quality Control Districts. These conditions are not
well suited to a centralized approached as is the case with Arizona.
App C 4. 35 Excellent section on an important consideration. Alston
Public
Notification
App C 3 35 5 Insert the words “to be” in between “ESMP” and “included”. Potter
Appendix C 35 12- CDF analyzes a potential project area with applicable landowners. The project has to Stephens
13 meet CDF vegetation management priorities for burning. For various reasons it may not
Outreach Process II - 329
be in the best interest of the state to conduct the burn due to: location, topography, public
benefit, etc. However, it may fit a CDF California Fire Plan project where the project is
addressed with mechanical, hand or other methods, which air agencies aren’t aware of.
The point is, that only a project that needs burning is burned, other vegetation
management options become non-burn projects. Under the present organization the non-
burn project would not be reported to the Central Authority in the form of permits etc.
Therefore, a reporting system would have to be put into place whereby the Central
Authority tracks no-burn projects, in order for the reporting agency/landowner to take
credit for reduced emission.
Appendix C 35 12- 3. Alternatives to Fire Doc Smith
17 This should be a very large part of the ESMPs. Not just the burners but the
states/tribes/agencies should be required to develop utilization opportunities through
grants, subsidies, taxes, and the like.
App C, 3 35 15 Cite Darla’s paper? Riley
Alternatives 35 19 The intent of this paragraph is a bit unclear, since the use of fire is parcel-specific Alston
to Fire (burning one field or forest unit does not reduce the need on another). Perhaps the
meaning is that the financial or personnel resources freed by burning (instead of
mechanical removal, for example) in one area could be used to support non-fire
alternatives elsewhere?
App C, 3 35 23 Offset is a regulatory terminology but I don’t think it is meant that way here. Use another Riley
term such as substitute?
C 35 27 Include statement that demonstration of reasonable progress was determined in an Hirami
objective, equitable way and clearly articulated by State/Tribes to those involved.
App C, 3 35 27- What about the wildfire consequences of burn curtailment actions? Riley
32
App C, 4 35 34 This section needs to relate better to visibility impact to class I areas. Riley
4 35 35 Insert the words “to be” in between “ESMP” and “included”. Potter
4 35 39 Please provide the appropriate cite(s) for those interested in finding out what EPA Potter
requires for a certifiable SMP.
36 1 4. Public Notification of Burning Doc Smith
reword “…date of burn, and location of burn, and the expected plume direction, extent,
and duration.
36 12 “….parts of any smoke management or fuels treatment program.” Dykzeul
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36 12- Doesn’t seem to be an equal educational promotion of non-burning alternatives…? Dykzeul
25
4 35- 45- These three paragraphs seem redundant. Please evaluate whether there is a way to Potter
36 17 combine and simplify the three paragraphs. If there is not, please make the differences
between the information in the three paragraphs more apparent and distinct.
4 36 37 This is the first time the acronym NEPA is used in the text of the document. Please insert Potter
the words “National Environmental Policy Act (NEPA)” for those who are unfamiliar
with the acronym.
5 36 41 Insert the words “to be” in between “ESMP” and “included”. Potter
Appendix C 37 A centralized public reporting phone number and/or website should be agreed upon and Main
Surveillance listed for centralized assessment and consistent documentation. Could also mention in
and section 2.4.4 and 2.4.6. A large number of complaints from one area could be the trigger
Enforcement used to deploy a rapid response team to better document unforeseen smoke concerns or
(General) infractions.
5 37 1 After activity add: on tribal lands where no capacity exist to monitor smoke impacts. McLeod
App C, 5 37 7 States/tribes and burners … Riley
5 37 8 Change the word “Using” to “The use of”. Potter
6 37 19 Insert the words “to be” in between “ESMP” and “included”. Potter
6 37 19- Change sentence to read: States/tribes/FLMs must consider surveillance and McLeod
21 enforcement in developing (delete: their) ESMPs included in (delete: their) regional
haze SIPs/TIPs/FIPs. If no TIP in place some mechanism for oversight on Tribal
lands should be identified, i.e., EPA oversight.
App C, 6 37 22 Regulators, burners, and public … Riley
6 37 27 Four change to Five if acceptable McLeod
Appendix B 37 29- See my comments above to section 2.4 Finneran
33
6 37 33 • Centralized regulatory authority, Not acceptable to Tribes unless EPA assumes McLeod
this role.
5. Air 37 43 Although the number of complaints can be used to monitor smoke impacts, use of the raw Alston
Quality numbers of complaints may not be a reliable metric since a small number of people can
Monitoring easily skew such a figure. The explanation beginning on line 43 seems a better approach,
and could be emphasized by deleting the phrase “In other cases” (since the two concepts
are not mutually exclusive).
Outreach Process II - 331
38 3 6. Surveillance and Enforcement Doc Smith
Add a bullet-“Duration of the impairment, 1-2 days or weeks.”
38 5 What are the economic impacts of both burning or not burning? Doc Smith
38 11 o Are there any statutory implications in establishing the next crop? Dykzeul
App C, 6 38 11 Add bullet – Is there compliance? Riley
38 11 Add “Is the impact a result of poor planning or of something that could not be Doc Smith
anticipated?” This is a little weak but the intent is not to punish a mishap that could not
be reasonably forecasted or anticipated.
6 38 12- These two paragraphs both talk about enforcement and have some overlap. Please Potter
15 evaluate whether there is a way to combine and simplify the two paragraphs. If there is
& not, please make the differences between the information in the two paragraphs more
35- apparent and distinct.
38
5. Air 38 22 Another “photographic” tool could be computer-generated images (for example, through Alston
Quality the WinHaze program) to illustrate acceptable or unacceptable conditions.
Monitoring
5. Air 38 36 The word “equitably” is key here – thanks! Alston
Quality
Monitoring
7 39 6 Insert the words “to be” in between “ESMP” and “included”. Potter
39 18 7. Program Evaluation Doc Smith
Perhaps there should be a public review every decade or so. (Give the public another
shot.)
Appendix C 39 32 $ Scientific advancements and adaptive management Main
addition
39 45 Add “Conduct an annual workshop/review/training session of 1-3 days for burners Doc Smith
40 4 Adequate, sincere evaluation of alternatives Dykzeul
App C, 7 40 4 Add in parenthesis (tracking, new research, etc.) Riley
7 40 6 Please rephrase this sentence by replacing “responsible for protecting” with “that have a Potter
responsibility to protect”. On the surface this may appear to be semantics. However,
states that have been granted primacy under the Clean Air Act have the authority to
Outreach Process II - 332
protect air quality related values and therefore are also responsible for protecting air
quality related values.
8 40 17 Insert the words “to be” in between “ESMP” and “included”. Potter
7 40 23 Change may also to will McLeod
7 40 24 Change Four to Five if acceptable McLeod
7 40 30 • Add: Establish a burn coalition authority, i.e. Tribes/States and FLMs McLeod
40 30 8. Burn Authorization Doc Smith
Add a bullet “Combinations of the above utilizing a ‘step-up’ set of triggers.”
Appendix C 40 31/3 Establishment of any of these authorization situations would also entail the development Main
2 of coordination procedures described in Section 4.3.9, below.
8 40 32 The reference to Section 4.3.9 appears to be incorrect. Please revise accordingly. Potter
App C, 8 41 1, 9 Clarify that state/local agencies can also establish permit programs. Riley
App C, 8 41 18 Add incentive programs. Riley
41 23- A regional burn authority would likely, in most cases, be working with the most severe Doc Smith
24 and persistent problems. This is not a necessary statement!
8 41 25 Add: Tribes would be a part of this centralized authority. McLeod
9 41 27 Insert the words “to be” in between “ESMP” and “included”. Potter
App C, 9 41 30 Cumulative visibility impacts Riley
App C, 9 41 37, Non-attainment areas and state/tribe boundaries may not have anything to do with Riley
38 visibility in class I areas.
9 41 44 9. Regional Coordination Doc Smith
Add in the bullet statement “Burn information (size, location, ignition date, expected plum
etc.). The expected plume direction and duration is a very important feature of the burn and
documentation of the burn so that it is easily understood by both professionals and the publ
9 42 7 • Add: Identification of the centralized burn authority who maintains McLeod
oversight
9 42 41 Add: Tribes would be an integral part of this centralized authority. McLeod
42 42 Add “Centralized Authority Coordination may be triggered by anticipated emissions, i.e., Doc Smith
used only in the Fall.”
Outreach Process II - 333
May 30, 2002
TO: ESMP Task Team
FR: Mike Dykzeul, Director, Forest Protection
RE: ESMP Draft Comments
In looking through the ESMP Draft, I quickly realized that a very significant amount of time would be needed on this in order to
provide meaningful detailed comments. With the relatively short comment period, please accept the detailed comments on the
provided form and these more narrative observations and concerns.
1. The reduction in harvest, (commercial utilization of wood fiber), on federal land is going to increase smoke emissions (either
through prescribed fire, as the current preferred or only choice, or default wildfire). Harvest or mechanical treatments are a highly
valuable and safe alternative to burning. This allows us to manage forests, without having to release smoke emissions, in a manner that
adds value to society through the utilization of the wood fiber as a renewable resource through products society demands and
economic benefits to individuals and communities.
2. Acceptable levels of smoke emissions will become more limited at the same time smoke emissions are expected to increase due to
federal land management policy. For example, the continued creation of small, scattered national wilderness areas (such as
conversion of remaining roadless areas to wilderness) will only further increase the number and distribution of "Mandatory Class 1"
areas. My example is that “Oregon Wild 2002” has proposed an additional 4.8 million acres in 28 new wilderness areas in Oregon
alone! Is there a “Traditional” Class 1 or will we eventually be surrounded at each city limit with a wilderness? Thus, eventually
eliminating the ability to provide a sustainable crop?
3. Increased smoke emissions on federal land, combined with mandatory reductions in overall smoke emissions; will reduce
opportunities to utilize fire on private lands. In addition, what limited opportunities will exist will come at a much higher cost due to
regulation, mitigation, reduced flexibility, permits, fees, requirements for qualified Burn Managers, etc., etc, resulting in increasing
fuel loading/hazard on private lands, shifting the problem back from federal to private lands.
4. The increased costs of fuels management on private lands should not have to be borne by the private landowner since the increased
costs are largely related to federal land management policy (either through resource management choices or the creation of more Class
1 areas). There should be some means of compensation to private landowners by the public for these additional costs. Additionally,
through increased commercial utilization, smoke emissions from private forestland management has been reduced significantly over
the past 20 years. There should be due recognition of this progress, not further restrictions!
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Response from Utah Farm Bureau Federation:
Please allow me to indicate at the outset that it is very difficult for me to evaluate a proposal for regulating smoke emission by
agriculture without first knowing our relative contribution compared to wildfires and other prescribed burns. My first thought is that it
could be inconsequential, thereby making the regulatory oversight on our industry relatively small. This piece of information
regarding proportional contributions will be very helpful in the future. Our first and foremost goals are to: 1) determine if there is a
problem; 2) ensure proper scientific evidence demonstrating problem; and 3) address the problem on a voluntary, incentive based
fashion.
In addition, I am in now way, by sending you this response, prepared to say it comprehensively states all of our concerns. The
timeframe within which we have to review the material and the limited prior exposure to discussion and terms ensure something will
be missing.
Let me first address the application of the ESMP. The document specifically states, “This Policy applies to both wildland and
agricultural lands regardless of ownership.” It further states the policy “does not apply to open burning activities on residential,
commercial, or industrial property.” The application of a set of emission standards to a specific industry without regard to other
contributors we believe to be inappropriate. Agriculture should not be forced to bear a higher standard of regulation for visibility from
smoke emissions. I recognize that these other sectors are regulated for health and safety, but as this report so adeptly points out, just
because there are regulations for health and safety does not mean those will successfully control for visibility concerns. These other
contributors should be brought into the same playing field.
Second, much of the emphasis seems to be aimed at meeting some sort of emissions goal. In fact, on line 38 of page 15, you state “the
rule calls for the establishment of annual emissions goals”. As section 4.3.2 points out, situational circumstances dictated by relative
tonnage of emissions could be used to evaluate emission releases from burning. However, please keep in mind that in a year in which
Utah is experiencing such high drought conditions, any normal emissions from agriculture which would have been acceptable in a
prior year, now are unacceptable because of other unrelated factors such as the wildfires. This is despite any proactive measures
which agriculture may be taking to reduce emissions.
We would rather have the ESMP think in terms of assisting in the implementation of economically viable alternatives to burning
where some exist. Utah Farm Bureau has taken a very proactive stance in terms of the lessoning agricultural discharge to water bodies
by investing in a voluntary approach. We hope the same can be accomplished in this instance.
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Regarding lines 15-22 on page 6 of the report, simply because someone decides to try to put a fire out does not suddenly make it a
contribution to regional haze, whereas otherwise it would not be considered a contributor. I understand the idea of using fire cessation
practices which lesson visibility problems, but I do not think it has place in the rule.
Related to that point, the statement on line 12-13 of page 5, that the ESMP applies without regard to “cause of ignition” whether
accidental or for management practices seems to typify the approach of managing for tonnage rather than improved practices.
I do appreciate much of the work which has been done to allow for flexibility based on relative contribution of an area.
Thank you for considering this hastily compiled response.
G. Wesley Quinton
Vice President--Public Policy
Utah Farm Bureau
wesq@sisna.com
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WRAP ESMP Policy
Reviewer List
Affiliation Name Received Returned
Email Draft Comment
Policy
Academia/Research
Eastern WA U Robert Quinn Robert.Quinn@mailserver.ewu.edu X
Northern AZ University Doc Smith Doc.Smith@nau.edu X X
USDA-FERA David Sandberg dsandberg@fs.fed.us X X
Agriculture
Farm Bureau, UT Wes Quinton wesq@sisna.com X X
Farmer, WA Mark Wagoner wagoner@pocketinet.com X X
Madera County, CA Farm Bureau Jason Baldwin jasonbaldwin@sbcglobal.net X X
North Idaho Farmers Association Linda Clovis nifa@northidahofarmers.org X
Environmental Organizations
Environmental Defense (IOC) Vickie Patton vpatton@environmentaldefense.org X
Grand Canyon Trust Taylor McKinnon mckinnon@grandcanyontrust.org X X
EPA
EPA Gary Blais blais.gary@epa.gov X
EPA Rich Damberg damberg.rich@epa.gov X
EPA, Region 10 Scott Downey downey.scott@epa.gov X
EPA Tim Smith Smith.Tim@epamail.epa.gov X
EPA Charlene Spells spells.charlene@epa.gov X
EPA Ken Woodard Woodard.Ken@epamail.epa.gov X X
Federal Land Managers
BIA, NIFC Lyle Carlile lyle_carlile@nifc.gov X
BIA, WRO John Philbin N/A X
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BLM Carl Gossard cgossard@blm.gov X X
FWS Dennis Haddow mollyden@cs.com X
NM, FLM Bob Lee rlee@blm.gov X
NPS, Grand Canyon Joseph Alston joe_alston@nps.gov X X
NPS, Grand Canyon Carl Bowman Carl_Bowman@nps.gov X
NPS Brian Mitchell brian_mitchell@nps.gov X X
USFS Patti Hirami phirami@fs.fed.us X X
USFS Kathy McAllister kmcallister@fs.fed.us X
USFS Jim Russell jrussell01@fs.fed.us X
USFWS R2 Mike Main michael_main@fws.gov X X
mark_kaib@fws.gov
loren_derosear@fws.gov
cmaxwell@fs.fed.us
Industry
American Forest Resources Council Chuck Burley cburley@afrc.ws X
Arch Coal Company Greg Schaefer gschaefer@archcoal.com X
OR Forest Industries Council Mike Dykzeul mike@ofic.com X X
Pacificorp Ruben Plantico rcplantico@prodigy.net X
Phelps Dodge Ken Evans kevans@phelpsdodge.com X X
Pinnacle West, AZ Public Service Edward Fox edward.fox@pinnaclewest.com X
Plum Creek (FEJF) Scott Kuehn Scott.Kuehn@plumcreek.com X X
State Air Regulators
CA Air Resources Board Bruce Oulrey boulrey@arb.ca.gov X
CA San Joachin Air Pol Dist Evan Shipp evan.shipp@valleyair.org X X
CO Air Pollution Control Div Coleen Campbell coleen.campbell@state.co.us X X
ID DEQ (FEJF) Diane Riley driley@deq.state.id.us X X
NV Div Environmental Protection Colleen Cripps csergent@ndep.state.nv.us X
(Chet Sargent)
OR DEQ Brian Finneran FINNERAN.Brian@deq.state.or.us X X
UT DEQ (FEJF) Frances Bernards fbernard@deq.state.ut.us X X
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WA (TOC) Bob Saunders rsau461@ecy.wa.gov X
WY DEQ Darla Potter dpotte@state.wy.us X X
State Forestry
AZ State Land Dept Kirk Rowdabaugh kirkrowdabaugh@azstatefire.org X
CDF Louis Blumberg louis_blumberg@fire.ca.gov X
Council of Western States Foresters Jim Lawrence jimlaw@lamar.colostate.edu X
State Forestry Joel Frandsen joelfrandsen@utah.gov X X
State Forestry Paige Lewis plewis@lamar.colostate.edu X
State Forestry Pat McElroy pat.mcelroy@wadnr.gov X
State Forestry Jeff Stephens jeff.stephens@fire.ca.gov X X
tom.larsen@fire.ca.gov
State Parks CO Lyle Laverty emily.dorman@state.co.us X
Tribes
Nez Perce Julie Simpson julies@nezperce.org X
NTEC Bob Gruenig bgruenig@ntec.org X X
Quinault Lisa Riener lriener@quinault.org X
Salish Kootenai Lewis McLeod alex@ronan.net X X
Umatilla John Cox johncox@ctuir.com X
White Mountain Apache Amy Mignella amytm9@cox.net X X
Yakama Rose Lee rose@yakama.com X X
Yurok Kevin McKernan kevinmck@reninet.com X X
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Outreach Process II - 340
FEJF Conference Call
July 1, 2002
Conference Call to Review & Approve Revised ESMP Document
Prior to Submission to IOC
Chronological Record II - 341
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Chronological Record II - 342
FEJF Conference Call
July 1, 2002
Conference Call Record
Participants: Ann Acheson (ESMP Co-Chair), USDA-FS; Francis Bernards, (FEJF), UT
DEQ; Larry Biland, (FEJF), USEPA; Dennis Haddow (FEJF Alternate), USFWS; Scott
Kuehn, (FEJF), Plum Creek Timber Co; Pete Lahm, (FEJF Chair), USDA-FS; Jim
Lawrence, (FEJF), WFLC; Dave Randall, (FEJF), Air Sciences; Diane Riley, (FEJF), ID
DEQ; Pat Shaver, (FEJF), USDA-NRCS; Evan Shipp, (FEJF Alternate), SJVAPCD;
Mike Ziolko, (FEJF Alternate/ESMP Co-Chair), OR Dept of Forestry; Rebecca
Reynolds, Facilitator, Rebecca Reynolds Consulting, Inc.
