Co-Chairs
Michael O. Leavitt
Governor
State of Utah
Cyrus J. Chino
Governor
Pueblo of Acoma
Supporting Documentation
for the
Recommended Policy for
Categorizing Fire Emissions
OCTOBER 31, 2001
WRAP is Jointly Administered by:
Western Governors’ Association
National Tribal Environmental Council
Supporting Documentation
for the
Recommended Policy for
Categorizing Fire Emissions
Report authored and compiled by the following members of the
Natural Background Task Team of the Fire Emissions Joint Forum.
Darla Potter
Carl Gossard
Peter Lahm
NBTT Co-Chair
WDEQ-AQD
NBTT Co-Chair
USDI-BLM
FEJF Co-Chair
USDA-FS
Mark Fitch
Dave Jones
Shelley Nolde
AZDEQ
San Joaquin Valley APCD
USDA-FS
Jim Russell
David Sandberg
Mike Ziolko
USDA-FS & USDI-BLM
USDA-FS
OR DOF
Rebecca Reynolds
Rebecca Reynolds Consulting Inc.
[Ed note: This document has been formatted
for 2-sided printing (i.e., duplex printing).]
Acknowledgements
Western Regional Air Partnership
Northern Air Managers Committee
Rose Lee, Co-Chair
Dan Olson, Co-Chair
Bureau of Land Management
Western Governors’ Association
National Tribal Environmental Council
Policy Maker/Opinion Leader Workshop Speakers:
Dianne R. Nielson, Executive Director, Utah Department of Environmental Quality
Richard Tobin, Deputy Director, Arizona Department of Environmental Quality
Senior Staff Workshop Presenters:
James K. Agee, Ph.D., U of WA
Richard M. Hayslip, Salt River Project
Patrick Cummins, WGA
William C. Malm, Ph.D., NPS/CIRA
Dennis Haddow, USDA FS
Philip N. Omi, Ph.D., CSU
Robert Quinn, Ph.D., Eastern WA U
Senior Staff Workshop Position Paper Authors:
Manuel Cunha, Jr., Nisei Farmers League
Kenneth E. Evans, Phelps Dodge Corporation
Brian Finneran, OR Dept. of Env. Quality
Grand Canyon Trust
Intertribal Timber Council
Scott Kuehn, Plum Creek Timber
Bill Leenhouts, U.S. Fish and Wildlife Service
C.V. Mathai, Pinnacle West/AZ Public Service
Greg Schaefer, Arch Coal Company
USDA Forest Service
Mark Wagoner, Alfalfa Seed Farmer
Robert Wilkosz, ID Dept. of Env. Quality
i
Acknowledgements
Senior Staff Workshop Volunteer Facilitators:
Tamara Blett, NPS
Susan Ford, USFS
Karen Hamilton, EPA
Jane Leche, USFS
Marion Malinowski, BLM
Ellenjean Morris, CDPHE
Doris Sanders, EPA
Lisa Silva, CDPHE
Dave Steinke, USFS
Dana Stotsky, EPA
Western Governors’ Association Staff:
Patrick Cummins, Air Quality Program Manager, WRAP Co-Project Manager
Richard Halvey, Project Manager
Deborah Kinsley, Administrative Secretary
Toni McCammon, Office Manager/Executive Secretary
National Tribal Environmental Council Staff:
Bill Grantham, Air Program Coordinator, WRAP Co-Project Manager
FEJF Website Host:
Air Sciences, Inc.
Policy Maker/Opinion Leader Workshop Registration and Social Sponsor:
Pinnacle West Capital Corporation
Senior Staff Workshop Q&A Session and Hospitality Suite Sponsor:
Air Sciences, Inc.
Policy Maker/Opinion Leader Workshop Participants
Senior Staff Workshop Participants
ii
Table of Contents
Page
Recommended Policy Development Process
Introduction
1
Background
1
FEJF-NBTT Work Process
3
Fire’s Contribution to Natural Visibility Workshops
Senior Staff Workshop
Draft Policy for Categorizing Fire Emissions
Policy Maker/Opinion Leader Workshop
4
5
5
6
Further Policy Development
WRAP Meeting
IOC Meeting
FEJF Meeting
AAQTF Meeting
7
7
8
8
8
Recommended Policy for Categorizing Fire Emissions
9
Recommended Policy Approval Process
NBTT Submission to FEJF
FEJF Submission to IOC and TOC
IOC Submission to WRAP
9
9
10
11
Appendix I.
Senior Staff Workshop Summary
a. Executive Summary
b. Breakout Group Notes & Decision Tree Representations
c. Agenda & Presenters’ Information
d. Group Classification Exercise Results
e. Decision Tree Materials
f. Presenter Materials
g. Stakeholder Position Papers
h. Participant Information
I-1
I-5
I-43
I-49
I-53
I-69
I-113
I-139
Appendix II.
Policy Maker/Opinion Leader Workshop Summary
a. Executive Summary
b. Discussion Notes & Evaluation Forms – Quest. 6 Response Compilation
c. Agenda
d. Draft Policy for Categorizing Fire Emissions
e. Decision Tree Change Guide
f. Participant Information
II-1
II-3
II-21
II-23
II-57
II-63
iii
Table of Contents
Appendix III.
Further Policy Development
a. WRAP May 23-24, 2001 Meeting
i. NBTT Briefing Summary
ii. Summary Paper
III-1
III-3
III-13
b. FEJF July 11-12, 2001 Meeting
i. NBTT Briefing Paper
ii. Recommended Policy Content and Structure Overview
iii. FEJF Recorded Comments & Discussion
III-23
III-25
III-27
III-31
c. AAQTF July 18-19, 2001 Meeting
i. Briefing Paper – Recommended Policy for Categorizing
Fire Emissions
III-37
III-39
Appendix IV.
Recommended Policy Approval Process
a. NBTT Submission to FEJF – August 14, 2001
i. Recommended Policy for Categorizing Fire Emissions,
Draft August 14, 2001
ii. Comments Received on Recommended Policy
iii. August 30, 2001 FEJF Conference Call Notes
IV-1
IV-3
IV-35
IV-45
b. FEJF Submission to IOC/TOC – August 30, 2001
i. Recommended Policy for Categorizing Fire Emissions,
August 30, 2001
IV-55
IV-57
c. IOC Submission to WRAP – October 31, 2001
i. IOC Transmittal Letter to the WRAP
ii. Recommended Policy for Categorizing Fire Emissions,
October 25, 2001
IV-89
IV-91
IV-93
Appendix V.
Background Materials
a. FEJF Storyline
b. Facts about WRAP
c. WRAP/FEJF Organizational Charts
d. FEJF & NBTT Rosters
e. Website References
iv
V-1
V-9
V-13
V-15
V-17
RECOMMENDED POLICY DEVELOPMENT PROCESS
INTRODUCTION
This document represents a compendium of all supporting material prepared by the NBTT
throughout the development of the Recommended Policy for Categorizing Fire Emissions. The
Recommended Policy for Categorizing Fire Emissions has been developed over an 18-month
period by the Natural Background Task Team (NBTT) of the Fire Emissions Joint Forum
(FEJF). The NBTT is a group made up of state, tribal, and federal agency representatives as well
as those from industry, agriculture, academia, and environmental organizations. During this
process, the NBTT solicited stakeholder and public input regarding both technical and policy
issues. This compendium of supporting documentation was prepared by the NBTT to provide a
record of the process used to develop the Recommended Policy for Categorizing Fire Emissions.
The Recommended Policy for Categorizing Fire Emissions, October 25, 2001 submitted to the
WRAP for review and approval at its November 14-15, 2001 meeting is contained in Appendix
IV. Upon WRAP approval, the Recommended Policy will become a product of the WRAP,
published as the Policy for Categorizing Fire Emissions and posted on the WRAP website at
www.wrapair.org.
BACKGROUND
The Regional Haze Rule (Rule) outlines the requirements for addressing regional haze in Federal
Class I park and wilderness areas, a critical element of which is the establishment of natural
background condition values. When established, these values will provide the basis by which a
state or tribe may demonstrate reasonable progress toward attaining the 2064 natural conditions
goal.
There are a number of sources that the Environmental Protection Agency (EPA) has identified as
potential contributors to natural background conditions, one of which is fire. The Regional Haze
Rule Preamble stipulates that fire of all kinds contributes to regional haze and that fire can have
both natural and human-caused sources. The Preamble further states that some fire that is human
ignited may be included in a state’s or tribe’s determination of natural background conditions.
“EPA believes that States [and Tribes] must take into account the degree to which
fire emissions cause or contribute to ‘manmade’ visibility impairment and its
contribution to natural background conditions.”1
To address the implementation of specific sections of the Rule, the Western Regional Air
Partnership (WRAP) has established several Committees and Forums. (See Appendix V for
Facts about WRAP and a WRAP Organizational Chart.) The Ambient Air Monitoring &
Reporting Forum (AMRF) is working to develop guidance on the determination of natural
background, taking into consideration emissions that can result in a natural reduction of
1 64 FR 35735.
1
visibility. The Fire Emissions Joint Forum (FEJF) is addressing both policy and technical issues
concerning smoke effects that are caused by wildland and agricultural fire on public, tribal and
private lands. . (See Appendix V for the FEJF Storyline, FEJF Organizational Chart, and FEJF
Roster.)