Purpose: Review & Approval of WRAP ESMP Policy
Substantive Issues:
J. Lawrence: One issue as follows.
Interstate/inter-region cooperation is important to the ESMP. This Policy doesn’t seem to
address how this would be accomplished. Thought we needed a bit more explanation of
how it might occur and who would take the lead for facilitating it. How to set up
structure for it: e.g., between UT and CO, etc.
Response (P. Lahm): Under the Rule, interstate effects lays responsibility across state
boundaries. Cite this.
Pat S: Agrees that it is important.
Mike. Z: Who should be cited as initiator of it? We need guidance…
Pete L: WRAP, ESTAR, and STAPALTCO? Western States Fire Managers (State
Group), Wildfire Leadership Council, partnership between some of these.
Frances B: Do the list on p. 40 – refer to it in both sections.
Evan S: Suggest mentioning generically a tracking system like…PIFRERS-like tracking
system or other. Or that something will be developed. Connect emissions tracking to
Regional Coordination.
Pete L: Get language out there – generically – via email to FEJF.
Diane R: Seven issues to address, two of them are substantive.
#1: Policy statements need to be spelled out clearly. Suggest that we state the
policy statements up front in the document.
Also, add that States must establish implementation criteria (section 4) to
determine the level of effort of the ESMP
Chronological Record II - 343
Dave R: State interpretation of the Rule, it needs to be right. And Policy has not been
explicit about what 308 states must do. We consciously tried to broaden the Policy.
“Viable tool for both”
Executive Summary line 30: Specifically “required.” Line 33 “requires states to
consider”
P 10, line 26
Consensus on the 7 Policy Statements
Section 1
- ESMP required for 309
- ESMP is a viable tool for 308 to develop SIPs
- ESMP must include 9 elements
- Implementation criteria must be developed to determine the level of effort
applied to track the elements of the ESMP
- Cite the Rule considerations
- ESMP is defined as smoke management for visibility
- ESMP will be developed in a collaborative process including the
considerations and the level of effort to implement the 9 elements
Page 10, Section 308, line 25-27
- “Rule requires states to consider smoke management techniques” “in their long-
term strategies”
- “then the SIP will need to include…” (must consider)
- A state/tribe finds that:
- If smoke contributes to viz impairment in Class 1s, then smoke
management techniques should be considered in the SIP.
Dave R: Concern over collaborative process being part of Policy.
Evan S: Gives us and the state process credibility.
If…then…scenario as written under 308 is not acceptable.
Dave R: If all 308 states have to do is consider smoke management techniques then I am
uncomfortable.
Page 11, line 4: “If a 308 state has determined that fire is contributing to viz impairment
and has determined that smoke needs to be addressed in their SIP, then the ESMP is a
viable tool.”
Evan S: To do that assessment, certain elements will need to be considered.
Chronological Record II - 344
Dave R: For 308, ESMP kicks in at the end.
Frances B: Rule specifies sources, isn’t it logically implied that all sources would be
considered? Ergo, fire will be included in visibility impairment analysis.
Diane R: agree with Frances.
Diane R: submitted other written comments for our consideration – ESMP TT will
review them.
Scott K: I would like on the record that I am concerned about the role of BSMP vs.
ESMP. This probably needs to be dealt with offline. But right now I see few changes that
will be made to MT’s current SMP based on the guidance in this document and I do not
know how this will help us address regional haze. However, this concern will not hold
up the process.
Dennis H: I think the document is good.
Pete L: I mentioned Tribal concerns – we may add a few more cites to address these.
Scott K: in re: exemptions. Ok.
Pete L: Mike Main’s concerns.
Rebecca R: will revise and send those sections out to FEJF – ASAP.
Call Darla: re: 5-year review. Get cite.
Call Evan.
P 14. 7 Program Evaluation
ESMPs need to be reviewed for their effectiveness by the regulation authority on a
periodic basis. [This evaluation could be part of the progress report submitted to EPA as
cited under the Regional Haze Rule.]
Make first paragraph on page 38 the same as on page 14.
Executive Summary:
line 9 states (“or their delegated regulatory authority”)
page 33 Emissions Target – replace “Goal” with “Target”
page 1, line 24 States will develop the regional haze implementation plan per the
nationally applicable Section 308, and the Transport Region States may choose to
incorporate the GCVTC.
Page 8, line 36 as per the requirements of section 309 of the Rule.
Chronological Record II - 345
[This page intentionally left blank.]
Chronological Record II - 346
1
2
3
4
5
6
7
8
9 WRAP Policy
10
11 Enhanced Smoke Management Programs
12 for Visibility
13
14 DRAFT
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36 Prepared by the Enhanced Smoke Management Task Team for the Fire
37 Emissions Joint Forum
38 July 1, 2002
ESMP Policy Draft D, 7/1/02 II - D - 1
1 WRAP Policy
2
3 Enhanced Smoke Management Programs
4 for Visibility
5
6 Executive Summary
7
8 The Western Regional Air Partnership (WRAP) is charged with developing technical and
9 policy tools to assist states (or the delegated regulatory authority) and tribes with
10 implementing the Regional Haze Rule (Rule). The WRAP Policy on Enhanced Smoke
11 Management Programs for Visibility (WRAP ESMP Policy) has been developed over a
12 nine-month period through a stakeholder-based consensus process to assist the WRAP
13 region states and tribes in addressing emissions from fire sources. In this Policy, the
14 WRAP seeks to provide a consistent framework that states and tribes can use to
15 efficiently develop their individual implementation plans. The WRAP recognizes states’
16 and tribes’ authority and responsibility to develop, adopt and implement their regional
17 haze state and tribal implementation plans, and recognizes the Rule as the principal
18 document on which states and tribes should rely to develop their implementation plans.
19
20 The Rule requires states to develop implementation plans
21 (SIPs) for addressing regional haze in the Nation’s 156
22 mandatory Class I areas.1 Additionally, the Rule requires effective
23 management of fire sources and specifically, the development of smoke management
24 programs. The Rule provides two pathways for western states to follow as they
25 implement the requirements of the Rule: 1) develop their regional haze implementation
26 plans per the nationally applicable provisions of Section 308, or 2) Transport Region
27 states may choose to incorporate the Grand Canyon Visibility Transport Commission
28 (GCVTC) Recommendations into their regional haze implementation plans under Section
29 309 of the Rule.
30
31 Enhanced smoke management programs are specifically required in Section 309 of the
32 Rule. However, if a state, under Section 308, has determined that fire emissions are
33 contributing to visibility impairment and that smoke needs to be addressed in its SIP, then
34 an enhanced smoke management program is a viable tool to accomplish this goal.
35 Therefore, the WRAP is advancing the WRAP ESMP Policy for states under both
36 Section 308 and 309.
37
38 Tribes are not subject to the same requirements of the Rule as states, but tribes wishing to
39 assume the regional haze requirements outlined in the Rule may, according to the Tribal
40 Authority Rule (TAR), seek approval under 40 CFR 49 to be “treated as States.” The
41 intent of this Policy is to assist both states and tribes with the development of their
1
The Rule is only applicable to mandatory Class I areas (see Appendix A & Appendix B for additional
information on mandatory Class I areas). States/tribes in the WRAP region may utilize the WRAP ESMP
Policy to protect visibility in non-mandatory Class I areas.
ESMP Policy Draft D, 7/1/02 II - D - 2
1 regional haze implementation plans (SIPs/TIPs), and therefore, tribes are included in all
2 references to states, except where specific requirements and/or deadlines of the Rule are
3 cited.2
4
5 It is the position of the WRAP ESMP Policy that there are nine elements of an enhanced
6 smoke management program that are necessary to meet the requirements of the Rule. The
7 WRAP ESMP Policy defines the enhanced smoke management program as smoke
8 management efforts that specifically address visibility. According to the Rule, enhanced
9 smoke management programs are to be included in implementation plans based on the
10 criteria of efficiency, economics, law, emissions reduction opportunities, land
11 management objectives, and reduction of visibility impacts.
12
13 Smoke management efforts/programs currently in place (sometimes referred to as “basic
14 smoke management programs”) may not specifically address visibility effects in
15 mandatory Class I areas. The WRAP ESMP Policy explicitly addresses visibility effects
16 from fire that contribute to visibility impairment in mandatory Class I areas. Fortunately,
17 smoke management efforts/programs, regardless of the purpose (e.g., visibility
18 protection, avoidance of National Ambient Air Quality Standards (NAAQS) violations,
19 or prevention of nuisance smoke impacts), have many common elements. It is anticipated
20 that the enhanced smoke management program elements outlined here will integrate well
21 with current and future smoke management efforts/programs.
22
23 The WRAP ESMP Policy document is comprised of four major sections. Section 1 is the
24 WRAP ESMP Policy statements. Section 2 provides overall background for the WRAP
25 ESMP Policy, including a discussion of the regulatory environment, the current context
26 of smoke management in the WRAP region, and details of the Rule that are germane to
27 the WRAP ESMP Policy. Section 3 is the annotated WRAP ESMP Policy, including a
28 description of the nine enhanced smoke management program elements, the rationale for
29 these elements, and an explanation of the Rule’s enhanced smoke management program
30 criteria. Section 4 provides direction for states/tribes to assist them with implementation
31 of the enhanced smoke management program. Finally, the Appendices include (A) a
32 glossary of terms, (B) a related documents listing, and (C) specific examples for
33 states/tribes on the implementation of the nine enhanced smoke management program
34 elements.
35
36 The WRAP ESMP Policy provides states and tribes an equitable and practical method for
37 implementing an enhanced smoke management program. The WRAP ESMP Policy is
38 intended to assist states and tribes in their efforts to demonstrate reasonable further
39 progress toward the natural visibility goal. The Fire Emissions Joint Forum (FEJF) of the
40 WRAP is developing additional policy and technical tools that will support the WRAP
41 ESMP Policy and its implementation, such as an annual emissions goal policy, guidance
42 on assessing the availability and feasibility of alternatives to burning, and a policy on
43 tracking fire emissions.
2
Further information on tribes and Tribal Implementation Plans (TIPs) is provided in Section 2.6.4 of this
document.
ESMP Policy Draft D, 7/1/02 II - D - 3
1 WRAP Policy
2
3 Enhanced Smoke Management Programs
4 for Visibility
5
6
7 TABLE OF CONTENTS
8
9 Executive Summary i
10
11 1. The WRAP Policy on Enhanced Smoke Management Programs
12 for Visibility 1
13
14 2. Background 2
15
16 2.1 Introduction 2
17 2.2 Purpose 3
18 2.3 Scope and Applicability 4
19 2.4 Regulatory Environment 5
20 2.5 Context 7
21 2.5.1 Current Smoke Management Guidance 7
22 2.5.2 Current Smoke Management Efforts 8
23 2.6 The Regional Haze Rule Requirements to Address Fire 9
24 2.6.1 Emissions Tracking 9
25 2.6.2 Section 309 10
26 2.6.3 Section 308 10
27 2.6.4 Regional Haze Implementation Plan (SIP/TIP) Process 11
28
29 3. Annotated WRAP ESMP Policy 12
30
31 3.1 Elements Description 12
32 3.2 Elements Rationale 15
33 3.3 Criteria Description 16
34
35 4. Enhanced Smoke Management Program Implementation 17
36
37 4.1 Responsibilities Under an Enhanced Smoke Management Program 17
38 4.2 Implementation Options 18
39 4.2.1 Source Sector Thresholds 19
40 4.2.2 Situational Thresholds 19
41 4.2.3 Impact Based Thresholds 20
42 4.3 Funding Mechanisms 21
43
44
ESMP Policy Draft D, 7/1/02 II - D - 4
1 TABLE OF CONTENTS
2
3 5. Appendices 22
4
5 Appendix A. Glossary 23
6
7 Appendix B. Related Documents Listing 29
8
9 Appendix C. Enhanced Smoke Management Program Elements:
10 Implementation Guidance 30
11
12 1. Actions to Minimize Emissions from Fire 30
13 Emissions Reductions Techniques 30
14 Burn Manager Qualification 31
15 Incentives 32
16 Emissions Target 33
17 2. Evaluation of Smoke Dispersion 33
18 3. Alternatives to Fire 34
19 4. Public Notification of Burning 34
20 5. Air Quality Monitoring 36
21 6. Surveillance and Enforcement 36
22 7. Program Evaluation 38
23 8. Burn Authorization 39
24 Permit by Rule 39
25 Burn Permitting System 40
26 Centralized Burn Authority 40
27 Regional Burn Authority 40
28 9. Regional Coordination 40
29 Source Sector Authority Coordination 41
30 Centralized Authority Coordination 41
31 Regional (Multi-State/Tribe) Coordination 42
32
33
ESMP Policy Draft D, 7/1/02 II - D - 5
1 1. The WRAP Policy on Enhanced Smoke Management
2 Programs for Visibility
3
4 Policy Statements
5
6 A. An enhanced smoke management program is defined as smoke management efforts
7 that specifically address visibility effects.
8
9 B. An enhanced smoke management program is required for states under Section 309 of
10 the Regional Haze Rule.
11
12 C. An enhanced smoke management program is a viable tool for states under both
13 Section 308 and 309 to use in their SIP development.
14
15 D. An enhanced smoke management program includes nine elements that are necessary
16 to meet the requirements of the Regional Haze Rule,3 as follow:
17
18 1. Actions to Minimize Emissions from Fire
19 Any burning techniques that reduce the actual amount of emissions produced.
20
21 2. Evaluation of Smoke Dispersion
22 Using meteorological conditions to assess the ability to minimize smoke impacts.
23
24 3. Alternatives to Fire
25 Removal or reduction of fuels by mechanical, biological or chemical treatments.
26
27 4. Public Notification of Burning
28 Any method that communicates burn information to the burn community, to air
29 regulators and to the general public. Also includes public education and media
30 relations.
31
32 5. Air Quality Monitoring
33 Observations and/or equipment that enable an assessment of air quality impacts of
34 smoke from fires.
35
36 6. Surveillance and Enforcement
37 An oversight mechanism that assures adherence to smoke management efforts as
38 defined by the regional haze implementation plan.
39
40 7. Program Evaluation
41 A mechanism to assess the adequacy of the enhanced smoke management program in
42 meeting the requirements of the Rule.
43
44 8. Burn Authorization
3
Published in the Federal Register on July 1, 1999, 64 FR 35714.
ESMP Policy Draft D, 7/1/02 II - D - 6
1 The management approach used to facilitate burn decision-making.
2
3 9. Regional Coordination
4 Communication and information sharing across state/tribe jurisdictional lines.
5
6 E. Enhanced smoke management programs will be based on the criteria of efficiency,
7 economics, law, emission reduction opportunities, land management objectives, and
8 reduction of visibility impact,4 which will determine the rigor applied to the nine
9 elements.
10
11 F. An enhanced smoke management program may be applied uniformly to source sectors
12 throughout a state’s jurisdiction or they may be tailored to source sectors and/or
13 geographic areas to address presumed or confirmed visibility impairment.
14
15 G. The development and application of an enhanced smoke management program,
16 including the consideration of the criteria (E), will be done collaboratively with state,
17 tribal, local and federal agencies and private parties.
18
19 2. Background
20
21 2.1 Introduction
22
23 The WRAP ESMP Policy is the result of the WRAP region-wide multi-state/tribe
24 stakeholder planning and coordination effort focused on addressing the development of
25 enhanced smoke management programs that address visibility effects. This effort is
26 consistent with the direction provided by the Environmental Protection Agency (EPA) in
27 the Preamble to the Rule:
28
29 …progress toward the national [visibility] goal will require regional programs that
30 operate over large geographic areas and limit emissions of pollutants that can
31 cause regional haze…5
32
33 Most states/tribes in the WRAP region address fire source sectors differently, as does
34 EPA in its guidance documents. Consequently, fire sources in the WRAP region are
35 currently regulated at various and inconsistent levels, from rigorous regulation to
36 regulation with exemption applied, to no regulation. This variability emphasizes the need
37 for the development and application of an enhanced smoke management program
38 framework that is predictable and flexible while meeting the requirements of the Rule.
39
40 The elements of an enhanced smoke management program as outlined in this Policy are
41 based upon careful review and consideration of the Rule, and the existing guidance on
42 smoke management: the EPA’s Interim Air Quality Policy on Wildland and Prescribed
4
64 FR 35771, § 51.309 (d) (6) (iv).
5
64 FR 35718.
ESMP Policy Draft D, 7/1/02 II - D - 7
1 Fires (EPA Interim Policy)6, and the Agricultural Air Quality Task Force’s (AAQTF)
2 Recommendation on Air Quality Policy on Agricultural Burning (AAQTF
3 Recommendation on Air Quality Policy).7 The WRAP ESMP Policy goes beyond the
4 EPA Interim Policy and the AAQTF Recommendation on Air Quality Policy to
5 specifically address visibility effects and regional haze, as required by the Rule.
6
7 The WRAP ESMP Policy has been developed to embody appropriate regulatory and
8 policy requirements and to provide a predictable framework for enhanced smoke
9 management programs that can be reasonably implemented by states and tribes. The
10 WRAP recognizes states/tribes authority and responsibility to develop, adopt and
11 implement their regional haze state and tribal implementation plans. The WRAP further
12 recognizes that the implementation plans will be revisited and revised, per the schedule
13 specified in the Rule, giving opportunities to refine individual enhanced smoke
14 management programs to reflect technical advances and policy updates.
15
16 2.2 Purpose
17
18 The purpose of the WRAP ESMP Policy is to identify for states/tribes in the WRAP
19 region the elements of an enhanced smoke management program to address visibility
20 effects from all types of fire that contribute to visibility impairment in mandatory Class I
21 areas. Although the Rule is only applicable to mandatory Class I areas, state/tribes in the
22 WRAP region may utilize the WRAP ESMP Policy to protect visibility in non-mandatory
23 Class I areas.8 The intent of the WRAP ESMP Policy is to assist states/tribes to address
24 visibility effects associated with fire in a way that is adequate for SIP/TIP
25 implementation.
26
27 The enhanced smoke management program adds visibility impairment/regional haze
28 considerations to existing smoke management efforts for NAAQS and/or nuisance. The
29 WRAP recognizes that states/tribes are addressing their public health and nuisance
30 concerns associated with smoke in their current smoke management efforts. It is possible
31 that states/tribes may encounter conflicts between managing smoke for visibility
32 considerations and smoke management efforts for NAAQS and/or nuisance. It is
33 therefore recommended that states/tribes coordinate their efforts to protect visibility with
34 existing or future efforts to address NAAQS and/or nuisance smoke.
35
36 The WRAP ESMP Policy integrates visibility protection with NAAQS and nuisance
37 protection, in accordance with the Rule:
38
6
U.S. EPA, Office of Air Quality Planning and Standards, Interim Air Quality Policy on Wildland and
Prescribed Fires, April 23, 1998 (hereafter referred to as “EPA Interim Policy”).
7
Agricultural Air Quality Task Force, Air Quality Policy on Agricultural Burning, Recommendation to the
U.S. Department of Agriculture, November 10, 1999 (hereafter referred to as “AAQTF Recommendation
on Air Quality Policy”).
8
See Appendix B for a map of Class I areas.
ESMP Policy Draft D, 7/1/02 II - D - 8
1 The regional haze program is being promulgated in a manner that facilitates
2 integration of emission management strategies for regional haze with the
3 implementation of programs for new NAAQS for Ozone and PM.9
4
5 The elements included in the enhanced smoke management program as outlined by this
6 Policy have been selected in an attempt to address direct visibility effects and regional
7 haze in mandatory Class I areas so as to improve visibility on the worst days and
8 maintain visibility on best days. Worst days are defined by the Rule as those days that
9 fall in the lowest 20th percent for visibility measurements from Interagency Monitoring of
10 Protected Visual Environments (IMPROVE), and the best days are those days that are in
11 the highest 20th percent on an annual basis.10
12
13 2.3 Scope and Applicability
14
15 The WRAP ESMP Policy applies to smoke impacts in mandatory Class I areas from fire
16 anywhere in the WRAP region. Each state has an obligation to account for those
17 emissions it produces that have impacts in its own mandatory Class I areas.
18 Accountability also extends to states and tribes that have smoke impacts outside their
19 jurisdictions.
20
21 The WRAP ESMP Policy applies to all fire, and maintains the previously established
22 definitions:
23
24 This Policy applies to both wildland and agricultural lands regardless of
25 ownership (i.e., Federal, state, tribal, public, private), cause of ignition (e.g.,
26 lightning, arson, accidental human, land management practices) or purpose of the
27 fire (e.g., vegetative residue disposal, hazard reduction, maintain ecosystem
28 health). It is the intent that this Policy be applied equitably across all land types
29 and sources. 11
30
31 All fire source sectors are included in the WRAP ESMP Policy because it is recognized
32 that all fires contribute to regional haze.12 This Policy needs to be applied to all sources
33 addressed by the WRAP Fire Categorization Policy.
34
35 This Policy specifically does not apply to Native American cultural non-vegetative
36 burning for traditional, religious, or ceremonial purposes (e.g., cremation, sweat lodge
37 fires).13 Nor does it apply to open burning activities on residential, commercial, or
38 industrial property (e.g., backyard burning, garbage incineration, residential wood
39 combustion, construction debris).14 However, states/tribes may choose to consider the
40 impacts of these fire sources when developing their regional haze implementation plans.
9
64 FR 35719, emphasis added.
10
64 FR 35764, §51.301.
11
WRAP Policy for Categorizing Fire Emissions, November 15, 2001 (hereafter referred to as “WRAP
Fire Categorization Policy”), p 7.
12
GCVTC Report, p.47.
13
WRAP Fire Categorization Policy, p. 24.
14
Ibid., however “industrial property” would not include land such as industrial forest land.
ESMP Policy Draft D, 7/1/02 II - D - 9
1 2.4 Regulatory Environment
2
3 In 1990, Congress amended the Clean Air Act (CAA), and as part of these amendments
4 created the GCVTC.15 The GCVTC was charged with assessing the current scientific
5 information on visibility impacts and making recommendations for addressing regional
6 haze in the western United States. The GCVTC signed and submitted more than 70
7 recommendations to the EPA in a report dated June 1996 that indicated that visibility
8 impairment was caused by a wide variety of sources and pollutants, and that a
9 comprehensive strategy was needed to remedy regional haze.
10
11 Fire sources were among those specifically acknowledged in the GCVTC Report as
12 contributors to visibility impairment on an episodic basis:
13
14 All types of fire (prescribed fire and agricultural burning) must be addressed
15 equitably as part of a visibility protection strategy. 16
16
17 Further supporting equity, Section 118(a) of the CAA requires that all entities, federal
18 and non-federal, be subject to the same requirements, authorities and processes17
19 Additionally, stakeholder input garnered in the development process of the WRAP Fire
20 Categorization Policy supported consistent consideration of fire between Sections 308
21 and 309 of the Rule18. The WRAP ESMP Policy, therefore, will be applicable and useful
22 to all states and tribes in the WRAP region.
23
24 The GCVTC Report acknowledged federal and state land managers’ projection of
25 significant increases in prescribed fire in order to reduce the effects of wildfire resulting
26 from past decades of fire exclusion.19 The GCVTC Recommendations cited the need for
27 minimizing the increase in emissions from all fire programs to the maximum extent
28 feasible.20 One of these Recommendations called for:
29
30 …the development and implementation of criteria and requirements for the use of
31 enhanced smoke management programs (including alternative management
32 practices) and emission reduction strategies.21
33
34 The WRAP was established in 1997 as the successor organization to the GCVTC. The
35 WRAP is a voluntary organization comprised of western governors, tribal leaders and
15
The Grand Canyon Visibility Transport Commission (GCVTC) was composed of the governors of eight
western states (AZ, CA, CO, NM, NV, OR, UT, WY), four tribes (Acoma Pueblo, Hopi, Hualapai, and
Navajo), four Federal land management agencies (Bureau of Land Management, U.S. Fish and Wildlife
Service, U.S. Forest Service, National Park Service), the Columbia River Inter-Tribal Fish Commission,
and the Environmental Protection Agency.
16
GCVTC Report, p. 47.
17
Clean Air Act § 118(a).
18
WRAP Fire Categorization Policy, p. 7.
19
GCVTC Report, p. 23.
20
GCVTC Report, Recommendation 7, p. 50.
21
GCVTC Report, Recommendation 4, p. 49.
ESMP Policy Draft D, 7/1/02 II - D - 10
1 federal agencies,22 and is charged “to identify regional or common air management
2 issues, develop and implement strategies to address these issues, and formulate and
3 advance western regional policy positions on air quality.”23 These policies and technical
4 tools are developed through inclusive, stakeholder-based processes and approved by
5 consensus of the WRAP. A WRAP policy, once approved, represents the WRAP's
6 consensus position on the best means for states and tribes to implement the portion of the
7 Rule at issue. The WRAP recognizes states’ and tribes’ authority and responsibility to
8 develop, adopt and implement their regional haze state and tribal implementation plans,
9 and the seminal guidance to do this is the Regional Haze Rule. 24
10
11 WRAP participants include state air quality agencies, tribes, federal/state/private land
12 managers, the EPA, environmental groups, industry, academia and other interested
13 parties. There are over 400 tribes within the WRAP region. The large number of tribes
14 limits the participation of all of them in WRAP activities, and accordingly, in the
15 development of this Policy. Therefore, the tribal representatives involved in the
16 development of this Policy may not represent all tribal concerns.
17
18 Following the issuance of the GCVTC Recommendations, the EPA issued the Regional
19 Haze Rule in July 1999 to improve visibility in 156 national parks and wilderness areas
20 across the country. The Rule outlines the requirements for states and tribes to address
21 regional haze in these mandatory Class I areas. EPA incorporated all of the GCVTC
22 Recommendations into Section 309 of the Rule, which may be used by some of the
23 WRAP states/tribes. The remaining WRAP states must/tribes may utilize the nationally
24 applicable Section 308 provisions of the Rule:
25
26 Progress toward the national [visibility] goal will require regional programs that
27 operate over large geographic areas and limit emissions of pollutants that can
28 cause regional haze.25
22
The WRAP members include the governors of thirteen western states (AK, AZ, CA, CO, ID, MT, ND,
NM, OR, SD, UT, WA, and WY). Tribal nations selected as WRAP members include Pueblo of Acoma,
Campo Band of Kumeyaay Indians, Cortina Indian Rancheria, Hopi Tribe, Hualapai Nation of the Grand
Canyon, Nez Perce Tribe, Northern Cheyenne Tribe, Salish and Kootenai Confederated Tribes, Pueblo of
San Felipe, and Shoshone-Bannock Tribes of Fort Hall. Federal WRAP members are the Department of the
Interior, the Department of Agriculture, and the Environmental Protection Agency.
23
WRAP Charter, Purpose, p. 1.
24
The WRAP recognizes the unique legal status and jurisdiction of tribes and seeks to promote policies that
ensure fair and equitable treatment of all participating members of the WRAP. The Partnership also
recognizes the states’ and tribes’ authority and responsibility to develop, adopt and implement their
individual state and tribal implementation plans. Further, the Partnership recognizes the discretion of the
U.S. Environmental Protection Agency and its responsibility to develop national regulatory initiatives, and
review State and Tribal implementation plans through public rulemaking procedures. In addition, the
Partnership recognizes the affirmative responsibility of the federal land managing agencies under the Clean
Air Act to protect the air quality related values, including visibility of Class I areas and to manage all the
areas under their respective jurisdictions for the public purposes set forth in their governing statutory
authorities. The WRAP has no regulatory authority and recognizes that all legal authority is reserved by its
members in accordance with existing law. The Partnership also recognizes the United States' trust
responsibility as carried out by the federal agencies to protect tribal resources from degradation. –
Excerpted from the WRAP Charter, p.1.
25
64 FR 35718.
ESMP Policy Draft D, 7/1/02 II - D - 11
1 EPA recognizes the WRAP as the Regional Planning Organization that is developing the
2 necessary policy and technical tools to implement the Rule in the WRAP region.
3
4 2.5 Context
5
6 2.5.1 Current Smoke Management Guidance
7
8 The EPA Interim Policy and the AAQTF Recommendation on Air Quality Policy were
9 developed to guide states/tribes in addressing public health (i.e., NAAQS) and welfare
10 impacts of smoke.
11
12 In its Interim Policy, the EPA lists seven basic components that it requires for a smoke
13 management program to be certifiable26 including: A) Authorization to Burn, B)
14 Minimizing Air Pollution Emissions, C) Smoke Management Components of a Burn
15 Plan, D) Public Education and Awareness, E) Surveillance and Enforcement, F) Program
16 Evaluation and G) Optional Air Quality Protection.27 The Interim Policy refers to these
17 elements as a basic program for smoke management.28
18
19 The AAQTF Recommendation on Air Quality Policy sets up a two-tiered voluntary
20 program, in which the first tier is based on a predetermined set of burn conditions. The
21 second tier is designed for areas where agricultural burning would be expected to
22 contribute to NAAQS violations or to visibility impairment in mandatory Class I areas. In
23 this second tier, many of the same elements as the EPA Interim Policy requires are
24 involved, including burn authorization, air quality monitoring, emissions reductions
25 techniques, public notification, and enforcement requirements.29
26
27 An integral part of both the EPA Interim Policy and the AAQTF Recommendation on Air
28 Quality Policy is the guidance to consider the visibility effects of burning when planning
29 burning operations, and to consider alternatives to burning as well as the use of other
30 emission reduction practices. However, they do not provide specific mechanisms for the
31 development of a smoke management program that addresses visibility effects. The EPA
32 Interim Policy states:
33
34 After the regional haze rules become final, states will need to address the impacts
35 of fires and other contributing sources on meeting reasonable progress in their
36 control strategy analyses, as well as during periodic progress assessments. The
37 EPA will revisit this section of the Air Quality Policy on Wildland and Prescribed
38 Fires after the final rules for implementing the regional haze program have been
39 promulgated.30
40
26
A state/tribe certifies “to EPA that they have adopted and are implementing a smoke management
program that includes the basic components identified in this policy.” EPA Interim Policy, p. 7.
27
EPA Interim Policy, pp. 17-23.
28
EPA Interim Policy, p. 18. [The term “basic smoke management program” or “BSMP” is sometimes
used to refer to smoke management programs for NAAQS and nuisance. –Ed.]
29
AAQTF Recommendation on Air Quality Policy, p.2
30
EPA Interim Policy, p. 31.
ESMP Policy Draft D, 7/1/02 II - D - 12
1 To date, the EPA has not integrated regional haze considerations outlined in the Rule
2 with its Interim Policy.
3
4 The AAQTF Recommendation on Air Quality Policy, published after the EPA Interim
5 Policy, addresses regional haze as follows:
6
7 [The Regional Haze Rule] establishes a program to facilitate the integration of
8 emission management strategies for regional haze with SIP components that
9 address emissions of NOx, SO2, VOCs and PM2.5. The Rule strongly encourages
10 multi-state planning efforts to address the haze issue and Air Quality Agencies are
11 moving forward with this effort.31
12
13 2.5.2 Current Smoke Management Efforts
14
15 Most current smoke management efforts and programs to date in the WRAP region have
16 been developed to address public health and/or nuisance concerns, and do not have
17 procedures to address regional haze. States/tribes are currently addressing NAAQS
18 and/or nuisance to the extent they deem appropriate through existing smoke management
19 efforts. Some states/tribes have certified their smoke management programs, both inside
20 and outside the SIP/TIP process. The EPA certified programs include those mandated by
21 rule, state statute, and programs based on voluntary measures.32
22
23 There is considerable variety among current smoke management efforts of the states and
24 tribes in the WRAP region. The WRAP recognizes that few, if any, states/tribes have
25 smoke management programs that address all fire sources, (e.g., prescribed fire on
26 wildlands, wildland fire use, wildfire and agricultural burning), in one unified program.
27 Current smoke management efforts in the WRAP region range from some fire sources
28 having little or no regulation to other fire sources in the same area having a centralized
29 authority deciding which burns may be conducted and when.
30
31 Based on the FEJF-commissioned smoke management program surveys,33 prescribed fire
32 on public wildlands is the most widely regulated fire source sector, with smoke
33 management programs run by a centralized burn authority existent in a majority of
34 WRAP states (AZ, CA, OR, WA, ID, MT, UT). According to the FEJF surveys, three
35 states (CA, OR, WA) in the WRAP Region actively regulate and track agricultural fire
36 sources, and smoke management programs for private rangeland burning are less
37 common than agricultural smoke management programs.
38
39 Under the WRAP ESMP Policy, an enhanced smoke management program does not
40 erode states’/tribes’ current smoke management efforts, but rather, assumes that
41 states/tribes will maintain their current smoke management efforts and/or smoke
42 management programs for NAAQS and/or nuisance. If there are currently no smoke
43 management efforts, an enhanced smoke management program will still be needed, as per
31
AAQTF Recommendation on Air Quality Policy, p. 10.
32
WRAP states implementing smoke management programs using voluntary measures include NM and ID.
33
See Appendix B, Related Documents Listing.
ESMP Policy Draft D, 7/1/02 II - D - 13
1 the requirements of Section 309 of the Rule. The WRAP ESMP Policy can be used to
2 establish new programs to address visibility concerns. While the WRAP ESMP Policy
3 provides a framework for visibility/regional haze, states/tribes may choose to do more in
4 their smoke management programs to protect NAAQS, prevent nuisance and/or address
5 visibility.