The AMRF will analyze the Interagency Monitoring of Protected Visual Environments
(IMPROVE) visibility monitoring data to establish a baseline, current conditions, and track
reasonable progress toward the 2064 natural conditions goal, as required in the Rule. Organic
carbon aerosol, as monitored by IMPROVE, is a significant contributor to regional haze in the
WRAP region. The current monitoring technology is unable to identify the source of organic
carbon aerosol monitored at Federal Class I areas, of which fire has been acknowledged as a
major source. As technology and science develops, with regard to the ability to differentiate fire
impacts as compared to other sources for the purposes of tracking reasonable progress toward the
2064 natural conditions goal, the needs and methods of tracking are anticipated to change.
Due to the limitations of the current monitoring technology, the AMRF requested that the FEJF
work on determining the classification of fire emissions as either “natural” or “anthropogenic”.
This classification will be an important component of fire’s inclusion in natural background
condition values and ultimately, the tracking of reasonable progress. The Natural Background
Task Team (NBTT) was created by the FEJF to assist in this effort.
At the May and June 2000 NBTT meetings, the NBTT evaluated the request from the AMRF as
well as the broader topic of fire’s contribution to natural background visibility conditions. During
that evaluation, the NBTT determined that three processes must be developed for the states and
tribes to meet the requirements of the Regional Haze Rule as it applies to fire emissions.
1.
Develop a methodology to categorize fire into “anthropogenic” and “natural”
source classifications.
2.
Develop approaches for estimating the contribution of fire emissions to natural
background visibility conditions.
3.
Establish methods for tracking and apportioning fire emissions into the
classifications above.
The NBTT recognized that, although all three processes are interrelated, categorizing fire is the
first step, which will then enable the second and third processes to be developed. Therefore, for
the past 18-month period the NBTT has focused its efforts on developing a methodology to
categorize fire, leaving the development of the remaining two processes to the FEJF.
2
FEJF-NBTT WORK PROCESS
Initial discussions on fire’s contribution to natural visibility took place at three FEJF meetings2
among the original participants of the NBTT3, who were mostly representatives from Federal
Land Management agencies. In May of 2000, a core stakeholder group4 was established for the
NBTT by the FEJF to achieve a balance of stakeholder representation and input. By mid-2000, a
growing number of people were becoming involved in the NBTT (see NBTT Roster in Appendix
V), and in June of 2000, a smaller representative group (the NBTT Management and Content
Team5) was created by the NBTT to lead the work for the Task Team.
Upon identifying the complexity of the Task Team’s objective, as well as recognizing the high
degree of diverging stakeholder sentiment, the decision was made to contract with a coordinator
and facilitator to focus the work of the NBTT. Rebecca Reynolds Consulting, Inc. began
working with the NBTT in June of 2000 and has continued to work with the NBTT on
conference calls, meetings, workshops, and written material through the publication of this
report.
From May of 2000 through September 2001, the NBTT was very active holding 18 meetings and
34 conference calls. Of the 18 meetings, six meetings were held for the full Task Team, six
meetings were held for the full Management and Content Team, and six meetings were held for
various subsets of the Management and Content Team. Of the 34 conference calls, 24 conference
calls were conducted among the full Management and Content Team and 10 conference calls
were conducted among the NBTT Co-Chairs. In addition, continuous conference calls were
conducted to coordinate with Rebecca Reynolds Consulting, Inc.
As a Task Team of the FEJF, it was pertinent that the NBTT interact on an ongoing basis with
the FEJF and non-FEJF members. This was achieved by conducting NBTT briefings at
numerous FEJF meetings.6 The purpose of the NBTT briefings was to submit progress reports as
well as work products to the FEJF and non-FEJF members for input and approval.
2 December 14-15, 1999 Spokane, WA; February 9-10, 2000 Phoenix, AZ; and April 18-19, 2000 Sacramento, CA.
3 Fred Greef, NBTT Co-Chair – WA DE; Carl Gossard, NBTT Co-Chair – BLM; Tim Sexton, NPS; Bill Leenhouts,
FWS; Jim Russell, USDA-FS & USDI-BLM; Sam Sandberg, USDA-FS; Dave Randall, Air Sciences, Inc.; Patti
Hirami, USDA-FS; Bob Raisch, MT DEQ; Amy Mignella, White Mountain Apache Tribe; Shelley Nolde, USDAFS; Mike Ziolko, OR DOF; and Peter Lahm, FEJF Co-Chair – USDA-FS.
4 Fred Greef, NBTT Co-Chair – WA DE; Carl Gossard, NBTT Co-Chair – BLM; Tim Sexton, NPS; Bill Leenhouts,
FWS; Jim Russell, USDA-FS & USDI-BLM; Mark Fitch, AZ DEQ; Darla Potter, WDEQ-AQD; Mike Ziolko, OR
DOF; Kevin McKernan, Hoopa Valley Tribe; Elvis Graves, USDA-NRCS; Ken Evans, Phelps Dodge Corp.; and
Bob Palzer, Sierra Club.
5 Darla Potter, NBTT Co-Chair – WDEQ-AQD; Carl Gossard, NBTT Co-Chair – BLM; Peter Lahm, FEJF CoChair – USDA-FS; Mark Fitch, AZ DEQ; Shelley Nolde, USDA-FS; Jim Russell, USDA-FS & USDI-BLM; Sam
Sandberg, USDA-FS; and Mike Ziolko, OR DOF. Dave Jones, San Joaquin Valley APCD, joined the NBTT
Management and Content Team in October of 2000.
6 June 27-28, 2000 Denver, CO; September 6-7, 2000 Boise, ID; December 6-7, 2000 Santa Fe, NM; February 2122, 2001 Las Vegas, NV; April 24-25, 2001 Portland, OR; July 11-12, 2001 Rapid City, SD; and September 27-28,
2001 Park City, UT.
3
In addition to the NBTT meetings and 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 NBTT. The Task Team web page, www.airsci.com/FEJF/Task_Team.htm, was maintained
with postings (e.g., meeting notes, conference call notes) to document the activity of the Natural
Background Task Team. A dedicated web page was also established for the posting of NBTT
workshop information and follow up information, www.airsci.com/FEJF/nbtt/NBwkshop.htm.
The hard costs associated with the development of the Recommended Policy for Categorizing
Fire Emissions have been estimated at $90,000, including contract coordination and facilitation,
workshops, meetings, mailings and travel. The hard costs were augmented by incalculable inkind support by those involved with the NBTT and the two workshops. Funding was provided by
the FEJF ($10,000) and the Northern Air Managers Committee of the WRAP ($50,000). In
addition, the Bureau of Land Management contributed $30,000 to support the contract
coordination and facilitation, which proved vital to the success of the development process.
FIRE’S CONTRIBUTION TO NATURAL VISIBILITY WORKSHOPS
Through the fall of 2000, the NBTT conducted a thorough discussion of the distinction between
“natural” and “anthropogenic” fire emissions. In the process, the Task Team determined that
broad input on these discussions would lead to a much stronger result. In planning the approach
to categorize fire emissions, the NBTT decided a two-workshop format would best enable the
Task Team to gain the necessary input surrounding both the technical and policy implications
involved. The first workshop would be geared to senior level staff able to review and give input
on the technical and policy aspects; the second workshop would be designed for policy maker
review and input. The use of workshops is consistent with the WRAP’s guidelines for Forums,
which states that Forums are expected to communicate with the general public and are
encouraged to hold public workshops as a tool to garner public input.
To solicit participants for the workshops, a placeholder/invitation was developed and distributed
on October 30, 2000 to 387 people that represented a wide stakeholder audience7. The
placeholder/invitation identified that workshop participants were needed to review and refine a
methodology to determine what smoke would be considered as part of natural visibility in
federally protected Class I parks and wilderness areas in the West.
To solicit additional workshop participants, a flyer was developed and distributed on December
11, 2000 to 120 targeted invitees that represented a broad stakeholder distribution, similar to that
for the distribution of the placeholder/invitation. The flyer identified that workshop participants
were still needed to review and refine a methodology to determine what smoke would be
considered as part of natural visibility in federally protected Class I parks and wilderness areas in
the West.
7 Federal, state, and tribal governments, industry, agriculture, environmental organizations, academic/research
entities, other WRAP Forums/Committees, and other Regional Planning Organizations.
4
Senior Staff Workshop
The Senior Staff Workshop on Fire’s Contribution to Natural Visibility (Senior Staff Workshop)
was held in Denver, Colorado on January 24-25, 2001 with the following objective:
To categorize fire emissions sources into two classifications, “natural” &
“anthropogenic”, and to assess the policy and technical implications. These
classifications will help define the natural visibility conditions in the Federal
Class I parks and wilderness areas in the West.
The Senior Staff Workshop involved 65 participants from the following stakeholder groups:
federal, tribal, state, and local governmental, regulatory and land management agencies; large
and small industries; agriculture, including Agricultural Air Quality Task Force (AAQTF)
representatives; forest products industry; members of WRAP; WRAP Initiative Oversight
Committee (IOC) and Technical Oversight Committee (TOC) members; members of non-WRAP
Regional Planning Organizations; environmental and public interest groups; and the academic
community. The Senior Staff Workshop was conducted by a ten-person NBTT Resource Team,
ten volunteer facilitators, and two contracted coordination and facilitation persons. (See
Appendix I for the Senior Staff Workshop Participant Information.)
The Senior Staff Workshop utilized a proposed decision tree methodology to categorize potential
source emissions into either “natural” or “anthropogenic” classifications. After a half-day of
background discussion to establish a common level of understanding, the participants met in
eight small workgroups for one day. (See Appendix I for the Senior Staff Workshop Agenda &
Presenters’ Information, Presenter Materials, Stakeholder Position Papers, and Group
Classification Exercise Results.)
The small workgroups utilized a decision tree approach with a series of assumptions provided by
the NBTT (see Appendix I for the Senior Staff Workshop Decision Tree Materials) and were
asked to review the decision tree and assumptions. In addition, the small workgroups were asked
to attempt to reach consensus on what criteria would be used to classify all wildland fires,
agricultural land burns, and Native American cultural burns.
During the evaluation of the Senior Staff Workshop results, it became apparent that there was no
consensus between the workgroups. However, a number of workgroups converged on similar
approaches and decision-making criteria. (See Appendix I for the Senior Staff Workshop
Executive Summary and Breakout Group Notes & Decision Tree Representations.) The
convergence of thought at the Senior Staff Workshop made possible, and was the basis for, the
NBTT’s development of a comprehensive policy approach for categorizing fire emissions.
Draft Policy for Categorizing Fire Emissions
The Draft Policy for Categorizing Fire Emissions, April 5, 2001 represented the convergence of
thought at the Senior Staff Workshop. The Draft Policy was not representative of any one
workgroup or workshop participant in particular. A copy of the Draft Policy for Categorizing
Fire Emissions is included in Appendix II.
5
The Draft Policy clarified the relationship between what would be defined as a “natural” fire
source and what would be defined as an “anthropogenic” fire source, thereby addressing the
complex relationship EPA acknowledges in the Preamble to the Rule. By clarifying the
categorization of fire emission sources, the Draft Policy provided a basis for estimating the
contribution of future fire emissions to natural background visibility conditions. The Draft Policy
also provided an approach toward management of “natural” and “anthropogenic” fire emissions,
which would result in an alignment of Sections 308 and 309 of the Rule, leading to a reasonable
progress demonstration for fire sources.
The Draft Policy only addressed the effects of fire emissions in terms of natural background
visibility and the requirements of the Rule. All kinds of fire (e.g., wildfire, prescribed fire,
agricultural burns, Native American cultural burns) contribute to regional haze. The Draft
Policy applied to both wildland and agricultural lands regardless of ownership, cause of ignition
or purpose of the fire.
The Draft Policy was comprised of two key definitions and ten Policy Statements with
supporting documentation. The supporting documentation included background information and
annotated sections to provide additional detail regarding each of the ten Policy Statements. The
annotated sections were separated into the following four topic areas: Discussion, Senior Staff
Workshop Results, Magnitude, and Linkage. The Draft Policy was prepared by the NBTT to be
an equitable and livable policy that could be implemented in the WRAP region. The Draft Policy
for Categorizing Fire Emissions was the basis of the discussion at the Policy Maker/Opinion
Leader Workshop on Fire’s Contribution to Natural Visibility.
A guide to the changes made to the original Decision Tree was finalized by the NBTT after the
Policy Maker/Opinion Leader Workshop. The Fire Emission Source Categorization Decision
Tree Change Guide is included in Appendix II.
Policy Maker/Opinion Leader Workshop
The Fire’s Contribution to Natural Visibility -- Policy Maker/Opinion Leader Workshop (Policy
Maker Workshop) was designed as a follow-up workshop to the Senior Staff Workshop. The
Policy Maker Workshop was held in Tempe, Arizona on May 2, 2001. (See Appendix II for the
Policy Maker Workshop Agenda.)
The objective of the Policy Maker Workshop was to build upon the outcomes and information
gained at the Senior Staff Workshop, toward the development of a Draft Policy for Categorizing
Fire Emissions that ultimately would be recommended through the FEJF to the WRAP. (See
Appendix II for the Draft Policy for Categorizing Fire Emissions.) It was the expectation of the
NBTT that the Policy Maker participants would discuss their stakeholder viewpoint of the Draft
Policy developed by the NBTT from the Senior Staff Workshop and move toward consensus,
making modifications that would result in a draft Recommended Policy.
6
The Policy Maker Workshop was a one-day facilitated and moderated meeting. Invitees to the
Workshop were chosen to participate as either a Policy Maker or as a Concerned Stakeholder.
The purpose of designating two groups of participants was to focus the Workshop around a
balanced Policy Maker core group of 23 participants for the main discussion. This core group
was enhanced by the input of 31 Concerned Stakeholder participants. The participants formed a
large and diverse stakeholder base, ranging from governmental and land management agencies to
the agricultural community, including a number of WRAP members. (See Appendix II for the
Policy Maker Workshop Participant Information.)
During the Workshop, valuable discussion took place among the participants regarding the
components of the Draft Policy, stakeholder viewpoints, and Draft Policy implications, resulting
in specific feedback for Draft Policy revisions. From the discussion, the Policy Maker Workshop
participants arrived at general assent on some changes to the Draft Policy and convergence on
certain key issues that would change the format of what was originally developed by the NBTT.
The majority of suggested changes to the Draft Policy concerned the supporting and explanatory
language in the annotated sections of the Draft Policy. The Workshop participants also came to
resolution on some Draft Policy Statements, endorsing removal and/or modification, while
several Draft Policy Statements were approved as originally written. (See Appendix II for the
Policy Maker Workshop Executive Summary, Discussion Notes, and Evaluation Forms,
Question 6 Response Compilation.)
FURTHER POLICY DEVELOPMENT
Additional input to the development of a draft Recommended Policy was obtained by the NBTT
beyond the two Fire’s Contribution to Natural Visibility workshops.
WRAP Meeting
Peter Lahm, FEJF Co-Chair, presented a FEJF-NBTT work summary at the May 24, 2001
WRAP meeting. The work summary was designed to allow the meeting participants to follow
the progression of the work accomplished to date, as well as the NBTT and FEJF decisions. The
work summary was comprised of the following elements: 1) NBTT Task: Develop a
Categorization Methodology for Fire, 2) Senior Staff Workshop, 3) Draft Policy for
Categorizing Fire Emissions, 4) Policy Maker Workshop, and 5) Post Policy Maker Workshop.
During the presentation of the Post Policy Maker Workshop portion of the work summary,
WRAP meeting attendees were asked for their feedback on the initial post Policy Maker
Workshop findings and guiding principles used by the NBTT for the development of the Draft
Policy. The feedback obtained at the WRAP meeting was in support of the NBTT’s direction and
approach to the development of a draft Recommended Policy. (See Appendix III for the WRAP
Briefing Summary and Summary Paper.)
7
IOC Meeting
Peter Lahm, FEJF Co-Chair, presented a FEJF-NBTT briefing at the June 19, 2001 Initiative
Oversight Committee (IOC) meeting. The briefing was similar to the work summary presented to
the WRAP as it was designed to allow the meeting participants to follow the progression of the
work accomplished to date as well as the NBTT and FEJF decisions.
The June 19th briefing was viewed as an initial step in preparing the IOC for their consideration
of the Recommended Policy for Categorizing Fire Emissions at their September 2001 meeting. A
portion of the briefing discussed a contingency should consensus approval not be reached by the
FEJF on the draft Recommended Policy. The IOC raised concern that there could be potential
policy conflicts with existing or soon to be developed EPA guidance, such as the Natural Events
Policy, and felt that these guidance documents should be taken into consideration by the NBTT.
FEJF Meeting
The NBTT presented a briefing to the FEJF at the July 11-12, 2001 meeting in Rapid City, South
Dakota with the following objective.
To clarify the newly revised Draft Policy for FEJF members, and to gain their
input toward finalization of the Recommended Policy for Categorizing Fire
Emissions for the WRAP region.
The briefing consisted of a work summary that detailed the progression of the work
accomplished to date as well as the post Policy Maker Workshop findings and WRAP discussion
points and feedback. In addition, the briefing detailed the NBTT’s plan for the finalization of the
draft Recommended Policy, and was comprised of the following elements: 1) Policy Statements,
2) Structure & Guiding Principles, and 3) Changes for Finalization of the Draft Recommended
Policy. (See Appendix III for the NBTT Briefing Paper and Recommended Policy Content and
Structure Overview.)
FEJF and non-FEJF members commented on and discussed the NBTT’s plan for the finalization
of the draft Recommended Policy. The NBTT Management and Content Team made changes as
a result of input from the meeting participants when the draft Recommended Policy was
finalized. (See Appendix III for the FEJF Recorded Comments & Discussion.)
AAQTF Meeting
At the May 24, 2001 WRAP meeting, the WRAP members suggested that further agricultural
community outreach would benefit the draft Recommended Policy. Toward this end, Peter Lahm,
FEJF Co-Chair, presented a WRAP-FEJF update at the July 19, 2001 Agricultural Air Quality
Task Force (AAQTF) meeting. The presentation detailed the activities of the FEJF as well as the
draft Recommended Policy being developed by the NBTT. (See Appendix III for the Briefing
Paper – Recommended Policy for Categorizing Fire Emissions.)