6
7 2.6 The Regional Haze Rule Requirements to Address Fire
8
9 The Rule requires states/tribes to address visibility impairment in mandatory Class I areas
10 due to emissions from fire activities. The Preamble to the Rule emphasizes the
11 “[i]mplementation of smoke management programs to minimize effects of all fire
12 activities on visibility.”34 Just like the EPA’s 1992 Prescribed Burning Background
13 Document35 required incorporation of Best Available Control Measures (BACM) for fire
14 emissions into the SIPs/TIPs to address PM10 NAAQS, the Rule requires states under
15 Section 309 to incorporate an enhanced smoke management program into regional haze
16 SIPs that address visibility effects from all fire sources that contribute to visibility
17 impairment in mandatory Class I areas.36
18
19 Fire is addressed in both Sections 308 and 309 of the Rule as a source of potential
20 visibility impairment. States/tribes complying with either Section 308 or 309, addressing
21 other than the 16 Class I areas on the Colorado Plateau, will need a strategy to develop
22 and track reasonable progress toward the natural visibility goal, calculate baseline and
23 natural visibility conditions, develop a long-term strategy for management of emissions,
24 establish a monitoring strategy, prepare periodic reports demonstrating progress, and
25 develop or update SIPs/TIPs.37
26
27 2.6.1 Emissions Tracking
28
29 The tracking of emissions from all fire (i.e., wildland and agricultural land) is a
30 requirement of the Rule for states choosing to implement the Rule either via Section
31 30838 or via Section 309.39 Further, emissions tracking will provide information critical to
32 implementing several of the necessary elements of an enhanced smoke management
33 program. Accurate inventories of regulated pollutants emitted by burning on wildlands
34 and agricultural lands will allow for revising SIPs/TIPs to reflect reasonable progress
35 goals, tracking progress in emission reductions, determining the effectiveness of visibility
36 monitoring and modeling, and the calculation of baseline natural visibility conditions.
37
34
64 FR 35748.
35
U.S. EPA, Office of Air Quality Planning and Standards, Prescribe Burning Background Document and
Technical Information Document for Prescribed Burning Best Available Control Measures, EPA-450/2-92-
003, September 1992.
36
The EPA has recently proposed approval of voluntary emission budgets with an established backstop for
stationary sources of sulfur dioxide as one potentially adequate approach to meeting regional haze
requirements. 67 FR 30418, May 6, 2002.
37
64 FR 35765-35769, § 51.308 and 35769-35773, § 51.309.
38
64 FR 35767, § 51.308 (d) (3) (iv) and 35769, § 51.308 (g) (4).
39
64 FR 35771, § 51.309 (d) (6) (ii)
ESMP Policy Draft D, 7/1/02 II - D - 14
1 It is important that information can be compared within and between states/tribes in order
2 to assess impacts to regional haze. By collecting the seminal burn activity information
3 uniformly, the emissions can then be calculated in a consistent fashion across the WRAP
4 region. Section 309 also requires projected fire emissions be addressed in order to
5 facilitate regional haze planning and operational smoke management.40 The FEJF is
6 currently developing policy on emissions tracking for use in the WRAP region to
7 facilitate these objectives.
8
9 2.6.2 Section 309
10
11 The EPA incorporated all of the GCVTC Recommendations into Section 309 of the Rule,
12 which specifically calls for “[e]nhanced smoke management programs for fire that
13 consider visibility effects, not only health [NAAQS] and nuisance objectives….”41 Under
14 Section 309, states must incorporate an enhanced smoke management program into their
15 SIPs, which will give them the demonstration of reasonable further progress through
16 2018.42 The ability of a state/tribe to implement the enhanced smoke management
17 program may require legislative changes to existing rules or removal of exemptions from
18 regulation for specific fire sources. Should a state be unable to meet the requirements of
19 the enhanced smoke management program, it is possible that the Section 309 option may
20 become unavailable.
21
22 Also under Section 309, the Rule calls for the establishment of annual emission goals for
23 fire that will minimize emissions increases from fire to the maximum extent feasible.43
24 The FEJF is currently developing policy on the establishment of annual emissions goals
25 that will work in concert with the WRAP ESMP Policy. The policy on annual emissions
26 goals will also be coordinated with the FEJF policy on emissions tracking.
27
28 2.6.3 Section 308
29
30 Under Section 308, a state must consider smoke management techniques for agricultural
31 and forestry lands in its long-term strategy for regional haze.
32
33 Section 308 of the Rule states:
34
35 The State must identify all anthropogenic sources of visibility impairment
36 considered by the State in developing its long-term strategy [for regional haze].
37 The State should consider major and minor stationary sources, mobile sources,
38 and area sources.44
39 and:
40 (v) The State must consider, at a minimum, the following factors in developing its
41 long-term strategy [for regional haze]:
40
64 FR 35771, § 51.309 (d) (6) (i).
41
64 FR 35771, § 51.309 (d) (6) (iv).
42
64 FR 35769, § 51.309 (a).
43
64 FR 35771, § 51.309 (d) (6) (v).
44
64 FR 35767, § 51.308 (d) (3) (iv).
ESMP Policy Draft D, 7/1/02 II - D - 15
1 (E) Smoke management techniques for agricultural and forestry management
2 purposes including plans as currently exist within the States for these purposes.45
3
4 If a state’s visibility impairment analysis46 shows that fire sources contribute to visibility
5 impairment in a mandatory Class I area and the state determines that fire sources need to
6 be addressed in its SIP, then the enhanced smoke management program will be a viable
7 tool to do so. For this reason, the WRAP is advancing the WRAP ESMP Policy for both
8 Section 308 and 309 to meet the requirements of the Rule.
9
10 2.6.4 Regional Haze Implementation Plan (SIP/TIP) Process
11
12 The Rule requires states to develop State Implementation
13 Plans (SIPs) for addressing regional haze in the Nation’s
14 156 mandatory Class I areas.47 Additionally, the Rule requires effective
15 management of fire sources and specifically, the development of smoke management
16 programs.
17
18 Tribes are not subject to the same requirements of the Rule as states, but tribes wishing to
19 assume the regional haze requirements outlined in the Rule may, according to the Tribal
20 Authority Rule (TAR), seek approval under 40 CFR 49 to be “treated as States.”48 In
21 these cases, EPA still recognizes that “unlike States, tribes are not required by the TAR to
22 adopt and implement CAA plans or programs, thus tribes are not subject to mandatory
23 deadlines for submittal of implementation plans.”49 Although provision for flexibility in
24 the submission of programs and implementation plans for tribes is made under TAR,
25 EPA does “encourage tribes choosing to develop implementation plans to make every
26 effort to submit by the deadlines to ensure that the plans [TIPs] are integrated with and
27 coordinated with regional planning efforts.”50
28
29 For those tribes who do not seek eligibility under TAR, the EPA will retain responsibility
30 for protecting tribal air quality until such time as tribes administer their own air quality
31 protection programs.51 In keeping with the intent of this Policy to assist states and tribes
32 with their development of regional haze SIPs/TIPs as related to fire sources, tribes are
33 included in the discussion of SIP/TIP submittal that follows.
34
45
64 FR 35767, § 51.308 (d) (3) (v) (E).
46
As outlined in the Rule under Section 308, this process includes calculating the baseline of all sources;
comparing the baseline visibility conditions with natural conditions; assessing the contribution to this of the
different sources (of which smoke is one); then considering in the development of long term strategies:
smoke management techniques, including current smoke management programs that exist; and if not
adequate, considering enforceable emissions limitations and compliance schedules and other measures as
necessary. 64 FR 35765 § 51.308.
47
The Rule is only applicable to mandatory Class I areas (see Appendix A & Appendix B for additional
information on mandatory Class I areas). States/tribes in the WRAP region may utilize the WRAP ESMP
Policy to protect visibility in non-mandatory Class I areas.
48
64 FR 35759.
49
64 FR 35758.
50
64 FR 35759.
51
64 FR 35758.
ESMP Policy Draft D, 7/1/02 II - D - 16
1 In general, the SIP/TIP process includes the following steps: state/tribal agency technical
2 analyses; identification of necessary emission reductions; identification of control
3 strategies to achieve emission reductions; demonstration of reasonable further progress;
4 submittal of SIP/TIP to EPA for consideration/approval; public review/comment; EPA
5 approval of SIP/TIP; 5-year state/tribe review for reasonable progress and SIP/TIP re-
6 submittal.
7
8 It is anticipated that the establishment of enhanced smoke management programs will be
9 incorporated into the SIPs/TIPs submitted to EPA in order to meet the requirements of
10 the Rule. Within the context of smoke management, it is recommended that states/tribes
11 integrate their NAAQS and visibility SIP/TIP requirements.
12
13 Under Section 309, states are required to, and tribes may, have a regional haze
14 implementation plan that addresses the Class I areas of the Colorado Plateau (the 16
15 Class I areas specified by the GCVTC) 52 submitted by December 31, 2003. The Rule
16 stipulates that states must commit to implement all SIP measures from December 31,
17 2003 through December 31, 2018.53 Further, all mandatory Class I areas in the GCVTC
18 Transport Region, other than the Colorado Plateau 16, may be addressed in SIPs/TIPs by
19 the 2008 Section 309 deadline.54
20
21 Under Section 308 states must, and tribes may, incorporate the requirements of the Rule
22 into their implementation plans within 12 months of designation as PM2.5 attainment, or
23 within three years after designation as PM2.5 non-attainment, but no later than December
24 31, 2008. Under Section 308, all mandatory Class I areas, except those addressed under
25 Section 309, will be addressed in the SIP/TIP submittal tied to the PM2.5 designation.55
26
27
28 3. Annotated WRAP ESMP Policy
29
30 3.1 Elements Description
31
32 The WRAP ESMP Policy elements include measures to control and/or reduce emissions
33 from fire (Elements 1, 3, and 8); tools to assess and manage the potential impacts from
34 fire (Elements 2 and 5); and operational components of a successful smoke management
35 program (Elements 4, 6, 7, and 9). In addition to the elements descriptions that follow,
52
The GCVTC Report specified 16 mandatory federal Class I areas on the Colorado Plateau that were
adopted into Section 309 of the Regional Haze Rule. These 16 Class I areas are: Grand Canyon National
Park, Sycamore Canyon Wilderness, Petrified Forest National Park, Mount Baldy Wilderness, San Pedro
Parks Wilderness, Mesa Verde National Park, Weminuche Wilderness, Black Canyon of the Gunnison
Wilderness, West Elk Wilderness, Maroon Bells Wilderness, Flat Tops Wilderness, Arches National Park,
Canyonlands National Park, Capital Reef National Park, Bryce Canyon National Park, and Zion National
Park. 64 FR 35770, § 51.309 (b) (1).
53
64 FR 35770, § 51.309. EPA Region 9 has determined that implementation schedules may be negotiated
as part of the SIP/TIP process and has previously accepted up to one year for implementation of SIP/TIP
programs.
54
64 FR 35773, § 51.309.
55
64 FR 35765, § 51.308 (b) (1), (2).
ESMP Policy Draft D, 7/1/02 II - D - 17
1 suggestions for implementation of the nine enhanced smoke management program
2 elements are included in Appendix C of this document.
3
4 1. Actions to Minimize Emissions from Fire
5
6 A wide range of opportunities to minimize emissions exists depending upon the fire
7 source and management objectives. Four potential actions that may be used are: emission
8 reduction techniques, establishing burn manager qualification programs,56 developing
9 incentive programs, and establishing emissions goals.
10
11 2. Evaluation of Smoke Dispersion
12
13 A variety of tools and methods exist by which a land manager/owner could reduce smoke
14 impacts over periods ranging from several hours to several days. States/tribes may focus
15 on the use of specific weather information, fuels information, modeling or a burner
16 qualification and certification program to assist in the evaluation of dispersion conditions.
17
18 3. Alternatives to Fire
19
20 Methods to consider alternatives to fire (not the alternative methods of burning discussed
21 in (1) above) will be addressed in all enhanced smoke management programs. The
22 minimal consideration in the enhanced smoke management program is that states/tribes
23 provide to land managers/owners information on alternatives to fire. Land
24 managers/owners may be required to assess the feasibility of using alternatives to fire
25 where there are many competing sources or large amounts of burning occurring that
26 could lead to visibility impairment in mandatory Class I areas. Regulatory authorities
27 may want to consider incentives to encourage the use of alternatives to burning where
28 appropriate.
29
30 4. Public Notification of Burning
31
32 Public notification is a significant part of the CAA, and is inherent in the Rule. Public
33 notification under an enhanced smoke management program should be at least what is
34 required by EPA for a certifiable smoke management program,57 and may include extra
35 activities, depending on location. Generally, regardless of what kind of smoke
36 management program is in place, significant effort should be made to educate and notify
37 the public about burning, its impacts, as well as its benefits.
38
39 5. Air Quality Monitoring
40
41 Monitoring of smoke impacts may be a very sophisticated effort using EPA reference
42 method sampling equipment or it may be as simple as creating a hand-written log of
56
States/tribes could consider adopting existing burn qualification programs sanctioned by land
management agencies.
57
EPA Interim Policy, p.17-23.
ESMP Policy Draft D, 7/1/02 II - D - 18
1 smoke behavior as assessed visually. Minimal procedures would be most likely in areas
2 of little burn activity or when farther away from Class I areas.
3
4 6. Surveillance and Enforcement
5
6 Good communication between regulators and land managers/owners can significantly
7 reduce the need for surveillance and enforcement. An atmosphere of trust and
8 cooperation between regulators and land managers/owners can help facilitate emissions
9 reductions and compliance with air quality regulations. Performance and compliance
10 standards may be established under various methods of operations. Some methods to
11 consider for implementation are:
12
13 • Voluntary (Land manager/owner self-enforcement)
14 • Source sector regulator (e.g., Agricultural Burn Manager, Smoke Management
15 Meteorologist)
16 • State/tribe oversight
17 • Centralized regulatory authority
18
19 7. Program Evaluation
20
21 Enhanced smoke management programs need to be reviewed for their effectiveness by
22 the regulatory authority on a periodic basis. Formal periodic progress reports could
23 coincide with time intervals used to evaluate reasonable progress. The Rule requires
24 progress reports every five years.58 However, shorter review and evaluation time periods
25 would better determine if enhanced smoke management programs are effective.
26
27 8. Burn Authorization
28
29 Burn authorization requirements are expected to vary depending upon the amount of
30 burning that is occurring, the fire source types that are conducting the burning, and the
31 degree of impairment that exists or may be expected to occur as a result of the burning.
32 The proximity of mandatory Class I and non-attainment areas may also have a bearing on
33 the complexity of the burn authorization procedure that should be implemented. Four
34 broad levels of stringency may be considered in the development and adoption of an
35 enhanced smoke management program:
36
37 • Establish a permit-by-rule system
38 • Establish a burn permitting system by source sector
39 • Establish a centralized burn authority
40 • Establish a regional burn authority
41
42 9. Regional Coordination
43
58
64 FR 35768, § 51.308 (g) and 35772, § 51.309 (d) (10).
ESMP Policy Draft D, 7/1/02 II - D - 19
1 Coordination of burning activity is critical to avoiding cumulative smoke impacts within
2 and across source types in mandatory Class I areas. Coordination may range from a
3 passive mode of information sharing between land managers/owners and/or the public to
4 a more complex, active coordination in which burn decisions are altered based on
5 jurisdictional authority and other activities that are occurring or have recently occurred.
6 Methods for this inter-jurisdictional and regional coordination will need to be developed.
7 The development process should be a collaborative one involving state, tribal, local and
8 federal agencies, and private parties.
9
10 3.2 Elements Rationale
11
12 The first seven enhanced smoke management program elements come directly from
13 Section 309 of the Rule that states that SIPs “must include smoke management programs
14 that include all necessary components including, but not limited to, actions to minimize
15 emissions, evaluation of smoke dispersion, alternatives to fire, public notification, air
16 quality monitoring, surveillance and enforcement, and program evaluation.”59 These
17 same smoke management components are also found in the EPA Interim Policy and the
18 AAQTF Recommendation on Air Quality Policy. 60
19
20 The EPA Interim Policy and the AAQTF Recommendation on Air Quality Policy also
21 advocate a burn authorization component (i.e., Element #8).61 Without a central burn
22 authority considering the cumulative smoke impacts, it will be difficult on a daily basis
23 for individual land managers/owners to assess their relative contribution to regional haze.
24
25 Regional coordination (i.e., Element #9) is central to burn authorization, and will
26 facilitate coordinated decision-making. It is a necessary mechanism to address transport
27 issues and cumulative effects, especially when considering impacts of a source that may
28 be large, or many sources that cumulatively are large, but a long distance from a Class I
29 area (i.e., greater than 100 km). Regional coordination is emphasized in the Rule as key
30 to reaching the natural visibility goal:
31
32 Progress toward the national [visibility] goal will require regional programs that
33 operate over large geographic areas and limit emissions of pollutants that can
34 cause regional haze.62
35 and:
36 In developing each reasonable progress goal, the State must consult with those
37 States, which may reasonably be anticipated to cause or contribute to visibility
38 impairment in the mandatory Class I Federal area.63
39
59
64 FR 35771, § 51.309 (d) (6) (i), emphasis added.
60
EPA Interim Policy, p. 17-23, and AAQTF Recommendation on Air Quality Policy, p. 2.
61
EPA Interim Policy, p. 18, and AAQTF Recommendation on Air Quality Policy, p.12.
62
64 FR 35718.
63
64 FR 35766, § 51.308 (d) (1) (B) (iv).
ESMP Policy Draft D, 7/1/02 II - D - 20
1 The enhanced smoke management program elements of this Policy, including burn
2 authorization and regional coordination, are necessary to address visibility effects that
3 contribute to visibility impairment in mandatory Class I areas.
4
5 3.3 Criteria Description
6
7 According to the Rule, enhanced smoke management programs will be developed based
8 on the criteria of efficiency, economics, law, emission reduction opportunities, land
9 management objectives, and reduction of visibility impacts.64 These criteria may
10 influence the extent to which individual elements of the enhanced smoke management
11 program are applied or the level of effort that is possible. For example, legal barriers may
12 need to be removed and/or infrastructure may need to be developed to implement the
13 enhanced smoke management program. It is envisioned that, through a collaborative
14 effort, a schedule and process for implementing the enhanced smoke management
15 program will be created that is acceptable to both EPA and affected stakeholders.
16 Additional examples of the enhanced smoke management program criteria are listed
17 below.
18
19 Efficiency: What are the resources, infrastructure, networking, workforce and
20 information necessary to reduce visibility impairment in mandatory Class I areas? Is it
21 feasible to share these items with another group in order to reduce redundancy or build on
22 existing expertise?
23
24 Economics: What are the costs and incentives of the items listed under
25 Efficiency? Are there ways to economically quantify improvements to regional haze in a
26 local area? What is the economic trade-off of moving fuels off-site to be converted to
27 another use or burned elsewhere? What are the economic costs to a landowner to look for
28 emission reduction alternatives? What are the economic gains from improved habitats,
29 functioning watersheds, species diversity and healthy ecosystems? What are the
30 economic losses to a community associated with impairment, (e.g., property values,
31 tourism, etc.)?
32
33 Law: Are there federal, state, tribal ordinances, local rules or statutes that prohibit
34 mechanical treatments or prohibit the regulation of burning? Are there conflicts with
35 management or law pertaining to Threatened and Endangered Species and/or the
36 Wilderness Act?
37
38 Emission Reduction Opportunities: Where are the opportunities to consider
39 reducing emissions through mechanical, biological, or chemical means? Where are the
40 places where reducing emissions will be best done through smoke management
41 techniques rather than moving fuels off-site or manipulating fuels through chemicals or
42 biological decomposition or a combination of mechanical treatments and maintenance
43 burning?
44
64
64 FR 35771, § 51.309 (d) (6) (iv).
ESMP Policy Draft D, 7/1/02 II - D - 21
1 Land Management Objectives: Are there places where manipulating fuels is not
2 an option because of land management objectives, e.g., tribal cultural values, wildlife
3 habitat, crop requirements, residue removal constraints, or inaccessible terrain? Are there
4 places where manipulating fuels is more conducive to the land management objective,
5 e.g., areas targeted for commodity production, watershed protections or tribal cultural
6 activities sites? Are there places that restoration of ecosystem function may have a high
7 priority?
8
9 Reduction of Visibility Impacts: Using the current information and science
10 available to a state/tribe, how will an enhanced smoke management program decrease
11 impacts to visibility?
12
13 4. Enhanced Smoke Management Program Implementation
14
15 This section deals with several important aspects of implementation of an enhanced
16 smoke management program, including responsibilities of the regulatory authority and
17 the land owner/manager. According to this Policy, enhanced smoke management
18 programs will be developed through a collaborative stakeholder process involving state,
19 tribal, local and federal agencies, and private parties.
20
21 In accordance with Policy Statement F, this section presents a number of implementation
22 options for states and tribes to consider in determining the appropriate level of effort for
23 each of the enhanced smoke management program’s nine elements. The implementation
24 options explored here are not exhaustive or definitive in structure or design. These
25 options may be viable and there are other ways in addition to these that states/tribes may
26 want to consider.
27
28 One of the recommendations of the GCVTC was to address potential funding
29 mechanisms; this section offers some suggestions on this. Additional guidance on
30 implementation of the elements is included in Appendix C of this document.
31
32 4.1 Responsibilities Under an Enhanced Smoke Management Program
33
34 Throughout all the enhanced smoke management program elements outlined in this
35 Policy, it is assumed that the regulatory authority (i.e., state, tribe, or EPA on behalf of
36 the tribe) has the oversight for the enhanced smoke management program through its
37 implementation plan, although it may choose to delegate implementation to another
38 entity, e.g., county, municipality, fire source sector representative or other non-
39 governmental organization. It is the regulatory authority’s responsibility to ensure that the
40 mechanisms and infrastructure are in place to implement the enhanced smoke
41 management program. In some cases this will mean a system such as consistent forms,
42 databases or websites, or on-site mechanisms by which the needed information will be
43 obtained from the land manager/owner. It will also be the responsibility of the regulatory
44 authority to track emissions and determine the amount of the contribution to visibility
45 impairment in Class I areas.
46
ESMP Policy Draft D, 7/1/02 II - D - 22
1 The greater the impact to visibility in mandatory Class I areas (as determined by the
2 regulatory authority in consultation with the federal land manager), the greater the
3 responsibility of the regulatory authority. Accordingly, the infrastructure necessary to
4 implement the enhanced smoke management program will also be greater. For example,
5 areas where multiple source type or multiple landowner/land managers are impacting a
6 mandatory Class I area may require increased oversight and coordination of burning to
7 address the situation.
8
9 It is also incumbent upon the regulatory authority to develop a SIP/TIP that is consistent
10 with Section 118 of the CAA pertaining to equitable treatment of federal activities.
11 Section 118 requires that all entities, federal and non-federal, be subject to the same
12 requirements, authorities and processes. Section 118 states, in part:
13
14 ...Each department, agency, and instrumentality of the executive, legislative, and
15 judicial branches of the Federal Government (1) having jurisdiction over any
16 property or facility, or (2) engaged in any activity resulting, or which may result,
17 in the discharge of air pollutants, and each officer, agent, or employee thereof,
18 shall be subject to, and comply with, all Federal, State, interstate, and local
19 requirements, administrative authority, and process and sanctions respecting the
20 control and abatement of air pollution in the same manner, and to the same extent
21 as any nongovernmental entity....65
22
23 Equitable application of enhanced smoke management program requirements is the
24 regulatory authority’s responsibility. It is the land manager’s/owner’s responsibility to
25 meet the enhanced smoke management program requirements. The land manager/owner
26 needs to ensure that data and information submitted to the regulatory authority are
27 accurate, timely, and complete. In some instances this may be no more onerous than a
28 form faxed by the land manager/owner to the regulatory authority’s office at the end of
29 the year; in others, extensive information on a daily basis regarding planned and
30 accomplished burning is required.
31
32 Finally, failure of the regulatory authority to develop appropriate and necessary oversight
33 and responsibilities may result in EPA's disapproval of the regional haze SIP/TIP.
34
35 4.2 Implementation Options
36
37 The WRAP ESMP Policy includes nine elements to be included in the SIP/TIP. A
38 state/tribe may apply the enhanced smoke management program uniformly throughout its
39 jurisdiction, or may elect to apply different degrees of implementation of the enhanced
40 smoke management program elements to the different fire source sectors and/or
41 geographical areas. Since fire sources that contribute to regional haze may be from
42 different geographical areas, the partitioning of a geographic area may be considered
43 under this Policy. State/tribal authorities will want to be mindful of equitable treatment of
44 sources in the implementation of their enhanced smoke management programs.
45
65
Clean Air Act § 118 (a).
ESMP Policy Draft D, 7/1/02 II - D - 23
1 This section presents a number of implementation options for states and tribes to consider
2 in determining the appropriate level of effort for each of the enhanced smoke
3 management program’s nine elements. The options described below may be implemented
4 independently or in any combination, as necessary. The implementation options explored
5 here are not exhaustive or definitive in structure or design. These options may be viable
6 and there are other ways in addition to these that states/tribes may want to consider.
7
8 4.2.1 Source Sector Thresholds
9
10 Under this implementation option, there is a presumption that certain source sectors are
11 reasonably expected to contribute to visibility impairment based on historical data and/or
12 projected future burning. Where this presumption exists, states/tribes could choose to
13 apply the nine enhanced smoke management program elements to those source sectors
14 with a greater level of effort.
15
16 4.2.2 Situational Thresholds
17
18 The situational thresholds describe certain circumstances that, if true, would indicate to
19 the state/tribe the need for a greater level of effort of implementation of the enhanced
20 smoke management program elements. The scenarios below can be used by states/tribes
21 in the development of area and/or source sector-specific enhanced smoke management
22 programs. Each scenario describes a combination of emission levels, NAAQS status (e.g.,
23 non-attainment area status) and proximity to Class I areas that may indicate the level of
24 enhanced smoke management program needed.
25
26 The following is an example of how these situational thresholds could be applied, and is
27 modeled after the Prevention of Significant Deterioration (PSD) permitting
28 requirements66 for major stationary sources (see table in footnote below).67 In this
29 example, the emissions are the annual totals that would be produced by a fire source
30 sector. The attainment status accounts for existing non-attainment area (NAA) issues that
31 a state/tribe may need to address. The proximity parameter addresses how close a fire
32 source sector is to a Class I area. This example is predicated on all three factors applying
33 simultaneously.
66
40 CFR § 52.21.
67
This table provides estimates of acres burned to give an idea of approximate fire size using the available
emission factors for the source type indicated. These numbers are not an exact representation of acreages,
emission factor, and fuel loading of all fires for each type. Note: Agriculture and Rangeland numbers are
the same.
Tons (PM10) Acres Burned (Annual Total)
Wildland Agriculture Rangeland
(Forest: 20 tons/acre (4 tons/acre consumed) (2 tons/acre consumed)
consumed)
250 833 12,500 12,500
100 333 5,000 5,000
70 233 3,500 3,500
50 167 2,500 2,500
ESMP Policy Draft D, 7/1/02 II - D - 24
1
2 a) Emissions levels: Greater than 50 tons/yr of PM10 (total/year) within
3 state/tribe for all anthropogenic fire sources
4 Attainment status: No PM10* or Ozone NAAs
5 Proximity: Within and near (i.e., <50 km) a Class I area
6
7 b) Emissions levels: Greater than 250 tons/yr of PM10 (total/year) within
8 state/tribe for all anthropogenic fire sources
9 Attainment status: No PM10* or Ozone NAAs
10 Proximity: Within 100 km of Class I area
11
12 c) Emissions levels: Greater than 100 tons/yr PM10 (total/year) within state/tribe
13 for all anthropogenic fire sources
14 Attainment status: Moderate PM10* or Ozone NAA or Maintenance Area
15 Proximity: Within 100 km of Class I area
16
17 d) Emissions levels: Greater than 70 tons/yr PM10 (total/year) within state/tribe
18 for all anthropogenic fire sources
19 Attainment status: Serious PM10* or Ozone NAA
20 Proximity: Within 100 km of Class I area
21
22 e) Emissions levels: Greater than 250 tons/yr of PM10* (total/year) within
23 state/tribe for all anthropogenic fire sources
24 Attainment status: Any level of Attainment/NAA
25 Proximity: Distances farther than 100 km
26
27 * When PM2.5 NAAs are identified, then PM2.5 could also be used in assessing the level
28 of enhanced smoke management program needed.
29
30 4.2.3 Impact Based Thresholds
31
32 A state/tribe can determine the level of effort of an enhanced smoke management
33 program based on the relative contribution (i.e. impact) of its fire source sectors to
34 visibility impairment in Class I areas:
35
36 Since the national [visibility] goal is expressed in terms of air quality (i.e.,
37 visibility) rather than emissions, we believe that it is very important to require the
38 quantitative tracking of visibility impairment as an integral element in measuring
39 reasonable progress.68
40
41 One possible impact level that could be used is related to deciview, the metric commonly
42 associated with visibility analyses and also used within the PSD permitting process.69
43 Under this scenario, states/tribes would determine if a source sector contributes to a
68
64 FR 35726.
69
Significance levels of visibility impairment is an approach used in determining mobile source strategies
under § 309, 64 FR 35771.
ESMP Policy Draft D, 7/1/02 II - D - 25
1 deciview impact (e.g., greater than or equal to 1) on any one of the 20 percent “worst”
2 visibility days in a calendar year. In order to determine this impact, a visibility
3 impairment assessment could be conducted using IMPROVE data, emissions data
4 derived from fire activity data, contemporary visibility modeling techniques, or other
5 available information.
6
7 Note that currently, final analysis of IMPROVE data sometimes lags as much as a year
8 from when data were collected. This situation may also be true of visibility impairment
9 assessments. Therefore, there may be lag time between when impacts were measured and
10 how soon enhanced smoke management programs could be implemented or revised.
11
12 Furthermore, to prevent degradation of the 20 percent “best” visibility days in a calendar
13 year, the state/tribe may want to increase the rigor of its enhanced smoke management
14 program if emissions from fire sources correspond with declining visibility.
15
16 4.3 Funding Mechanisms
17
18 Funding for smoke management programs can come from many possible sources.
19 Funding mechanisms will depend on the magnitude of the smoke management programs.
20 For example, an enhanced smoke management program in a state/tribe with minor smoke
21 impacts to mandatory Class I areas may not require elaborate funding mechanisms, while
22 a program in a state/tribe with a large amount of prescribed burning and a number of
23 mandatory Class I areas may need a complex funding mechanism.
24
25 The following is a list of possible methods for funding smoke management programs:
26
27 A. Funds obtained from users of prescribed fire.
28 g. Memorandum of Understanding (MOU)/Memorandum of Agreement
29 (MOA)/Consortium Funds
30 • Each member/signatory pays an annual membership fee and there is an
31 additional per acre fee for accomplished burns.
32 h. Fees
33 • Permit Fees
34 • Emissions-based Fees
35 • Acreage-based Fees
36 B. Funds Obtained from Users of Class I Areas
37 C. Grants and/or Appropriated Funding
38 • A combination of many sources including EPA grants, state/tribe, city and
39 county governments, fire protection assessments, property taxes.
40 • General revenue program/appropriated funds received from a legislative
41 body.
42 D. Provision of Resources
43 • Fire source sector provides personnel or other resources to aid or manage
44 the enhanced smoke management program in lieu of direct permit
45 payments to defray overall costs of the enhanced smoke management
46 program.
ESMP Policy Draft D, 7/1/02 II - D - 26
1
2
3
4
5
6 APPENDICES
7
8
9
10
11
ESMP Policy Draft D, 7/1/02 II - D - 27
1 Appendix A
2 Glossary
3
4 This glossary is intended to facilitate readers’ consistent review of this Policy. This
5 glossary is not intended to be a complete list of all terms and acronyms. An asterisk (*)
6 indicates a definition from Section 1.1 of the WRAP FEJF Workplan, February 25, 1999.
7 A number sign (#) indicates a definition from the WRAP Policy for Categorizing Fire
8 Emissions, November 15, 2001.
9
10 Agricultural Fire/Burning* - Any fire ignited by management actions to meet specific
11 objectives (i.e., managed to achieve resource benefits) on agricultural land.
12
13 Agricultural Land* - Agricultural land includes croplands, pasture, and other lands on
14 which crops or livestock are produced (PL 104-127, Section 1240A). Rangeland will be
15 included with wildland for the purposes of the Fire Emissions Joint Forum work.
16
17 Alternatives To Burning - Land management practices that treat fuel without using fire.
18
19 Anthropogenic - Produced by human activities.
20
21 Anthropogenic Emissions Source Classification (“anthropogenic”)# - A categorization
22 that designates which fire emissions contribute to visibility impairment in a Federal Class
23 I area. “Anthropogenic” emissions must be controlled to achieve progress toward the
24 2064 natural conditions goal [i.e., natural visibility goal] for each Federal Class I area in
25 the WRAP region. This classification includes natural and human-caused ignitions.
26
27 Area Source - A source category of air pollution that generally extends over a large area.
28 Prescribed burning, field burning, home heating, and open burning are examples of area
29 sources.
30
31 Attainment Area - An area considered to have air quality as good as or better than the
32 national, state/tribe or local ambient air quality standards. Note that an area may be in
33 attainment for one or more pollutants but be a non-attainment area for one or more other
34 pollutants.
35
36 Best Available Control Measures (BACM) - A term used to refer to the most effective
37 measures (according to EPA guidance) for controlling small or dispersed particulates and
38 other emissions from sources such as roadway dust, soot and ash from woodstoves and
39 open burning of rush, timber, grasslands, or trash.
40
41 Best Management Practices (BMPs) - A term applied collectively to any administrative
42 or on-the-ground procedure that reduces the negative impacts of some action. An
43 example of a Best Management Practice with respect to air quality would be conducting a
44 prescribed burn when atmospheric ventilation is good, which in turn promotes smoke
45 dispersal.
46
ESMP Policy Draft D, 7/1/02 II - D - 28
1 Class I Area - See Mandatory Class I Area and Non-Mandatory Class I Area.
2
3 Control of Fire Emissions# - Actions may be taken to control fire emissions by utilizing
4 best management practices such as the use of alternatives, biomass utilization, and other
5 emission reduction techniques.
6
7 Criteria Pollutants - The 1970 amendments to the CAA required EPA to set National
8 Ambient Air Quality Standards for certain pollutants known to be hazardous to human
9 health. EPA has identified and set standards to protect human health and welfare for
10 pollutants: Ozone, carbon monoxide, particulate matter (PM10 and PM2.5), sulfur dioxide,
11 lead, and nitrogen oxide. The term, "criteria pollutants" derives from the requirement that
12 EPA must describe the characteristics and potential health and welfare effects of these
13 pollutants. It is on the basis of these criteria that standards are set or revised.
14
15 Cumulative Effects - The effect on the environment that results from the incremental
16 impact of the action when added to other past, present, and reasonable foreseeable future
17 actions regardless of what agency, entity or person undertakes such action. Cumulative
18 effects can result from individually minor but collectively significant actions taking place
19 over a period of time.
20
21 Deciview - a unit of visibility proportional to the logarithm of the atmospheric extinction.
22 Under many circumstances a change in one deciview will be perceived to be the same on
23 clear and hazy days.
24
25 Ecosystem Maintenance Burning# - A prescribed fire or wildfire managed for resource
26 benefits, in an ecosystem that is currently in an ecologically functional and fire resilient
27 condition, that is utilized to mimic the natural role of fire.
28
29 Ecosystem Restoration Burning# - The re-establishment of natural vegetation that may be
30 accomplished through the reduction of unwanted and/or unnatural levels of biomass,
31 which may have accumulated due to management action. Prescribed fires, wildfires
32 managed for resource benefits and mechanical treatments may be utilized to restore an
33 ecosystem to an ecologically functional and fire resilient condition.
34
35 Emission - pollution discharged into the atmosphere. Examples of emissions sources are
36 smokestacks, other vents, and surface areas of commercial or industrial facilities; from
37 residential chimneys; and from motor vehicle, locomotive, aircraft, or other non-road
38 engines.