8
The AAQTF did not comment on the draft Recommended Policy due to larger concerns
regarding all WRAP activities related to agricultural air quality (e.g., dust, fire). These concerns
were relayed to persons associated with the appropriate Forums or Committees within the
WRAP.
RECOMMENDED POLICY FOR CATEGORIZING FIRE EMISSIONS
The Recommended Policy for Categorizing Fire Emissions, Draft August 14, 2001 represents the
input obtained from the two workshops, WRAP, IOC, TOC, AAQTF, NBTT and FEJF. A copy
of the Recommended Policy for Categorizing Fire Emissions, Draft August 14, 2001 is included
in Appendix IV.
The Recommended Policy for Categorizing Fire Emissions will aid states and tribes in
determining which fire emissions will be considered as part of the natural background conditions
in Federal Class I areas. The remaining fire emissions will be considered “anthropogenic” and, as
such, subject to reasonable progress requirements of the Regional Haze Rule. The Recommended
Policy clarifies the relationship between what would be defined as a “natural” fire emissions
source and what would be defined as an “anthropogenic” fire emissions source, thereby
addressing the complex relationship EPA acknowledges in the Preamble to the Rule.
The Recommended Policy for Categorizing Fire Emissions is comprised of two main sections:
Classification Program Management and Classification Criteria. The Classification Criteria
section of the Policy determines the “natural” and “anthropogenic” sources of fire that contribute
to regional haze, as stated in the Preamble to the Rule. The Program Management section
expresses the prerequisites that enable classification to be effective and equitable. Although the
Program Management section addresses prerequisites that need to exist, it does not describe how
they will be brought about. This work is currently underway in the FEJF as well as in other
WRAP Forums.
RECOMMENDED POLICY APPROVAL PROCESS
The FEJF is organized into task teams to foster stakeholder participation and develop consensusbased work products that address key areas related to fire and air quality. As a task team may be
comprised of Forum and non-Forum members, task team work-products are to be submitted to
the FEJF for review and consensus approval prior to review by both the TOC and IOC and
finally by the WRAP.
NBTT Submission to FEJF
As the NBTT is a task team of the FEJF, the NBTT submitted the Recommended Policy for
Categorizing Fire Emissions, Draft, August 14, 2001 to the FEJF for formal review. (See
Appendix IV for the Recommended Policy for Categorizing Fire Emissions, Draft, August 14,
2001.) On August 14, 2001 the Recommended Policy was distributed via e-mail to the FEJF
members, FEJF liaisons to the IOC and TOC, Co-Chairs of the IOC and TOC, and WGA and
NTEC Project Managers. In addition, the Recommended Policy was posted on the FEJF website
on August 17, 2001. The distribution of the Recommended Policy included a request for
9
comments from the FEJF members as well as non-Forum members. Comments were received
from four FEJF members and four non-FEJF members. (See Appendix IV for Comments
Received on Recommended Policy for Categorizing Fire Emissions.)
Under the WRAP’s guidelines for Forums, it is stated that Forums are to conduct their business
on a consensus basis. Consensus is identified, by the WRAP, as having the following parameters:
• Consensus is agreement.
• Consensus is selection of an option that everyone can live with.
• Consensus may not result in the selection of anyone's first choice, but everyone is willing
to support the choice.
• Consensus is not a majority vote.
In keeping with the WRAP’s guidelines for Forums, a conference call for FEJF members was
conducted on August 30, 2001 to discuss and come to consensus on the Recommended Policy.
Conference call participants included nine FEJF members, one FEJF Member Alternate, and one
FEJF Non-Member. The FEJF Non-Member on the conference call was a NBTT Co-Chair who
participated to answer questions and provide clarification to the FEJF members during the
conference call. The conference call record is included in Appendix IV. It should be noted that
the e-mail distribution of the Recommended Policy to the FEJF members stated that not
participating on the August 30, 2001 conference call and/or not submitting comments would be
considered assent.
During the gauging of consensus at the beginning of the conference call, only one substantive
issue, regarding the annotation for escaped prescribed fire, was brought forward for resolution
before consensus approval could be achieved. Some commenters raised a few issues of
disagreement that they wanted officially noted, but that they did not consider as barriers to
consensus approval.
After resolution regarding the annotation for escaped prescribed fire, the Recommended Policy
for Categorizing Fire Emissions was approved by consensus, with the addition of an executive
summary. During the remainder of the conference call, editorial changes to the Recommended
Policy were discussed and either approved, disapproved, or noted for further consideration by the
NBTT.
Immediately following the FEJF conference call, the Recommended Policy was edited based on
the results of the conference call discussion to create the Recommended Policy for Categorizing
Fire Emissions, August 30, 2001. Due to time constraints the executive summary was not added
to the August 30 draft but was added to the version of the Recommended Policy prior to
submission to WRAP.
FEJF Submission to IOC and TOC
The Recommended Policy for Categorizing Fire Emissions, August 30, 2001 was submitted to
the IOC and TOC for review prior to the September 5 meeting scheduled to review and discuss
the Recommended Policy. (See Appendix IV for the Recommended Policy for Categorizing Fire
Emissions, August 30, 2001.)
10
As the FEJF is a joint Forum, both the TOC and IOC are charged with reviewing products and
recommendations from the FEJF and making recommendations to the WRAP. As the majority of
the Recommended Policy addresses policy rather than technical issues, the IOC took the lead in
the review and consideration of the Recommended Policy for passage to the WRAP. The TOC
formally discussed and deferred the lead on the Recommended Policy to the IOC and supported
the IOC’s conclusions.
A September 5, 2001 meeting of the IOC and TOC was conducted to review and discuss the
Recommended Policy for Categorizing Fire Emissions, August 30, 2001. On September 5, 2001,
Peter Lahm, FEJF Co-Chair, and Darla J. Potter, NBTT Co-Chair, presented the IOC and TOC
with a review and discussion of the following elements: 1) the process and public/stakeholder
outreach effort to reach the FEJF consensus approved Recommended Policy and 2) FEJF
consensus approved Recommended Policy.
Following the presentation, those present at the IOC and TOC meeting had extended discussions
on 13 topics regarding the Recommended Policy. Peter Lahm, Darla Potter, and Carl Gossard,
NBTT Co-Chair, contributed to the discussion by answering questions and providing further
explanation of the Recommended Policy. The discussions resulted in the identification of several
recommendations for the FEJF to consider during its current and ongoing work, which will
support the requirements expressed in the Recommended Policy.
At the conclusion of the meeting, the IOC expressed intent to formulate a transmittal letter to
accompany the Recommended Policy for Categorizing Fire Emissions when it goes before the
WRAP for approval in November 2001. A copy of the IOC Transmittal Letter to WRAP is
included in Appendix IV.
Some minor editorial changes were identified for correction during the IOC and TOC meeting to
be made to the Recommended Policy prior to its being forwarded to the WRAP. The
Recommended Policy dated August 30 was edited for a final time to create the Recommended
Policy for Categorizing Fire Emissions, October 25, 2001.
IOC Submission to WRAP
The IOC will submit a transmittal letter and the Recommended Policy for Categorizing Fire
Emissions, October 25, 2001 to the WRAP during October 2001. (See Appendix IV for the IOC
Transmittal Letter to the WRAP and Recommended Policy for Categorizing Fire Emissions,
October 25, 2001.)
It is anticipated that the WRAP will review and approve the Recommended Policy for
Categorizing Fire Emissions, October 25, 2001 at its November 14-15, 2001 meeting. Upon
WRAP approval, the Recommended Policy will become a product of the WRAP, published as
the Policy for Categorizing Fire Emissions and posted on the WRAP website at
www.wrapair.org.
11
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12
APPENDIX I.
SENIOR STAFF WORKSHOP SUMMARY
Executive Summary
Breakout Group Notes & Decision Tree Representations
Agenda & Presenters’ Information
Group Classification Exercise Results
Decision Tree Materials
Presenter Materials
Position Papers
Participant Information
[Ed note: This document has been formatted
for 2-sided printing (i.e., duplex printing).]
Executive Summary
February 28, 2001
Fire’s Contribution to Natural Visibility - Senior Staff Workshop
January 24-25, 2001 – Denver, Colorado
Introduction
The Regional Haze Rule requires states and tribes to develop a reasonable progress goal for each Class I
area to improve manmade visibility impairment on the 20% most-impaired days and to allow no
degradation on the 20% best days. States and tribes must:
1. determine baseline conditions based on monitoring data,
2. estimate natural visibility impairment and contribution of natural emission sources, and
3. track progress toward the goal of eliminating visibility impairment from anthropogenic emission
sources.
The preamble to the Regional Haze Rule states, “The EPA also recognizes that fire of all kinds (wildfire,
prescribed fire, etc.) contributes to regional haze, and that there is a complex relationship between what is
considered a natural source of fire versus a human-caused source of fire.” 64 FR 35735 (July 1, 1999)
“Consequently, in determining natural background for a Class I area, EPA believes states [and tribes]
should be permitted to consider some amount of fire in the calculation to reflect the fact that some
prescribed fire effects serve merely to offset what would be expected to occur naturally.” 64 FR 3573535736 (July 1, 1999), “[and tribes]” added.