39
40 Emission Inventory - A listing, by source, of the amount of air pollutants discharged into
41 the atmosphere.
42
43 Emissions Goal/Cap - The concept of placing a limit on the total amount of emissions
44 generated in a year or an extended time period (e.g., 10 years).
45
ESMP Policy Draft D, 7/1/02 II - D - 29
1 Emission Reduction - A strategy for controlling smoke from prescribed fires that
2 minimize the amount of smoke output per unit of area treated or other objective unit of
3 accomplishment.
4
5 Enhanced Smoke Management Program (ESMP) - A program for fire that considers
6 visibility effects, in addition to health and nuisance objectives, and is based on the criteria
7 of efficiency, economics, law, emission reduction opportunities, management objectives,
8 and reduction of visibility impact.
9
10 Federal Class I area - see Class I Area.
11
12 Fire* - When this term appears, it refers inclusively to wildfire, prescribed natural
13 fire/wildland fire managed for resource benefits, prescribed fire, rangeland fire, and
14 agricultural fire.
15
16 Fire Source Sector - a segment of fire attributed to a particular management or
17 ownership, e.g., wildland prescribed fire, agricultural prescribed fire, wildfire, and
18 wildland fire use. Also known as a fire source.
19
20 Fire Use - A term utilized in federal land management that includes both prescribed fire
21 and wildland fire use.
22
23 Fuel Moisture Content - The quantity of moisture in fuel expressed as a percentage of the
24 weight when thoroughly dried at 212 degrees F.
25
26 Fuel Reduction - The manipulation, including combustion, or removal of fuels to reduce
27 the likelihood of ignition and/or to lessen potential damage and resistance to control.
28
29 Fuel Treatment - Manipulation or removal of fuels to reduce the likelihood of ignition
30 and/or to lessen potential damage and resistance to control (e.g., lopping, chipping,
31 crushing, piling and burning).
32
33 Implementation Plan - Plans devised by states and/or tribes to carry out their
34 responsibilities under the CAA. SIPs/TIPs must be approved by the U.S. Environmental
35 Protection Agency and include public review.
36
37 Interagency Monitoring of Protected Visual Environments (IMPROVE) - A cooperative
38 visibility monitoring effort, using a common set of standards across the United States,
39 between the EPA, federal land management agencies, and state air agencies.
40
41 Jurisdiction - A geographic area of authority.
42
43 Land Managers* - When this term appears, it refers inclusively to federal, state, tribal,
44 and private land managers.
45
ESMP Policy Draft D, 7/1/02 II - D - 30
1 Manage Fire Emissions# - Actions may be taken to manage fire emissions to minimize
2 impacts on visibility, public health, and nuisance concerns. Some management actions
3 include concepts such as the timing of ignitions for better dispersion and consideration of
4 downwind air quality and visibility. It may also include consideration of factors related to
5 the area to be burned such as the fuel moisture condition and other physical parameters.
6 Manage fire emissions is analogous to smoke management.
7
8 Mandatory Class I Area - An area set aside under the CAA to receive the most stringent
9 protection from air quality degradation. Mandatory Class I Federal Areas are (1)
10 international parks, (2) national wilderness areas and memorial parks larger than 5,000
11 acres in size, (3) national parks that exceed 6,000 acres in size and which were in
12 existence when the 1977 CAA amendments were enacted. The extent of a mandatory
13 Class I Federal area includes subsequent changes in boundaries, such as park expansions.
14
15 Modeling - The artificial simulation of some event or action that has quantifiable results.
16 Mathematical expressions and computers are frequently used in modeling.
17
18 National Ambient Air Quality Standards (NAAQS) - See Criteria Pollutants.
19
20 National Environmental Policy Act (NEPA) - Establishes procedures that federal
21 agencies must follow in making decisions on federal actions that may impact the
22 environment.
23
24 National Visibility Goal - Section 169A of the CAA sets forth a national goal for
25 visibility which is the “prevention of any future, and the remedying of any existing,
26 impairment of visibility in Class I areas which impairment results from manmade air
27 pollution.”
28
29 Natural Background Condition# - An estimate of the visibility conditions at each Federal
30 Class I area that would exist in the absence of human-caused impairment.
31
32 Natural Emissions Source Classification (“natural”)# - A categorization that designates
33 which fire emissions can result in a natural reduction of visibility for each Federal Class I
34 area in the WRAP region. This classification includes natural and human-caused
35 ignitions.
36
37 Natural Ignition# - Fire/Burn ignited due to a natural (i.e., non-human-caused) event, e.g.,
38 fire ignited by lightning or volcanic eruption.
39
40 Natural Visibility Goal - The ultimate goal of the regional haze program is the absence of
41 visibility impairment due to human-caused emissions.
42
43 Non-Attainment Area (NAA) - An area identified by an air quality regulatory agency
44 through ambient air monitoring (and designated by the Environmental Protection
45 Agency) that presently exceeds federal, state/tribe or local ambient air quality standards.
46 See Attainment Area above.
ESMP Policy Draft D, 7/1/02 II - D - 31
1 Non-Mandatory Class I Areas - Class I areas designated by states or tribes, but are not
2 deemed mandatory by the CAA. As of January 2002, Class I areas designated by tribes
3 include: Fort Peck Reservation in MT, Northern Cheyenne Reservation in MT, Flathead
4 Reservation in MT, Yavapai-Apache Reservation in AZ (Class I status under litigation),
5 and Spokane Reservation in WA.
6
7 Nuisance Smoke - Unwanted smoke that does not exceed National Ambient Air Quality
8 Standards primarily for particulate matter.
9
10 Particulate Matter - Any liquid or solid particles. "Total suspended particulates" as used
11 in air quality are those particles suspended in or falling through the atmosphere. They
12 generally range in size from 0.1 to 100 microns.
13
14 Plume Blight - Visual impairment of air quality that manifests itself as a coherent plume.
15
16 PM10 - Particulate matter of aerodynamic diameter less than or equal to 10 micrometers.
17 Emissions of PM10 are significant from fugitive dust, power plants, commercial boilers,
18 metallurgical industries, mineral industries, forest and residential fires, and motor
19 vehicles.
20
21 PM2.5 - Particulate Matter of aerodynamic diameter less than or equal to 2.5 micrometers.
22 A measure of fine particles of particulate matter that come from fuel combustion,
23 agricultural burning, woodstoves, etc.
24
25 Point Source - A source of pollution that is point-like in nature. An example is the smoke
26 stack of a coal-fired power plant or smelter. See Source.
27
28 Prescribed Fire* - Any fire ignited by management actions to meet specific objectives,
29 i.e., managed to achieve resource benefits.
30
31 Rangeland# - Land on which the historic climax plant community is predominantly
32 grasses, grass-like plants, forbs, or shrubs. Includes lands re-vegetated naturally or
33 artificially when routine management of that vegetation is accomplished mainly through
34 manipulation of ecological principles. Rangeland includes natural grasslands, savannas,
35 shrub lands, most deserts, tundra, alpine communities, coastal marshes and wet meadows
36 (Natural Resources Conservation Service National Range and Pasture Handbook, 1997.)
37
38 Regional Haze - Visibility impairment caused by the cumulative air pollutant emissions
39 from numerous sources over a wide geographic area.
40
41 Smoke Effects* - The effects on visibility (both plume blight and regional haze), public
42 nuisance, and the health-based NAAQS due to emissions from fire.
43
44 Smoke Intrusion - Smoke from prescribed fire entering a designated area at unacceptable
45 levels.
46
ESMP Policy Draft D, 7/1/02 II - D - 32
1 Smoke Management Efforts - Programs, practices and techniques to minimize and/or
2 reduce smoke emissions or impacts from fire.
3
4 State Implementation Plan (SIP)# - See Implementation Plan.
5
6 Suppression - A management action intended to protect identified values from a fire,
7 extinguish a fire, or alter a fire’s direction of spread.
8
9 Tribal Implementation Plan (TIP)# - See Implementation Plan.
10
11 Transport Region State – One of nine states that make up the Grand Canyon Visibility
12 Transport Region: Arizona, California, Colorado, Idaho, Nevada, New Mexico, Oregon,
13 Utah, and Wyoming.
14
15 Visibility Impairment - Any humanly perceptible change in visibility (light extinction,
16 visual range, contrast, coloration) from that which would have existed under natural
17 conditions.
18
19 Wildfire* - Any unwanted, non-structural fire.
20
21 Wildfire Managed for Resource Objectives # - The management of naturally ignited fires,
22 regardless of land type or ownership, to accomplish specific, pre-stated resource
23 management objectives in predefined geographic areas with or without a plan in place.
24 This term is considered to be analogous with the terms Wildland Fire Managed for
25 Resource Benefits and Prescribed Natural Fire that are used in regulations and policies
26 regarding federal wildlands.
27
28 Wildland*- An area where development is generally limited to roads, railroads, power
29 lines, and widely scattered structures. The land is not cultivated (i.e., the soil is disturbed
30 less frequently than once in 10 years), is not fallow, and is not in the USDA Conservation
31 Reserve Program (CRP). The land may be neglected altogether or managed for such
32 purposes as wood or forage production, wildlife, recreation, wetlands, or protective plant
33 cover (EPA Interim Air Quality Policy). The land is not “agricultural land” as
34 operationally defined above. Silvicultural land and rangelands (per the FEJF charge),
35 woodlots, and private timberlands will be included with wildlands for the purposes of the
36 FEJF work.
37
38 Wildland Fire# - All types of fire (see definition of fire above), except fire on agricultural
39 land.
40
41 Wildland Fire Managed for Resource Benefits/Prescribed Natural Fire* - These terms
42 both have current use in regulations and policies. They are considered to be synonymous
43 and are used interchangeably in this work plan. These terms refer to the management of
44 naturally ignited fires to accomplish specific, pre-stated resource management objectives
45 in predefined geographic areas outlined in the fire management plan. Also referred to as
46 Wildland Fire Use.
ESMP Policy Draft D, 7/1/02 II - D - 33
1 Appendix B
2 Related Documents Listing
3
4 Regional Haze Rule
5 Published in the Federal Register on July 1, 1999, 64 FR 35714.
6 http://www.epa.gov/ttn/oarpg/t1/fr_notices/rhfedreg.pdf
7
8 Grand Canyon Visibility Transport Commission Report
9 Grand Canyon Visibility Transport Commission, Recommendations for Improving Western
10 Vistas, Report to the U.S. EPA, June 10, 1996.
11 http://www.wrapair.org Go to the GCVTC link.
12
13 EPA Interim Air Quality Policy on Wildland and Prescribed Fire
14 U.S. EPA, Office of Air Quality Planning and Standards, Interim Air Quality Policy on Wildland
15 and Prescribed Fires, April 23, 1998.
16 http://www.epa.gov/ttn/oarpg/t1/memoranda/firefnl.pdf
17
18 AAQTF Recommendation on Air Quality Policy
19 Agricultural Air Quality Task Force, Air Quality Policy on Agricultural Burning,
20 Recommendation to the U.S. Department of Agriculture, November 10, 1999.
21 http://fargo.nserl.purdue.edu/faca/Archives/2000/Policy/Burning%20Policy.htm
22
23 Tribal Authority Rule
24 Published in the Federal Register on February 12, 1998, 63 FR 7253.
25 http://www.epa.gov/fedrgstr/EPA-AIR/1998/February/Day-12/a3451.htm
26
27 WRAP Policy for Categorizing Fire Emissions
28 Approved by the Western Regional Air Partnership, November 15, 2001.
29 http://www.wrapair.org/commindex.htm Go to the FEJF Task Teams, then Natural Background.
30
31 Wildland Fire: Elements of a Basic Smoke Management Program Draft Report
32 Completed for the FEJF on July 10, 2001.
33 http://www.wrapair.org/commindex.htm Go to the FEFJ Task Teams, then Basic Smoke
34 Management.
35
36 Smoke Management Program Surveys
37 http://www.wrapair.org/commindex.htm Go to the FEJF, then Basic Smoke Management.
38 1) Wildland Smoke Management Program Survey, January 26, 2001
39 2) Boulder Wildland Smoke Management Program Survey, February 2, 2001
40 3) Agricultural Burning Smoke Management Program Survey, March 30, 2001
41 4) An Assessment of Tribal Air Quality Data and Programs in the Western United States, The
42 Institute for Tribal Environmental Professional (ITEP), September 2001
43
44 Class I Area Map
45 http://www.wrapair.org Go to About WRAP, then WRAP Boundaries and Regional Visibility
46 Planning in the West.
ESMP Policy Draft D, 7/1/02 II - D - 34
1 Appendix C
2 Enhanced Smoke Management Program Elements:
3 Implementation Guidance
4
5 It is the position of the WRAP ESMP Policy that there are nine elements of an enhanced
6 smoke management program that are necessary to meet the requirements of the Rule.
7
8 For each of the enhanced smoke management program elements, there are
9 implementation examples listed to assist states/tribes in developing their enhanced smoke
10 management programs. This is not meant to be an exhaustive list, and states/tribes may
11 also want to review the FEJF draft report on Wildland Basic Smoke Management
12 Program Elements as well as the EPA Interim Policy and the AAQTF Recommendation
13 on Air Quality Policy for additional suggestions.70 The level of effort each state/tribe
14 would apply to the nine elements of the enhanced smoke management program is based
15 on the severity of the smoke impacts in Class I areas affected by fire sources.
16
17 1. Actions to Minimize Emissions from Fire
18
19 A wide range of opportunities to minimize emissions exists depending upon the fire
20 source. Emission reduction techniques may be as simple as changing ignition timing to
21 allow for more efficient combustion. Other techniques may include the use of mechanical
22 means. Options to provide incentives and emissions goals may also serve this purpose.
23
24 Emissions Reductions Techniques
25
26 Under an enhanced smoke management program, provisions are made to account for
27 emission reduction techniques that are utilized when burning. Documentation of emission
28 reduction practices that were considered in the planning or implementation of burns also
29 support annual emissions goals and associated emissions tracking requirements. This
30 documentation may be part of a burn plan or other data collection or reporting system
31 that is used to meet annual emissions goals and associated emissions tracking
32 requirements as developed by the FEJF.
33
34 • Reducing the fuel load to be burned can reduce emissions. This can be
35 accomplished on forestland by not treating (no burning) portions of the unit,
36 yarding, consolidating, or isolating non-merchantable material; providing public
37 firewood access before the burn; finding off-site use for more of the wood before
38 the burn; using chemicals; burning when non-target fuels have a high fuel
39 moisture; using alternative mechanical treatments, and rapid mop-up.
40
41 • In agriculture, emissions can be reduced by baling and removing some of the
42 residue, spot burning only needed areas of the field, strip burning and backing
43 fires. Emissions can also be reduced by moving the burning season into a different
70
See Appendix B, Related Documents Listing.
ESMP Policy Draft D, 7/1/02 II - D - 35
1 time of the year if changes in fuel consumption or emissions factors can be
2 achieved.
3
4 • Land managers/owners should strive for the most efficient combustion possible.
5 Vegetation should be dry and in a condition that will minimize the smoke emitted
6 during combustion. When pile burning, material should be burned in dirt-free,
7 not overly compressed, cured, and dry piles. Piled material should be covered if
8 possible. Fires should be ignited so as to burn as rapidly as possible, in ways that
9 shift the proportion of the burn from the smoldering phase to the flaming phase.
10 Minimizing duff consumption and smoldering through fuel moisture
11 considerations will reduce emissions as well. Land managers/owners should only
12 burn those fuels essential to meet resource management objectives and burn piles
13 when other burns are not feasible, such as in snow or rain.
14
15 Regulatory authorities and other interest groups may also use WRAP guidance
16 information, such as its Alternatives to Burning documents that is currently under
17 development by the FEJF, as a reference for specific alternatives. Another resource is the
18 Smoke Management Guide for Prescribed and Wildland Fire, 2001 Edition (in press).71
19
20 Burn Manager Qualification
21
22 Another manner in which to reduce emissions is a burn manager qualification program
23 that certifies the land manager/owner is knowledgeable of alternative burning practices,
24 emission reductions techniques and is capable of implementing them. Burn manager
25 qualification programs already exist in most federal, state and tribal land management
26 agencies.
27
28 A certification and qualification process could be established by prescribing what training
29 meets requirements (such as training provided by the National Wildfire Coordination
30 Group) and by implementing training seminars and other institutional opportunities for
31 land managers/owners to gain the necessary skills and knowledge to implement proper
32 smoke management techniques. Land manager/owner certification/qualification programs
33 may be similar to those required by federal land management agencies like those offered
34 by the National Wildfire Coordination Group. For non-federal land managers/owners that
35 cannot participate in federal sponsored training, states/tribes could develop their own
36 certification processes and host training courses such as “State Forestry Prescribed Fire
37 Correspondence Course” or an “Interagency Basic Prescribed Fire Course”.
38
39 In an enhanced smoke management program, burner qualifications might be required on
40 permit applications and tracked by the regulatory agency. Burn size, or emission output,
41 might be limited depending on the level of burner qualification. For example, a Level I
42 qualified burner can burn up to abc acres/tons while a Level II qualified burner can burn
43 up to cde acres/tons, and so on.
44 As examples, a few types of burner qualifications are listed below:
71
Smoke Management Guide for Prescribed and Wildland Fire, 2001 Edition (in press), produced by the
National Wildfire Coordinating Group (NWCG) Fire Use Working Team.
ESMP Policy Draft D, 7/1/02 II - D - 36
1 • Satisfactory completion of “State Forestry Prescribed Fire Correspondence
2 Course” and direct experience in three prescribed burns prior to taking the
3 course, or satisfactory completion of the “Interagency Basic Prescribed Fire
4 Course” and direct experience in three prescribed burns before or after the
5 course.
6 • Completion of a National Wildfire Coordinating Group or federal/state/tribe land
7 manager equivalent course dedicated to smoke management or attendance at a
8 state approved smoke management workshop.
9 • Successful completion of a training program, which includes home study, 8-hour
10 classroom session, and a written exam, documented practical experience in
11 prescribed burning, and a signed agreement to conduct all burns in compliance
12 with all applicable laws and ordinances,
13 • Land management agencies and the state/tribe develop and present interagency
14 training to promote understanding of the regulatory context and affects of air
15 pollution, fire ecology, and smoke management.
16
17 Incentives
18
19 Providing incentives to landowners and land managers for practicing emissions
20 reductions techniques and utilizing alternatives to burning is yet another option for
21 states/tribes to include in enhanced smoke management programs. This approach could
22 be seen as addressing equity issues in that those who make efforts to reduce emissions are
23 rewarded for their efforts. The reward to the landowner/land manager could be seen in
24 terms of environmental gains as well as financial gain. The reward to communities could
25 be seen in retaining property values, and maintaining economic development and tourist-
26 related industries.
27
28 Environmental win-win options may be that by decreasing emissions, a burner is given a
29 higher priority when allocating burn days. Or, by utilizing alternatives, a higher priority
30 is given to a burner when attempting to burn. Similarly, financial win-win options may be
31 to decrease any assessed fees or burn costs when alternatives are used before burning.
32 The system rewards those that take the extra time, effort and money to utilize emission
33 reductions and alternatives. Those who either choose not to, or for land management
34 constraints, cannot utilize emission reductions/alternatives, would pay more.
35
36 Landowners/land managers could be afforded the opportunity to deal with other sources
37 to negotiate emissions management strategies for financial gain that would result in a net
38 emissions decrease. In January 2001, the EPA issued a policy document that provides
39 information on discretionary economic incentive programs, and guidance to assist
40 states/tribes with meeting the requirements of the Rule.72 In May 2002, the EPA provided
41 additional guidance on voluntary and backstop approaches to emissions reduction in its
42 Section 309 Annex to the Regional Haze Rule for stationary sources of sulfur dioxide.73
43 In an enhanced smoke management program, an incentive may be available if a
44 landowner/land manager can reduce his/her emissions and gain financially from not only
72
EPA Improving Air Quality with Economic Incentive Programs (EIP Guidance), January 2001.
73
67 FR 30418.
ESMP Policy Draft D, 7/1/02 II - D - 37
1 supplying a marketplace with raw materials, but also receiving payment for emissions not
2 generated.
3
4 Emissions Target
5
6 Another action that could be taken by regulatory authorities to minimize emissions is to
7 establish an emissions target within portions of a state/tribe, the entire state/tribe or over a
8 multi-state/tribe region. How to meet the target would be left to the discretion of the land
9 managers/owners. Establishing such a target would encourage land managers/owners to
10 seek alternative methods of burning and alternatives to burning so as to retain the ability
11 to burn where no alternatives are available.
12
13 2. Evaluation of Smoke Dispersion
14 States/tribes must consider evaluation of smoke dispersion in developing their enhanced
15 smoke management program to be included in their regional haze SIPs/TIPs.
16
17 A variety of tools and methods exist by which a land manager/owner could reduce smoke
18 impacts over periods ranging from several hours to several days. Enhanced smoke
19 management programs could contain the following criteria to support the dispersion
20 estimation process.
21
22 • States/tribes may provide or find ways to provide websites of current weather and
23 fuels information (i.e., fuel moisture) specific to meet the needs of land
24 managers/owners. Land managers/owners would utilize this information to time
25 ignitions during periods of expected good smoke dispersion.
26
27 • Acceptable weather and climatic conditions can be prescribed for burning in specific
28 areas so as to avoid impacting Class I areas. A predefined set of weather elements
29 would provide a degree of certainty as to when burning opportunities would be most
30 likely to occur. Burning should be banned during periods when air stagnation
31 advisories or air pollution alerts are in effect.
32
33 • As described previously, a burner qualification and certification program could be
34 established that includes advanced training on understanding the relationships
35 between weather and smoke dispersion. Individuals who have greater knowledge and
36 understanding of the factors affecting smoke behavior may make better decisions on
37 when and when not to burn.
38
39 • A more sophisticated and more comprehensive effort to evaluate smoke behavior
40 would be to conduct smoke dispersion modeling in the planning and implementation
41 process for burning. Dispersion modeling may be conducted by a state/tribal agency
42 or other delegated regulatory authority. Such modeling results could be used as a
43 screening approach to determine if there should be extra reason for concern about the
44 proposed burn(s). This approach may assist in determining cumulative effects of
45 multiple burns.
ESMP Policy Draft D, 7/1/02 II - D - 38
1 • Centralized decision-making of burn decisions with coordination among land
2 managers/owners (either by source type or between sources) would require a more
3 intensive effort of involvement by groups involved in burning. Land
4 managers/owners would check-in with a centralized burn authority to receive
5 information about other source activity prior to conducting a burn.
6
7 • A rigorous, timely, centralized decision-making system established with the intent of
8 providing "go/no-go" decisions affords a greater level of coordination that would rely
9 on greater infrastructure and resources for support. Meteorologists and other
10 specialists with knowledge of air quality, fire, weather and fuels interaction would
11 provide services that direct where and when burning could occur.
12
13 3. Alternatives to Fire
14
15 The FEJF has conducted landowner/land manager studies of alternatives and is providing
16 guidance discussing the results. States/tribes could establish websites with information
17 describing the alternatives.
18
19 Land managers/owners may be required to assess the feasibility of using alternatives to
20 fire where there are many competing sources or large amounts of burning occurring.
21 Burn plans and data systems could contain information that helps track the practice of
22 using alternatives to fire. Emissions tracking systems74 and reasonable further progress
23 assessments could use this information to validate landowner/land manager's
24 implementation of alternative practices as an emissions reduction technique.
25
26 Sources of smoke from geographic areas that continue to adversely affect a mandatory
27 Class I area's 20 percent worst and best days, according to the Rule, may be required to
28 implement measures that utilize alternatives to burning to the maximum extent feasible as
29 a condition of further burning. Incentives could be identified wherein land owners/land
30 managers have the opportunity to substitute emissions not produced in one area for
31 emissions produced in another geographic area not affecting a Class I area's visibility as
32 long as there is a net emissions decrease as a result of using the alternatives.
33
34 Geographic areas with sustained sources of adverse smoke impacts in mandatory Class I
35 areas may consider burn curtailments if programs to minimize emissions, impacts and
36 alternatives to fire use do not provide the necessary tools to meet reasonable progress
37 toward the natural visibility goal. Such actions could be considered on a fire source basis
38 so as to not impair one source's ability to use fire because of the failure of another source
39 type to take needed actions to meet the natural visibility goal.
40
41 4. Public Notification of Burning
42
43 Public notification is a significant part of the CAA, and is inherent in the Rule. Public
44 notification under an enhanced smoke management program should be at least what is
74
The FEJF is currently preparing a policy on emissions tracking systems to assist states/tribes.
ESMP Policy Draft D, 7/1/02 II - D - 39
1 required by EPA for a certifiable smoke management program,75 and may include extra
2 activities, depending on location. Generally, regardless of what kind of smoke
3 management program is in place, significant effort should be made to educate and notify
4 the public about burning, its impacts on visibility as well as its benefits.
5
6 Public notification includes public education and media relations, and consists of
7 activities such as issuing notices through the local news media including name and phone
8 number of person/agency, fuel type, expected time and date of burn, location of burn, and
9 the expected plume direction, extent, and duration. Public notification of non-burning
10 alternatives that have been considered for a project could also be included.
11
12 Other means of notification may include the use of a website, public open houses or
13 meetings, signs at burn sites, distribution of fact sheets that include information on smoke
14 impacts, brochures, posters, notices, personal contact by phone or visit, or legal
15 advertisements. It is a good practice to maintain a contact list of interested and affected
16 publics, and make sure that notification of planned burns gets to everyone on that list. A
17 plan for notifying the public could be part of the burn plan.
18
19 Effective public involvement, notification, and education can decrease complaints and
20 resistance to burning projects, as well as prepare the public to manage their activities
21 around scheduled burns. Public notification and education activities can also increase the
22 public’s faith in the different agencies and landowners, knowing that their health and
23 welfare is being carefully considered in both planning and implementation. A well-
24 developed public education and awareness program would not only serve the public but
25 also fulfills a Recommendation from the GCVTC.
26
27 Public awareness and education activities may be conducted by states/tribes, land
28 managers/owners, or in cooperation by all. Training and guidance in public notification
29 techniques could be provided to land managers/owners not accustomed to conducting
30 such work, i.e., non-federal land managers/owners. Program administrators might
31 consider developing an in-state/tribe public notification process to assist the non-federal
32 land managers/owners. Programs could strive to enhance non-federal land
33 managers’/owners’ ability to involve public in planning by providing training and
34 guidance, or open forums for disseminating information on planned burning activities
35 that may affect visibility. If the public is involved in planning of such activities regarding
36 potential affects to them, there is less chance of resistance to the burn while it is in
37 progress.
38
39 Finally, developing involvement by the community, and participation by land
40 managers/owners, in the SIP/TIP and National Environmental Policy Act (NEPA)
41 planning processes may be beneficial in developing common expectations.
42
43
44
45
75
See Appendix B Related Documents Listing, EPA Interim Policy.
ESMP Policy Draft D, 7/1/02 II - D - 40
1 5. Air Quality Monitoring
2
3 Monitoring of smoke impacts may be a very sophisticated effort using sampling
4 equipment and extensive modeling or it may be as simple as creating a log of smoke
5 behavior.
6
7 Minimal procedures would be most likely in areas of little burn activity or when farther
8 away from Class I areas. On-site record keeping with subsequent submittal to the
9 state/tribe regulatory authority should be substantive enough for use in analysis of
10 reasonable further progress tracking or emissions reduction programs.
11
12 As burning activity increases, states/tribes and land owners/managers could consider
13 conducting a more widespread and comprehensive monitoring program. The use of
14 cameras, satellite imagery and aerial monitoring to track and document smoke movement
15 could be considered. The use of IMPROVE monitored data may have to be supplemented
16 by air quality monitoring outside of Class I areas to track smoke movement.
17
18 Also, using visitor surveys in Class I areas regarding visibility impairment perceived
19 during their stay may be a way of generating subjective assessments of smoke impacts.
20 Such information would only be used to provide further validation of impacts, as relying
21 on surveys alone would be too subjective for states/tribes to administer reasonable smoke
22 management programs.
23
24 6. Surveillance and Enforcement
25
26 Good communication between regulators, land managers/owners and the public can
27 significantly reduce the need for surveillance and enforcement. An atmosphere of trust
28 and cooperation between regulators and land managers/owners can go a long way toward
29 facilitating emissions reductions and compliance with air quality regulations.
30
31 Four primary methods under which surveillance and enforcement activities may occur
32 are:
33 • Land manager/owner self-enforcement (i.e., peer pressure)
34 • Source sector regulator (e.g., Agricultural Burn Manager, Smoke Management
35 Meteorologist)
36 • State/tribe oversight
37 • Centralized regulatory authority (state or tribe)
38
39 Criteria and activities described below may be applicable for use in any of the four
40 methods. Some of the criteria can, obviously, only be enforced by a body that has legal
41 standing to do so. Whichever of the four methods a state/tribe may choose to implement
42 would be dependent upon the severity of the visibility impacts that are being addressed.
43
44 If states/tribes have regulations in place that govern smoke impacts, public complaints
45 can serve to monitor compliance. Such regulations should define criteria for establishing
46 these smoke impacts. The number and location of public complaints may be used to
ESMP Policy Draft D, 7/1/02 II - D - 41
1 monitor air quality impacts of fires. The number of complaints may not necessarily be a
2 trigger, rather the nature of the complaints and external verification of circumstances
3 leading to the complaints. In some cases, smoke regulations may apply only to non-
4 certified burning. In such cases certified burners cannot be shutdown for complaints
5 related to visibility, but can be shut down for a threat to health or safety.
6
7 Some criteria for taking action on smoke impacting visibility include:
8 • Is the visibility reduction (impact) occasional or constant?
9 • Is the use of property affected?
10 • What are the economic impacts of both burning and not burning?
11 • Is the location of the impact within or outside of a Class I area?
12 • What is the duration of the impairment?
13 • What is the number of people affected?
14 • How many complaints have been received?
15 • Was the burn conducted in compliance with applicable regulations?
16 • Has the visibility impact been mitigated to the extent practicable?
17 • Is the public health threatened?
18 • Is the impact a result of poor planning or of something that could not be
19 anticipated?
20
21 Criteria of performance standards in an enhanced smoke management program must be
22 stated clearly. Methods for detecting non-compliance could also be defined. Some
23 criteria or standards might include:
24 • Numerical standards for optical data at specific Class I areas (e.g., deciviews)
25 • NAAQS
26 • Comparison with photos taken of certain pre-determined visibility conditions
27 (most impaired, least impaired days)
28
29 Accordingly, some methods for detecting compliance might include:
30 • IMPROVE sites
31 • Photo points
32 • NAAQS ambient air monitors
33
34 If performance standards are established in code, random audits and inspections can
35 provide assistance with compliance. Unannounced burn inspections and burn report
36 audits, including smoke dispersion information, are means of ensuring compliance with
37 air quality regulations. Aerial observations are another surveillance method.
38
39 If no visibility impact-related regulations are in place, violation of NAAQS or violation
40 of other codified permit conditions or authorizations might trigger enforcement actions.
41 Enforcement actions must be based on established statute and regulation, and must be
42 applied equitably to all land managers/owners. Depending on state/tribe needs and
43 compliance history, a written report or warning is may be issued on the first instance of
44 violation, while subsequent observed violations result in appropriate legal action.
45
ESMP Policy Draft D, 7/1/02 II - D - 42
1 Example enforcement actions may include:
2 • 5-day moratorium on ignitions
3 • Civil/criminal penalties, depending on how regulations are written
4 • Burn shutdown/mop-up
5 • Notice of violation/compliance order
6 • Liability for cost of suppression or damages
7 • Revocation of permit
8 • Felony punishment for willful or intentional violation
9 • Misdemeanor for careless violation
10
11 7. Program Evaluation
12
13 Enhanced smoke management programs need to be reviewed for their effectiveness by
14 the regulatory authority on a periodic basis. It is incumbent upon the state/tribe to submit
15 progress reports to EPA describing how well the enhanced smoke management program
16 is being implemented as part of meeting reasonable further progress requirements.
17 Formal periodic progress report intervals could coincide with time intervals used to
18 evaluate reasonable progress. The Rule requires progress reports every five years.76
19 However, shorter review and evaluation time periods would better determine if enhanced
20 smoke management programs are effective.
21
22 Generally, daily interaction between land managers/owners and program administrators
23 can provide a continuous means of program evaluation, but a formal method could be in
24 place to document periodic evaluations. Annual evaluations of the overall smoke
25 management program will provide the information needed for periodic reports. Each
26 element of the enhanced smoke management program should consider evaluating:
27 • Implementation
28 • Compliance and enforcement
29 • Sections needing clarification or improvement
30 • Progress towards goals
31 • Recommendation for revisions
32 • Scientific advancements (modeling or other technological needs)
33
34 These annual evaluations could include, but not be limited to:
35 • An accounting of progress towards defined visibility improvement/impact
36 reduction goals
37 • An accounting of progress towards emissions reductions goals
38 • Review of project burning for the next year, as well as additional out-year
39 planning
40 • Regional information, considering visibility impacts to and from adjoining
41 states/tribes
42 • Burn activity summaries
43 • Burning restrictions or air quality alerts
76
64 FR 35768, § 51.308 (g) and 35772, § 51.309 (d) (10).
ESMP Policy Draft D, 7/1/02 II - D - 43
1 • Significant smoke intrusions or visibility impacts
2 • Summaries of IMPROVE and other monitored air quality data
3 • Emission inventory summaries
4 • Information tracking summaries
5 • Smoke complaint summaries
6 • Discussion of alternatives to burning
7
8 In an enhanced smoke management program, federal land managers responsible for
9 protecting air quality related values in Class I areas should be given the opportunity to
10 provide input to annual program evaluations.
11
12 Where MOUs or other agreements govern smoke management programs, an annual
13 meeting should be held where members share successes and failures, data is summarized
14 and the program is evaluated. In cases where review criteria are established in state code,
15 performance can be compared against standards. Permit files may be kept for a period of
16 time, including complaint files, and statistics generated to evaluate trends in the program.
17
18 8. Burn Authorization
19
20 Burn authorization requirements are expected to vary depending upon the amount of
21 burning that is occurring, the fire source types that are conducting the burning, and the
22 degree of impairment that exists or may be expected to occur as a result of the burning.
23 The proximity of non-attainment areas may also have a bearing on the complexity of the
24 burn authorization procedure that should be implemented. Four broad levels of stringency
25 may be considered in the development and adoption of an enhanced smoke management
26 program.
27 • Establish a permit-by-rule system
28 • Establish a burn permitting system by source sector or a coalition of source
29 sectors
30 • Establish a centralized burn authority
31 • Establish a regional burn authority
32
33 Establishment of any of these authorization situations would also entail the development
34 of coordination procedures described in (9) below.
35
36 Permit-by-Rule
37
38 The AAQTF Recommendation on Air Quality Policy describes a process in which a set
39 of requirements are established under which burning may take place. These requirements
40 may include acreage, time of year, time of day and meteorological factors.77 A written
41 permit may or may not be required. As long as the conditions are met, then burning may
42 occur. There is no daily decision-making by a coordinating authority in this scenario.
77
AAQTF Recommendation on Air Quality Policy, p.9.