The Natural Background Task Team (NBTT) of the Fire Emissions Joint Forum (FEJF) determined that
three processes must be developed for the states and tribes to meet the requirements of the Regional Haze
Rule as it applies to fire emissions.
Task 1.
Develop a methodology to categorize fire emissions (wildland/Native American
cultural/agricultural) into “anthropogenic” and “natural” source classifications.
Task 2.
Develop approaches for estimating the contribution of fire emissions to natural
background visibility conditions.
Task 3.
Establish methods for tracking and apportioning fire emissions into the Task 1
classifications.
The NBTT elected to take on the above tasks one at a time, beginning with Task 1. Over the past year
and a half, the NBTT has conducted a thorough discussion of the distinction between “natural” and
“anthropogenic” fire emissions. In the process, the group determined that broad input on these
discussions would lead to a much stronger result. To gain this input, the NBTT planned for two
successive workshops on fire’s contribution to natural visibility: the first for senior staff and the second
for policy level input.
I-1
Senior Staff Workshop Structure and Content
The first of these workshops was held in Denver, Colorado on January 24 & 25th, 2001 with the following
objective:
To categorize fire emissions sources into two classifications, “natural” &
“anthropogenic”, and to assess the policy and technical implications.
These
classifications will help define the natural visibility conditions in the Federal Class I
parks and wilderness areas in the West.
The Senior Staff Workshop involved 65 participants from the following stakeholder groups: federal,
tribal, state, and local governmental and land management agencies; large and small industries;
agricultural and forestry industries; environmental groups and the academic community. After a half-day
of background discussion, the participants met in eight small workgroups to attempt to reach consensus
on what criteria would be used to classify all wildland fires, agricultural land burns, and Native American
cultural burns.
In order to facilitate and focus the discussion of the Senior Staff Workshop, the NBTT developed a Fire
Emissions Source Categorization Decision Tree that diagrammed all of the potential emissions sources
and their differences based on stakeholder position and Regional Haze Rule assumptions that could then
be classified as “natural” or “anthropogenic”. Each workgroup was tasked with simplifying or modifying
the tree to reflect concurrence or rejection with these distinctions, or to introduce new distinctions.
At the conclusion of the workshop, the NBTT reviewed the eight workgroup solutions to identify
comparable recommendations, similar rationale for changes and recommendations, and whenever
possible, consensus between groups. The results of this review are captured in the summary that follows.
Senior Staff Workshop Results
The Senior Staff Workshop participants reached complete consensus on a few criteria for categorizing
fires, came to general agreement on most criteria, and left a few questions unresolved.
!
There was consensus that all fires on agricultural land and wildlands (i.e., forests and rangelands)
be considered equitably, that is, the same criteria for classifying natural and anthropogenic sources
would be used on all lands.
!
There was near-unanimous agreement that Native American religious or cultural burning is a
natural source, but that Native American agricultural or wildland burning done in the context of the
modern economy should be classified the same as any other prescribed fire or agricultural burn.
!
There was consensus that all prescribed fires used to maintain a sustainable ecosystem should be
considered a natural source.
However, prescribed fires used to restore an ecosystem to a
sustainable condition should be considered anthropogenic unless they satisfy other criteria
established to classify prescribed fires as natural.
!
The workgroups made few distinctions based on the purposes that motivate prescribed and
agricultural burning, other than fires used to maintain sustainable ecosystems that were categorized
as natural. All other purposes (e.g., hazard reduction, waste disposal, commodity production) may
be categorized the same, i.e., anthropogenic.
I-2
!
There was incomplete agreement on what criteria should be used to classify prescribed fire and
agricultural burn sources. The majority opinion is that where there is no reasonably available
(technological, economical, and non-air environmental) alternative to using fire to accomplish the
objective, then the source should be considered natural. A minority opinion was that burning that
results in lesser emissions than a natural fire regime in natural vegetation should be considered
natural. A small contingent felt that only fires conducted in the normal fire season should be
classified a natural source.
!
There was substantial agreement that all wildfires that are actively suppressed should be classified
as natural sources. One exception was that arson fires should be considered anthropogenic.
!
There was substantial agreement that wildland fires managed for natural resource benefits,
previously known as “prescribed natural fire”, should be treated as prescribed fires and classified
according to the criteria used for other prescribed fires and agricultural burns under the various
states’ use of smoke management plans.
!
There was agreement that escaped prescribed fires and agricultural burns would retain whatever
category, i.e., natural or anthropogenic, assigned to the originating fire, regardless of fire
management response.
!
There was general agreement that all prescribed fires and agricultural burns burned without a
permit and/or authoritative review by states or tribes should be considered anthropogenic sources.
Such a classification suggests conflict with legal exceptions to permitting that currently exist in
some states that exempt agricultural operations from regulation.
The workgroups also discussed the implications of the classification for tracking and regulating sources.
For example, it was stressed that a “natural” source designation did not exempt a source from other
regulations such as those enforced to protect human health or ambient air quality. Even though the
Regional Haze Rule does not in itself mandate control of natural sources, it will be desirable and prudent
to manage and even control emissions from natural sources whenever that can be accomplished.
Conclusion
The level of agreement within and between the eight workgroups at the Fire’s Contribution to Natural
Visibility - Senior Staff Workshop was quite substantial, and the discussions and decisions reached by
each group that are captured in the attached notes were both constructive and illuminating. The results of
the Senior Staff Workshop exceeded expectations.
From the accomplishments at the Senior Staff Workshop, the NBTT is developing a comprehensive
policy approach that addresses the classification of fire emissions under the Regional Haze Rule, toward
the 2064 Natural Visibility Goal for consideration by policy makers and opinion leaders at the second
Fire’s Contribution to Natural Visibility Workshop on May 2, 2001 in Tempe, Arizona. At this time, the
NBTT anticipates that Workshop resulting in the formulation of a clear policy recommendation for the
approval of the Fire Emissions Joint Forum members and presentation to the Western Regional Air
Partnership.
I-3
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I-4
Fire’s Contribution to Natural Visibility - Senior Staff Workshop
January 24-25, 2001 – Denver, Colorado
Breakout Group Notes
and
Decision Tree Representations
February 28, 2001
I-5
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I-6
Breakout Group A
Tamara Blett, NPS - Facilitator
Lisa Silva, Colorado Department of Health - Scribe
Carl Gossard, BLM - NBTT Resource Person
Greg Zschaechner
Utah Interagency Smoke Program
Salt Lake City, UT
Ken Woodard
EPA, OAQPS
Research Triangle Park, NC
Vicky Komie
New Mexico Air Quality Bureau
Santa Fe, NM
Manuel Cunha, Jr.
Nisei Farmers League
Fresno, CA
Mark Wagoner
Alfalfa Seed Farmer
FEJF Member - General Public: Farming
Representative
Touchet, WA
Patrick Cummins
Western Governors Association
Denver, CO
Doug Blewitt
CO Air Commissioner
Englewood, CO
Top 3-5 Group Results
Agricultural Branch: Completed
1. Group decided that the classification of “Legal Agricultural Burns” should be based on
whether or not there are alternatives to burning (with one abstention).
2. Accidental Human Ignitions classified as “Natural”.
3. Native American Cultural Burning classified as “Natural”.
Wildland Branch: Partial Rough-Cut Only
4. Hazard Reduction (Urban Interface definition) applied logic of whether alternatives to
burning were available.
Opening Discussion/Comments
Anthropogenic
Could be Either (Policy Decision)
Obviously Natural (Lightning, Fire)
Today
2064
Visibility – is not a health-based standard, but reduce as much as possible, no ban, won’t go to
zero burns/Class I areas only.
I-7
Group A/Opening Discussion cont’d.
Methodology and Other
!
!
!
!
!
!
!
!
!
!
All agreed that simplifying the classification system would be their goal.
Leave criterion boxes as is – OK, categories will fall out.
Natural = God (Mother Nature), Anthropogenic = Human-caused, two classifications, not
three?
Natural classifications problematic in that Anthropogenic can be argued as Natural (e.g., coal
burn for home heat = what? versus wood burn for home heat = Natural)
Natural could be “accidental man-made” on agricultural land
Natural could be if there was no potential for control or alternatives to fire.
Categories could be more easily collapsed if they were thought of as:
1) Alternatives to fire exist (Anthropogenic)
2) No alternatives to fire exist (Natural)
United States Department of Agriculture policy – economic consideration first in
determining whether alternatives are viable.
Make boxes broader by collapsing.
Two separate categories for Agricultural land and Wildland OK.
Agricultural Burning & the Agricultural Branch
General:
! Consider: Burn policy by Secretary of Agriculture.
! Burn as reduction.
! California 35 Air Districts.
! Commodities first, then United States Department of Agriculture policy, Environmental
Protection Agency to co-sign.
! Agriculture " commodity
! Don’t co-mingle agricultural land and wildland.
! The process for choosing Natural and Anthropogenic is not consistent with agricultural land.
! Anthropogenic on everything (California), need emissions inventory numbers.
! Intensive treatment on wildland, timber, might be on agricultural land branch.
! Industry must reduce emissions.
! Concern that all fire emissions classified as Anthropogenic could eventually be outlawed.
Native American Cultural Burn:
! Definition needed for some boxes (e.g., Native American Religious/Ceremonial)
! Collapse Native American, Religious, Traditional
! Does not include Commodity, does commercial belong? (e.g., Waste Disposal, Timber
Production)
! Regulatory authority here: Environmental Protection Agency only (Federal).
I-8
Group A/Methodology: Agricultural Branch cont’d.
Intentional Ignition:
! “Intentional” may have negative connotation; suggest “non-accidental”?
! Half emissions could be attributed to authorized burns to control future burns, noxious
weeds, under brush.
Note: Fire classifications can’t be revised just because it escapes (malfunctions).
Arson
! How to track, policy implications: change in one deciview means big change for controls.
! Is arson “background”?
! Is arson category necessary? So few on agricultural land, strike from Agricultural branch?
! Move to “illegal burn”?
! Group recommends keeping it Anthropogenic.
! Create a baseline: New Mexico – clean. Air quality deteriorates if definitions reduced to…
Commodity Production
! Now contains Escaped Agricultural Burn.
! All legal burns that burn on agricultural land.
Classification Discussion
Agricultural Branch
Collapse “Natural Ignition” to include:
! Caused by Mother Nature.
! Intensively Managed vegetation
! Even that which becomes wildland
Collapse “Accidental Human Ignition” to include:
! All intensively managed Vegetation (both Natural and Anthropogenic)
Rationale:
! Humans have always been clumsy; humans are part of nature.
! Can’t manage accidents, they’ll always be there, they have always occurred.
! Management approach based on what we can “control”.
Collapse Native American Cultural Burn:
! Traditional (Natural and Anthropogenic).
! Religious and ceremonial (Natural and Anthropogenic).
Weed/Pest/Disease Management (Natural and Anthropogenic):
! More emissions than natural vegetation
! Fewer emissions than natural vegetation
Yield Improvement (Natural and Anthropogenic)
I-9
Group A/Classification: Agricultural Branch cont’d.
Commodity Production:
1) Are there alternatives to fire? " Consider:
! Economics?
! Scientific on technology data? = Anthropogenic if Alternatives to Fire exist but fire is
used anyway
2) No alternatives to fire = Natural
Ecosystem Restoration:
! Alternative to Fire
! No Alternative to Fire
Agricultural Branch Rationale:
Main Branch is either:
! Caused by Mother Nature “natural ignition”.
! Accidental
! Intentional
For all legal burns (commodity and ecosystem):
Alternatives to Fire (Classification: Anthropogenic)
Rationale:
! Will change over time, source emissions may be reduced as technology improves and
alternative uses are discovered for agricultural residue. Therefore, classified as
Anthropogenic (man has a strong hand in this and can make choices).
! Also considers economics (cost effective), technology (equipment), and science
(methodology, i.e., genetic improvements).
No Alternatives to Burn (Classification: Natural)
Rationale:
! Accounts for the fact that there have been historical fires and emissions.
! Burning is a necessary part of agricultural production (which is equivalent to sustaining
human life).
! If human life is “natural”, then agricultural burning is Natural.
! Some agricultural land fire classified Natural because it used to burn naturally.
Accidental Human Ignition (Classification: Natural)
Rationale:
! Humans have always been clumsy: humans are part of nature.
! Can’t manage accidents, they’ll always be there, they have always occurred.
! Management approach based on what we can “control”.
Illegal Un-permitted Unregulated and Arson (Classification: Anthropogenic)
Rationale:
! They are willful human acts for harm.
! Crimes.
I-10
Group A/Classification: Agricultural Branch cont’d.
Native American Cultural (Classification: Natural) vs. Native American Agricultural Burning
(Classification: Anthropogenic)
Rationale:
! Native Americans using same categories, as other agricultural land (commodity production,
ecosystem restoration) should be treated the same as Non-Native American Agricultural
Burners.
! Modern Agricultural practices treated the same.
! Native American Cultural is considered Natural because documented pre-existing.
Commodity Production
Rationale:
! Escaped Fire keeps same category as its un-escaped intent.
! “Waste Disposal”, “Production”, “Weeds”, and “Yield”, are all under commodities because
they all are a part of commodities production, therefore they are all treated the same, so no
need to differentiate.
Wildland Branch
! Categories may not be as collapsible.
! Accidental Human Ignition is Natural (land managed or not).
! Native American Prescribed vs. Cultural
! Philosophy: Ecosystem Management = Natural
! Escaped Fires (to wildland) – management problem
Other Comments
! Policy Issue: the implication of controls, equitability.
! Emphasize controls on sources with greatest impact on Class I areas (mobile vs. static).
! Other:
! Fireplaces (all other sources?)
! Clarify how to be addressed
! Natural Volatile Organics Compounds (biogenic)
! International Transport
I-11
Fire Emissions Categorization Decision Tree - Agricultural Land Branch
Illegal
Un-permitted
Unregulated
& Arson
Intentional
Ignition
Native
American
Cultural
Burn
A
N
*All Legal
Burns on
Agricultural
Land
Legal
Burns
Agricultural
Land
Natural
Ignition
A
No
Alternatives
to Fire
N
Commodity
Production*
Agricultural
Burn
Accidental
Human
Ignition
Alternatives
to Fire
Ecosystem
Restoration
N
N
Alternatives
to Fire
A
No
Alternatives
to Fire
N
Breakout
Group
A
2-21-01 Representation
Fire Emissions Categorization Decision Tree - Wildland Branch
Arson
Intentional
Ignition
Illegal
Un-Permitted
Unregulated
Native
American
Cultural
Burn
A
Hazard
Reduction
Urban
Interface
N
Restore or
Attain
Sustainable
Ecosystem
Prescribed
Fire
(Including
Nat. Am.)
Maintain
Ecosystem
Health
Burn
SMP
Authorization Legal Authorized
Process
Wildland
N
Accidental
Human
Ignition
N
Waste
Disposal
Legal
Un-permitted
Unregulated
Based on intent
of original fire
Breakout
Group
A
Natural
Ignition
N
WFMRB/PNF
Go To Pres.
Above Fire
No
Alternatives
to Burning
N
Alternatives
to Burning
A
Single
Purpose
Benefit
Commodity
Production
Did not deal with this portion of the tree.
Links not completed
2-21-01 Representation
I-12
A
No
Alternatives
to Burning
N
In Natural
Fire Season
A
N
Out of Natural
Fire Season
In
Fir Nat
e S ura
eas l
on
Commodity
Waste
N
A
Escaped
Prescribed
Fire
Alternatives
to Burning
NonCommodity
Waste
Less
Emissions
than Natural
Vegetation
More
Emissions
than Natural
Vegetation
N
Breakout Group B
Doris Sanders, EPA - Facilitator
Tammie Dauson, Rebecca Reynolds Consulting, Inc. - Scribe
Mark Fitch, AZDEQ - NBTT Resource Person
Wendel Hann
USDA Forest Service
Leadville, CO
Tim Rogers
SD DENR, Air Quality Program
Pierre, SD
Brian Mitchell
National Park Service - Air Resources Div.
Denver, CO
Robert Quinn, Ph.D.
Eastern Washington University
Cheney, WA
Charlene Spells
EPA, OAQPS
Research Triangle Park, NC
John Beyer
USDA - NRCS
Fresno, CA
Jim Smitherman
NV DEP, Bureau of Air Quality
Carson City, NV
William C. Malone
White Mountain Apache Tribe
FEJF Member - Tribal Representative
White River, AZ
Top 3-5 Group Results
1. Both “N” (for a Natural classification) and “A” (for an Anthropogenic classification) will be
managed and “A” will be managed and controlled.
2. These trees keep equity broad because it provides similar ecological justification for both
Agricultural Land & Wildland.
3. Categorizing a man-made ignition as Natural could be a problem in the future (e.g.,
calculation of 2064 based on these branches).
4. Recommendation to go back to reasonable progress rather than “A” or “N” Classification.
5. Less/More is based on the integration of two definitions (Emissions Potential Relative to
Natural Vegetation and Natural Vegetation) plus including fire cycle and fuel loading.
Opening Discussion/ Methodology
!
!
!
!
!
!
!
!
!
How to discuss the criteria boxes when the definitions of each do not have context to the
“normal” person?
Definition of Natural is not clear.
These definitions will not be clear to regulators.
Need to keep it simple and workable.
The classifications of Natural and Anthropogenic will be dealt with differently so no one
wants to classify.
What target level of emissions is achievable by 2064?
EPA’s Reasonable Progress Goal does not allow a short-term increase in emissions to
achieve a long-term visibility goal.
Wild fire is dominating the number of burning acreage.
How does historical figure in?
I-13
Group B/Methodology cont’d.
Different Methodology/Approach Idea
Every classification should have a “Less emissions than Natural Vegetation” or a “More”
emissions than Natural Vegetation” classification, rather than a “Natural” or “Anthropogenic”
classification.
! How to define less or more? How to figure the baseline?
! Need to be able to allow for more emissions in the beginning (20 years) that will then
allow emissions to begin to drop.
! Simplify enormously, many boxes are not needed.
! Natural = natural ignition / Anthropogenic = human ignition
! Example of out-of-the-ordinary ignition = lightning strikes a man-made pile that was
intended to be put to fire anyway. What is its classification? No consensus. Two agree
to Anthropogenic. Five agree to Natural.