ESMP Policy Draft D, 7/1/02 II - D - 44
1 Such a system may be applicable for any fire source type in geographic areas of low fire
2 use. This system should, however, still allow for the collection of enough information by
3 an appropriate regulatory authority so that source activity and emissions may be tracked.
4
5 Burn Permitting System
6
7 A burn permitting system that is established by fire source type would include a local
8 burn manager and/or state, tribe, local agency, whose responsibility is to develop the
9 conditions under which burning may occur and then ensure that burning occurs within the
10 requirements that are established. The elements described in this WRAP ESMP Policy
11 would be implemented by the burn manager to ensure that visibility in Class I areas is
12 protected.
13
14 Centralized Burn Authority
15
16 A more intensive level of smoke management would involve the creation of a centralized
17 authority at the state, tribal or local level that provides daily coordination and approval of
18 burns if significant state/tribe-wide burning is occurring. The centralized authority may
19 be responsible for activities of one particular source type or a combination of sources.
20 This type of program could include the detailed use of meteorological information, burn
21 information and a permitting system to avoid cumulative impacts of smoke from a variety
22 of burns.
23
24 Regional Burn Authority
25
26 Establishment of a regional burn authority may be required if there are continued and
27 extensive inter-state impacts from burning. States/tribes would agree to have oversight of
28 burning by an authority that equitably considers burning opportunities for all source types
29 while addressing the Class I area impacts over broad areas. A regional burn authority
30 would likely, in most cases, be working with the most severe and persistent problems.
31
32 9. Regional Coordination
33
34 Coordination of burning activity is critical to avoiding cumulative visibility impacts
35 within and across source types. Coordination may range from a passive mode of
36 information sharing between land managers/owners and/or the public to a more complex,
37 active coordination in which burn decisions are altered based on other activities that are
38 occurring or have recently occurred.
39
40 Coordination can occur at locations that reflect the affected level of concern. When burns
41 are located near Class I areas or non-attainment areas, coordination will be carried out at
42 a level that is appropriate. If burns are located adjacent to state/tribe boundaries,
43 coordination will occur appropriate to the smoke transport/emission path and quantity.
44
ESMP Policy Draft D, 7/1/02 II - D - 45
1 A common mode of coordination regardless of the complexity and magnitude of burning
2 would be information sharing via use of the web. Operationally, certain information
3 needs to be established and updated as needed. This would include:
4 • Burn information (size, location, ignition date, etc.)
5 • Names and locations of sensitive receptors and/or special protection zones;
6 sensitive receptors should include sensitive populations
7 • Locations of monitors (state, tribe, EPA or local)
8 • Database of known significant user of fire (name, phone number)
9 • Identification of airsheds or air administered units
10 • Possible identification of Clean Air Corridors
11 • Updateable database of non-attainment and maintenance areas for criteria
12 pollutants of concern
13 • Identification of the centralized burn authority that maintains oversight
14
15 A minimal level of coordination would include the use of websites to post burn activity.
16 This passive mode of coordination would be used regardless of the burn authorization
17 method that is in place in a particular geographic area. Land managers/owners and
18 regulators could use this information to encourage and promote voluntary coordination
19 among land managers/owners. Burn locations and weather conditions may be posted or
20 linked at a common webpage or series of webpages.
21
22 Source Sector Authority Coordination
23
24 A more advanced coordination concept is that of using burn managers or smoke
25 coordination centers to actively time burning to avoid cumulative smoke impacts from
26 burns within a source sector. In addition to creating awareness of other sectors' burning
27 via tracking information on the web, radio or phone communications would be used to
28 distribute that burning information to land managers/owners.
29
30 A step further in this process is active management of burning with coordination
31 occurring between burn managers of different source types. Considerations that would
32 be taken into account by the burn managers are parameters such as special weather
33 conditions needed for a particular burn, fire safety considerations, etc. These
34 considerations can be identified in the early periods of burn planning so that all parties
35 are aware of the rationale behind burn decisions.
36
37 Centralized Authority Coordination
38
39 A centralized coordination authority within a state/tribe provides for a greater level of
40 control of smoke production and reduction of impacts. In this scenario, potential
41 state/tribe-wide impacts may be better managed and problems avoided than is the case
42 with more fragmented coordination points. Central authorities for each source type
43 would coordinate activities or one central authority would coordinate activities across all
44 source types. In most cases this coordination would occur through a statewide
45 coordination center that has access to information from all burning sources. Such a
46 coordination center would also be more likely to have sophisticated meteorological, air
ESMP Policy Draft D, 7/1/02 II - D - 46
1 quality, modeling and fire behavior and effects expertise upon which decisions would be
2 made.
3
4 Regional (Multi-State/Tribe) Coordination
5
6 Burning that creates inter-jurisdictional impacts may require the establishment and use of
7 multi-state/tribal coordination information procedures. If states’/tribes’ Class I areas are
8 consistently and measurably being impacted by smoke from outside of their own
9 boundaries, then more information sharing may be needed on day-to-day burning
10 activities. State/tribe centralized coordination centers would share information and
11 resources to limit cumulative impacts from external sources as well as from those within
12 its own boundaries.
13
14 Each state’s/tribe’s central coordination center would prioritize burns in areas that would
15 be most likely to create cross-jurisdictional impacts. On a regional basis, acres or
16 emissions may be limited by each state’s/tribe’s burn authority to minimize air quality
17 impacts in neighboring areas. Regional meteorological and air quality information would
18 be shared by coordination centers, with the result being regional approval and real-time
19 tracking of burns and their smoke impacts.
20
21 A segment of fires that are considered to be natural under the WRAP Fire Categorization
22 Policy may best be suited for regional coordination opportunities. Such fires are more
23 likely to be of longer duration and have the greater potential for generating regional haze.
24 Coordination in this case may range from monitoring smoke from such fires and
25 reporting impacts to nearby states/tribes, to limiting other burning until the smoke from
26 the natural fires has abated.
27
28 Methods for this inter-jurisdiction and regional coordination will need to be developed.
29 The development process should be a collaborative one, involving state, tribal, local and
30 federal agencies, and private parties. Entities to be involved in this process could include
31 WRAP, the Western States Air Resources Council (WESTAR), the National Tribal
32 Environmental Council (NTEC), the Wildfire Leadership Council, the Western States
33 Fire Managers, and the AAQTF.
34
35
ESMP Policy Draft D, 7/1/02 II - D - 47
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ESMP Policy Draft D, 7/1/02 II - D - 48
Initiatives Oversight Committee Meeting
Denver, Colorado: July 11, 2002
Review ESMP Document Draft Prior to Submission to the
Western Regional Air Partnership
Chronological Record II - 395
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Chronological Record II - 396
Initiatives Oversight Committee Meeting
Denver, Colorado
July 11, 2002
Meeting Record
Participants: Rick Sprott, UT Division of Air Quality, IOC Co-Chair; Julie Simpson, Nez
Perce Tribe, IOC Co-Chair; Jeff Burkes, UT EC; Vickie Patton, Environmental Defense;
Wayne Liepold, Phelps-Dodge; Steve Frey, EPA Region 8; Annette Liebe, OR DEQ,
Dan Olsen, WY DEQ; Dick Hayslip, Salt River Project; Doug Lempke, CO Air Board;
Colleen Cripps, NV DEQ; Bruce Polkowski, NPS; Greg Green, EPA; Ron King, AK
DEQ; Dan Johnson, WESTAR; Don Arkell, WESTAR; Bob Gruenig, NTEC; John
Bunyak, NPS; Colleen Delany, UT DAQ; Dan Clark, WY DEQ; Patrick Cummins,
WGA; Bill Grantham, NTEC; Rich Halvey, WGA; Pete Lahm, USFS, FEJF Chair; Lee
Alter, WGA, IOC Staff Support; Tom Moore, WRAP TOC Staff Support; Rebecca
Reynolds, FEJF-ESMP TT Facilitator.
ESMP Policy Review & Discussion
Session Summary
Pete Lahm presented the ESMP Policy.
Rick Sprott commended the Policy for its flexibility, its sophistication in addressing the
variety of complex and sensitive issues involved, and for giving states/tribes a useful
resource for their SIP/TIP development. He stressed that reading the Policy in its entirety
is necessary for a thorough understanding of its intent and scope.
The IOC concurred and recognized the outstanding work of the FEJF and the ESMP TT
in the development of such an excellent document.
Doug Lempke noted that the document being a “policy” is a big deal, an important step,
and will have major implications for SIP development. He wanted to make sure that he
understood the Policy and its implications well before voting on it, and felt he could not
do so at this point. (The Policy draft was received by the IOC just a few days prior to the
meeting, preventing some of the members from reviewing the document thoroughly.)
Others agreed that the lead-time was too short to give the document the review necessary
for voting. This led to a discussion of the timeframe for the ESMP Policy submittal to the
WRAP. Rick Sprott and Pat Cummins said that the ESMP Policy would not go before
the WRAP at its next meeting, and Pete Lahm indicated that he and the FEJF had been
operating on the timeframe that it would. There was concern expressed over waiting until
the WRAP November meeting as perhaps too late for some of the 309 states (AZ in
particular). Several proposals were discussed to split the approval process between the
two WRAP meetings (the IOC was comfortable with the Policy Statements and
uncomfortable with certain passages in the supporting text); July would address the
Policy Statements and November would address the supporting language. This approach
Chronological Record II - 397
was not approved. After further discussion, it was decided that the ESMP document
would go before the WRAP at its next meeting, with the IOC expressing that it generally
represented the direction that would be taken on the ESMP Policy. Full official approval
would then be done at the November WRAP meeting.
The IOC’s role in the ESMP Policy review/approval was also discussed. Rick Sprott
committed to reviewing the WRAP Bylaws for further guidance. The IOC members
were given the charge to more thoroughly review the document and give any necessary
comment to Pete to carry to the FEJF. The FEJF would then determine what revisions
would be needed and then re-submit the ESMP document to the IOC for its next meeting.
Further, it was decided that Pete would present to the WRAP, at its next meeting, the five
items specific to fire in Section 309 of the RHR followed by a presentation of the
products the FEJF has developed to address each (the ESMP Policy would be one of
these). When the ESMP Policy is presented, Pete will discuss the higher level issues (e.g.,
equity, flexibility, consistency with the Rule and other documents, etc.) that the document
addresses.
Some specific concerns raised about the content of the ESMP Policy included:
Exemption for “de minimus” sources (Doug L.)
Discomfort with the one-deciview example in the Impact Based Options (Annette L.)
Concern over the definition of “Alternatives to Burning” as not broad enough (Vickie P.)
To address these and any other comments from IOC members, Pete will receive IOC
comments and take them back to the FEJF. IOC members will get comments to Pete as
soon as possible so that necessary revisions can be made prior to the next IOC meeting.
Chronological Record II - 398
1
2
3
4
5
6
7
8
9 WRAP Policy
10
11 Enhanced Smoke Management Programs
12 for Visibility
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36 Prepared by the Fire Emissions Joint Forum
37 for the Initiatives Oversight Committee
38 and the Technical Oversight Committee
39 July 8, 2002
ESMP Policy Draft E, 7/8/02 II - E - 1
1 WRAP Policy
2
3 Enhanced Smoke Management Programs
4 for Visibility
5
6 Executive Summary
7
8 The Western Regional Air Partnership (WRAP) is charged with developing technical and
9 policy tools to assist states (or the delegated regulatory authority) and tribes with
10 implementing the Regional Haze Rule (Rule).
11
12 The WRAP Policy on Enhanced Smoke Management Programs for Visibility (WRAP
13 ESMP Policy) has been developed over an eleven-month period through a stakeholder-
14 based consensus process to assist the WRAP region states and tribes in addressing
15 emissions from fire sources. In this Policy, the WRAP seeks to provide a consistent
16 framework that states and tribes can use to efficiently develop their individual
17 implementation plans. The WRAP recognizes states’ and tribes’ authority and
18 responsibility to develop, adopt and implement their regional haze implementation plans,
19 and recognizes the Rule as the principal document on which states and tribes should rely.
20
21 The Rule requires states to develop implementation plans
22 (SIPs) for addressing regional haze in the Nation’s 156
23 mandatory Class I areas.1 Additionally, the Rule requires effective
24 management of fire sources. The Rule provides two pathways for western states to follow
25 as they implement the requirements of the Rule: 1) develop their regional haze
26 implementation plans per the nationally applicable provisions of Section 308, or 2)
27 Transport Region states may choose to incorporate the Grand Canyon Visibility
28 Transport Commission (GCVTC) Recommendations into their regional haze
29 implementation plans under Section 309 of the Rule.
30
31 Enhanced smoke management programs are specifically required in Section 309 of the
32 Rule. However, if a state, under Section 308, has determined that fire emissions are
33 contributing to visibility impairment and that smoke needs to be addressed in its SIP, then
34 an enhanced smoke management program is a viable tool to accomplish this goal.
35 Therefore, the WRAP is advancing the WRAP ESMP Policy for states under both
36 Section 308 and 309 to meet the requirements of the Rule.
37
38 Tribes are not subject to the same requirements of the Rule as states, but tribes wishing to
39 assume the regional haze requirements outlined in the Rule may, according to the Tribal
40 Authority Rule (TAR), seek approval under 40 CFR 49 to be “treated as States.” The
41 intent of this Policy is to assist both states and tribes with the development of their
1
The Rule is only applicable to mandatory Class I areas (see Appendix A & Appendix B for additional
information on mandatory Class I areas). States/tribes in the WRAP region may utilize the WRAP ESMP
Policy to protect visibility in non-mandatory Class I areas.
ESMP Policy Draft E, 7/8/02 II - E - 2
1 regional haze implementation plans (SIPs/TIPs), and therefore, tribes are included in all
2 references to states, except where specific requirements and/or deadlines of the Rule are
3 cited.2
4
5 It is the position of the WRAP ESMP Policy that there are nine elements of an enhanced
6 smoke management program that are necessary to meet the requirements of the Rule. The
7 WRAP ESMP Policy defines the enhanced smoke management program as smoke
8 management efforts that specifically address visibility. According to the Rule, enhanced
9 smoke management programs are to be included in implementation plans based on the
10 criteria of efficiency, economics, law, emissions reduction opportunities, land
11 management objectives, and reduction of visibility impacts.
12
13 Smoke management efforts/programs currently in place (sometimes referred to as “basic
14 smoke management programs”) may not specifically address visibility effects in
15 mandatory Class I areas. The WRAP ESMP Policy explicitly addresses visibility effects
16 from fire that contribute to visibility impairment in mandatory Class I areas. Fortunately,
17 smoke management efforts/programs, regardless of the purpose (e.g., visibility
18 protection, avoidance of National Ambient Air Quality Standards (NAAQS) violations,
19 or prevention of nuisance smoke impacts), have many common elements. It is anticipated
20 that the enhanced smoke management program elements outlined here will integrate well
21 with current and future smoke management efforts/programs.
22
23 The WRAP ESMP Policy document is comprised of four major sections. Section 1 is the
24 WRAP ESMP Policy statements. Section 2 provides overall background for the WRAP
25 ESMP Policy, including a discussion of the regulatory environment, the current context
26 of smoke management in the WRAP region, and details of the Rule that are germane to
27 the WRAP ESMP Policy. Section 3 addresses the development and application of
28 enhanced smoke management programs, including a description of the nine enhanced
29 smoke management program elements, the rationale for these elements, and an
30 explanation of the Rule’s enhanced smoke management program criteria. Finally, the
31 Appendices include (A) a glossary of terms, (B) a related documents listing, and (C)
32 specific examples for states/tribes on the implementation of the nine enhanced smoke
33 management program elements.
34
35 The WRAP ESMP Policy provides states and tribes an equitable and practical method for
36 implementing an enhanced smoke management program. The WRAP ESMP Policy is
37 intended to assist states and tribes in their efforts to demonstrate reasonable further
38 progress toward the natural visibility goal. The Fire Emissions Joint Forum (FEJF) of the
39 WRAP is developing additional policy and technical tools that will support the WRAP
40 ESMP Policy and its implementation, such as an annual emissions goal policy, guidance
41 on assessing the availability and feasibility of alternatives to burning, and a policy on
42 tracking fire emissions.
2
Further information on tribes and Tribal Implementation Plans (TIPs) is provided in Section 2.6.4 of this
document.
ESMP Policy Draft E, 7/8/02 II - E - 3
1 WRAP Policy
2
3 Enhanced Smoke Management Programs
4 for Visibility
5
6
7 TABLE OF CONTENTS
8
9 Executive Summary i
10
11 1. The WRAP Policy on Enhanced Smoke Management Programs
12 for Visibility 1
13
14 2. Background 2
15
16 2.1 Introduction 2
17 2.2 Purpose 3
18 2.3 Scope and Applicability 4
19 2.4 Regulatory Environment 5
20 2.5 Context 7
21 2.5.1 Current Smoke Management Guidance 7
22 2.5.2 Current Smoke Management Efforts 8
23 2.6 The Regional Haze Rule Requirements to Address Fire 9
24 2.6.1 Emissions Tracking 10
25 2.6.2 Section 309 10
26 2.6.3 Section 308 11
27 2.6.4 Regional Haze Implementation Plan (SIP/TIP) Process 11
28
29 3. Development and Application of
30 Enhanced Smoke Management Programs 13
31
32 3.1 Responsibilities Under an Enhanced Smoke Management Program 13
33 3.2 Elements Description 14
34 3.3 Elements Rationale 16
35 3.4 Criteria Description 17
36 3.5 Application of Enhanced Smoke Management Programs 18
37 3.5.1 Source Sector Option 18
38 3.5.2 Situational Option 19
39 3.5.3 Impact Based Option 20
40 3.6 The Collaborative Process 21
41
42
43
ESMP Policy Draft E, 7/8/02 II - E - 4
1 TABLE OF CONTENTS
2
3
4 4. Appendices 22
5
6 Appendix A. Glossary