! Natural = managed / Anthropogenic = controlled and managed (controlled means limited)
Classification Discussion
Agricultural Land
What is Naturally Ignited?
! Range land.
! Acreage is minimal compared to forest.
! EPA did not include agricultural land in the natural ignition for management purposes.
Arson
Does it need to be a criteria box? It is such a small component that it doesn’t need to be there.
Burn Authorization Process
! Some states have a Burn Authorization Process in place but many do not.
! We don’t need to have Burn Authorization Process with natural ignition or accidental
ignition of agricultural land.
! Natural would be placed on the owner.
What is “Less Emissions that Natural Vegetation” versus “More”?
! Need to leave it open to the state.
! Less or more is taking us historical; do we want to go there?
! In order to figure the natural vegetation part of “less (or more) emissions than natural
vegetation”, do we have to go back historically?
! Being able to subtract out Natural emissions may be valuable to demonstrate progress
with year-by-year tracking.
! If we deem there are more emissions from an intentional burn than what naturally exists
then… it is OK to put CONTROLS on it, therefore: More… is Anthropogenic / Less…
is Natural
! If it is an intentionally ignited fire, the smoke emissions should be managed/controlled,
regardless of less or more (to the extent that the state laws allow).
I-14
Group B/Classification: Agricultural Branch cont’d.
Natural Vegetation definition:
! FEJF needs to consider including a natural fire cycle, fuel loading, exotic species (e.g.,
cheat grass).
! FEJF should give a model or systematic process to determine potential emissions from
natural vegetation.
Wildland Branch
! There are still major concerns of what less or more will do.
! Visibility Program Phase 1 vs. Phase 2 – less or more is relevant to Phase 2 (maybe) but
irrelevant to Phase 1.
! Public and industry will continue to be highly critical of the “wildland natural ignition” path
where fuels are 10+ times higher than “Natural” and could be better managed with prescribed
fire and mechanical treatment.
Group B’s Rationale for Changes to Agricultural Land and Wildland Branches
1. It is based on the definition of Natural Vegetation with the addition of fire cycle and fuel
loading, and the determining factor of Less or More Emissions than Natural Vegetation.
2. Simplify for tracking and implementation.
3. Some criteria were too minor and detracted from the hierarchical magnitude of the tree.
4. States could add the minor criteria back in if it helps tracking and implementation.
5. Keeps equity broad because it provides similar ecological justification for both branches.
Tracking
!
!
!
!
!
!
Need to track Natural and Anthropogenic the SAME.
Regulatory distinction could be less or more.
Problem with less or more would be inability to be consistent among states.
Can we go back to 1910 and track emissions? This could create a baseline.
Historical is an interesting possibility but is it relevant to our purpose now?
We know fire comes about every 30 years, just use that.
Overall End Comments
!
!
!
There will be exceptions!
Group is satisfied with progress today.
Fine-tuning will need to occur, tree is only an umbrella.
I-15
Fire Emissions Categorization Decision Tree - Agricultural Land Branch
Accidental
Ignition
Wildfire
A
Human
Ignition
Less
Emissions
than Natural
Vegetation
Burn
Authorization
Process
Intentional
Ignition
More
Emissions
than Natural
Vegetation
Agricultural
Land
Natural
Ignition
N
A
N
Natural
Breakout
Group
B
2-21-01 Representation
Fire Emissions Categorization Decision Tree - Wildland Branch
SMP
Authorized
Accidental
Human
Ignition
Wildfire
Human
Ignition
Natural
A
Less
Emissions
than Natural
Vegetation
Burn
Authorization
Process
Intentional
Ignition
More
Emissions
than Natural
Vegetation
Wildland
Natural
N
Natural
Ignition
SMP
Authorized
Breakout
Group
B
2-21-01 Representation
I-16
Natural
N
N
N
A
Breakout Group C
Karen Hamilton, EPA - Facilitator
Darla Potter, WDEQ - Scribe/NBTT Resource Person
Lyle Laverty
USDA Forest Service
Lakewood, CO
Robert Habeck
Montana DEQ
Helena, MT
Colleen Cripps
Nevada Division of Environ. Protection
Carson City, NV
Dave Randall
Air Sciences Inc.
FEJF Member - Small Business Representative
Lakewood, CO
David Jones
San Joaquin Valley Air Pollution Control District
FEJF Member - Local Government Representative
Fresno, CA
John Parada
La Posta Band of Mission Indians
Boulevard, CA
Top 3-5 Group Results
Wildland Branch
1. How fire is managed is more important than an ignition source.
2. If you have an opportunity to manage fire to control visibility impact, you do so. This
resulted in the “Anthropogenic” classifications.
3. Native American Cultural Burning addressed through some sort of decision or management
process that may not be similar to other land manager’s processes. Just as states have
different processes, the tribes may also have different processes.
4. Recognize the historical presence of fire through the breakout groups three Emission Source
Types (i.e., rectangles) that were given “Natural” classifications.
[Note: Breakout Group C did not address the Agricultural Land Branch.]
Opening Comments
1) State Responsibility (end point is a plan). Tracking is a key consideration.
! General Philosophy – What is Natural/Anthropogenic?
2) Branches are too complicated for tracking purposes
3) Parts of country there is more control over agriculture than other areas.
! Political implications in that due to legislative variability " needed to be discussed first
before today’s task.
! Need to look at administrative barriers
4) “Thread the Needle”
! Conflict intent of Congress (burn more) vs. available burn days.
! What are the outcomes and how do we measure success?
5) Need additional tribal representatives at a higher level.
6) Most Smoke Management Programs now are for National Ambient Air Quality Standards
protection or nuisance, not visibility.
! Anthropogenic/Natural Classification is for visibility only.
I-17
Group C/Opening Comments cont’d.
7) Technical constraints, tracking, monitoring, regulatory constraint.
! Natural visibility / portion of fire / type of fire.
! Can’t “satisfy” requirements of Regional Haze Rule if everything is “Natural”.
! Public acceptance.
! Distribution of Natural/Anthropogenic is the key to making Grand Canyon Visibility
Transport Commission recommendation work and Regional Haze Rule.
! How much room is there in the natural background (emissions pie) for growth and what
is tenable under the Regional Haze Rule.
8) Dilemma (Implementation – more, Some – closer to historical).
! Paying price now due to past land management.
! Visibility patterns now not the same as historical.
9) Limit to the air “space” in each air shed / competition with other sources.
All Emissions
Sources
Biomass Burning by
Fire Source Type
10) Have unrealistic expectations for visibility been established, legislated and regulated?
Workshop outcome may be headed the wrong direction (establishing 2064 Visibility Goal)
without knowing how “much” fire is in each category.
Methodology
!
!
!
Ignition Source doesn’t matter – management does (for what purpose), e.g., wildland arson
fire let burn.
Primary purpose of management for “greater public purpose” (good).
First Criteria Classification:
Greater
Public
Purpose
!
!
!
!
Yes (Natural)
No
(Anthropogenic)
! Above approach combines both trees. Easy to track.
! Does this approach drive land managers away from biomass utilization?
! Determination of “greater public purpose” is subjective?
Question threshold for health. Question threshold for visibility. Is there different “slack”?
Key is overlying management.
Native American Burning determined by intent of RHR and looking back at “historical”
levels.
Earned privilege. To not be subjected. To further management by use of alternatives to
burning prior to burn (i.e. spirit of reducing emissions prior to burning – fuel reduction,
emissions management).
I-18
Group C/Methodology cont’d.
!
!
!
!
Every fire can be Natural if above approach is followed to encourage the spirit of reducing
emissions.
Methodology is a folly due to practicality because we need to look forward and currently
don’t know enough to classify the fire emission sources.
E.g., level of effort: wilderness roadless / no options " “Natural”
What about areas where non-fire treatments are available but not used because land manager
say they aren’t feasible?
Classification
Group Decision: work with tree then come up with alternative approach.
Arson
! Natural – go to prescribed fire.
! Anthropogenic – fire not managed (suppress).
! Can’t be “regulated” – who’s responsible for managing the fire/smoke?
! How is it managed?
! e.g., wilderness area – let it burn (go to prescribed fire)
! e.g., plan in place – let it burn (go to prescribed fire)
! Anthropogenic – e.g., arson burn near municipality (suppress)
! Group not completely in agreement but decided to move on due to “minor amount of fires”.
Natural Ignition (Classification: Natural) – see * below
! Type of vegetation doesn’t matter, both Natural
! If on intensively managed vegetation (i.e., wheat farm), Anthropogenic.
! Suppressed a.s.a.p., then consensus: Natural
Intensively
Managed Veg.
(Natural)
Natural
Ignition
Natural
Veg.
Suppressed
(Natural)
Prescribed Natural
Fire Go To
Prescribed Fire
*Key to Natural Ignition Solution
! Management Goal – suppression but no resources available to suppress then treat same as
“suppressed”.
! Trust between Federal Land Manager’s and Regulators is still an UNDERLYING ISSUE in
some states.
Accidental Human Ignition
! Depends on how managed, suppress or let burn.
! Why different than natural ignition?
! Escaped Prescribed Fire does not flow into Accidental Human Ignition
! Combine with natural ignition, same process after the criterion box.
I-19
Group C/Classification cont’d.
!
Add Arson to criterion box also.
Hazard Reduction (Collapse, Classification: Anthropogenic)
! Doesn’t serve greater public good.
! Have opportunity to address air quality concerns so you SHOULD.
Maintain Ecosystem Health (Collapse, Classification: Natural)
! Greater public good, season doesn’t matter – Natural.
! Collapse because you can address air quality impacts – Anthropogenic. Collapse because
you have the opportunity to do so.
! Fire Season doesn’t matter, collapse – Anthropogenic.
! Collapse – Natural
! Mimicking nature in natural fire season – Natural. Out of season – Anthropogenic.
! Natural is OK because once ecosystem is restored, fire is only way to maintain.
! Change wording to Routine Maintenance of Ecosystem Health.
Waste Disposal and Commodity Production (Collapse, Classification: Anthropogenic)
! Chance to manage for visibility.
Restore/Attain Sustainable Ecosystem and Single Purpose Benefit (Classification:
Anthropogenic)
! Definition – includes burns after timber sales.
! Can manage for visibility and should.
Illegal and Legal Un-permitted Unregulated (Classification: Anthropogenic)
! Can manage for visibility.
*Key to Natural Ignition Solution (see Natural Ignition section above)
! Management Goal – suppression but no resources available to suppress then treat same as
“suppressed”.
! Trust between Federal Land Manager’s and Regulators is still an UNDERLYING ISSUE in
some states.
Took out Intentional Ignition Criteria Hexagon, due to movement of Arson to Accidental and
Natural Ignition.
Native American: Religious/Ceremonial
! Minor portion, why separate out? We’re not considering campfires.
! Can’t grapple with size (magnitude) of Religious/Ceremonial and Traditional.
! Native American Cultural, not enough information to address.
! Classify Traditional as Natural, if not routed through formal “regulatory” process.
! Could be Natural or Anthropogenic if routed through formal “regulatory” process.
! Assumption: you can channel Native American Cultural into the Burn Authorization
Process.
! Traditional or other fits into other “generic” categories.
I-20
Fire Emissions Categorization Decision Tree - Wildland Branch
Native
American
Cultural
Burn
Hazard
Reduction
Restore or
Attain
Sustainable
Ecosystem
Prescribed
Fire
Escaped
Prescribed
Fire
Wildland
WFMRB/PNF
t ed
No ess Go To Pres.
r
Above Fire
pp
Su
r
pp
es
d
se
Non
Prescribed
Natural Fire
N
Breakout
Group
C
SMP
Authorized
Illegal
Un-permitted
Unregulated
A
Legal
Un-permitted
Unregulated
A
Su
Accidental
Human or
Natural or
Arson
Ignition
Burn
Authorization
Process
Routine
Maintenance
Ecosystem
Health
2-21-01 Representation
I-21
Native
American
Religious or
Ceremonial
A
A
N
N
Waste
Disposal
A
Single
Purpose
Benefit
A
Commodity
Production
A
Breakout Group D
Dave Steinke, FS - Facilitator
Coleen Campbell, COAPCD - Scribe/NBTT Resource Person
Patti Hirami
U.S. Forest Service/Fire & Aviation
Washington, DC
Marcus Schmidt
Bureau of Land Management
Lakewood, CO
Steve Arnold
Colorado Dept. of Public Health & Environment
Denver, CO
Ursula Kramer
Pima County
Tucson, AZ
Scott Kuehn
Plum Creek Timber
FEJF Member - Wood Product Industry
Representative
Missoula, MT
C.V. Mathai
Environmental Department
Pinnacle West/Arizona Public Service
Phoenix, AZ
Rose Lee
Yakama Nation Environmental Program
Toppenish, WA
Top 3-5 Group Results
1. Designation of “N” (for Natural) is NOT a “Get out of jail Free Card” but will have less
regulation.
2. Fewer Boxes are better.
3. There needs to be Equity.
4. Historical practices may not continue, should be consistent with Regional Haze Rule.
5. Clear Allocation is not always possible. Need room for Apportionment.
6. Remember Reason we are here… it is for visibility.
7. Everyone has a different Management goal and we need to respect these.
Methodology Discussion
!
!
!
!
Because of tracking issues especially, less boxes are better
May be tracking – credit, neutral, or counts towards visibility.
Move Accidental Human Ignition to a neutral position.
Designation of Natural contains baggage of “free lunch”.
FLM Statements and Assumptions
! Assuming Smoke Management Programs are effective.
! Although a wildfire, air quality effects are considered.
! Treatment of fuels buildup, the Federal Land Managers are accountable but other
stakeholders do not see the mechanism that will be used to require accountability.
Classification Discussion
Native American Cultural Burn, Religious/Ceremonial, and Traditional should be collapsed into
one classification box for both Wildland and Agricultural Land Branches.
I-22
Group D/Classification cont’d.
Rationale: the Tribal Council would have designated all such burns. The group did not feel a
need to differentiate, would be classified the same by each group member, although no
consensus on Anthropogenic or Natural.
Wildland Branch
Illegal Un-permitted Unregulated fire moved as a direct decision off of Intentional Ignition on
the Wildland Branch.
Rationale: this classification would not have gone through burn authorization.
Native American Religious/Traditional (Classification: 4 Anthropogenic, 3 Natural)
Illegal Un-permitted Unregulated (Anthropogenic)
Natural Ignition and Accidental Ignition
There is no distinction between Intensively Managed Vegetation and Natural Vegetation.
Instead, there are two choices: Suppress or go to Burn Authorization.
Rationale: this decision is not going to rely on intensively managed or natural vegetation to
initiate this decision process.
Natural Ignition
Suppress Wildfire (Classification: 6 Natural, 1 Mixed)
Note on Mixed: If fire occurs between Fire Intervals, emissions classified as Natural; if fire
occurs on a cycle greater than the fir return interval, emissions should be Anthropogenic.
Accidental Human Ignition
Suppress Wildfire (Classification: 6 Anthropogenic, 1 Mixed)
Hazard Reduction (Classification: Anthropogenic)
Collapse Non-fire and Only Fire Treatment Available.
Single Purpose Benefit
Remove the box because it is difficult to track and fits into other categories well.
Commodity Production
Combine More and Less Emissions to one box
More/Less Emissions (Classification: 6 Anthropogenic, 1 Mixed)
Rationale: There is no distinction between the two.
Ecosystem Health
In Fire Season (Classification: 3 Anthropogenic, 3 Natural, 1 Mixed)
! Mixed Recommendation: Back to Fire Interval would be Natural
Out of Fire Season (Classification: 4 Anthropogenic, 2 Natural, 1 Mixed)
! Mixed doesn’t see the distinction
I-23
Group D/Other Issues cont’d.
Restore/Attain Ecosystem Health (Classification: 4 Anthropogenic, 3 Natural)
Other Issues
! Concern that any burn designated Natural will then not be controlled for smoke; Best
Management Practice not required but encouraged; non-burning alternatives are not required
but encouraged.
! Designation of Natural contains baggage of “free lunch”.
! Possibly look for three tiers, something in between Anthropogenic and Natural.
! Define as “By-product Disposal”; “Waste” has a negative connotation.
! Assumed the Federal Fire Policy 2000 is not in place.
! Conflict of interest (potential).
! Question concept of any emission biomass from “unnatural” fuels build up should be
considered Natural.
! Equity between types of fire if certain fires are classified as Natural and given priority.
! Smoke Management Programs do not at present get into emission reduction techniques, will
everyone with Anthropogenic be required to lower emissions but Natural will not?
! Definition of “natural background” – should inclusion of all Native American burning be
defined as Natural if just a past practice?
! Timing, size.
! Person lighted fire.
! Because of suppression (management decision) emissions from a natural ignition may not
actually have lower emissions.
Overall Thoughts
! Natural or Anthropogenic is not a “Get out of jail free” card.
! Natural will have fewer regulations than Anthropogenic.
! Historic practices need not be continued and future actions need to be consistent with
Regional Haze Rule.
! The less boxes the better on both branches.
! Natural and Anthropogenic are NOT black and white, room needs to be made in the middles
for apportionment.
! Level the playing field between the feds and industry.
! Let’s do it for the resources – we all want everything – more emphasis on the health of the
public and the ecosystem. We need to respect each other’s goals.
I-24
Fire Emissions Categorization Decision Tree - Agricultural Land Branch
Illegal
Un-permitted
Unregulated
A
A
Arson
Intentional
Ignition
Waste
Disposal
Native
American
Cultural
Burn
Religious or
Ceremonial,
Traditional
A
Accidental
Human
Ignition
Breakout
Group
D
Natural
Ignition
Burn
Authorization
Process
Escaped
Agricultural
Burn
Intensively
Managed
Vegetation
SMP
Authorized
NonCommodity
Waste
A
Less
Emissions
than Natural
Vegetation
More
Emissions
than Natural
Vegetation
Commodity
Production
A
Less
Emissions
than Natural
Vegetation
Yield
Improvement
Wildland
Go To WildBranch land
Intensively
Managed
Vegetation
A
Weed/
Pest/Disease
Mgt.
Agricultural
Burn
Agricultural
Land
Commodity
Waste
Legal
Un-permitted
Unregulated
A
Ecosystem
Restoration
More
Emissions
than Natural
Vegetation
N
A
A
A
A
A
A
2-21-01 Representation
Fire Emissions Categorization Decision Tree - Wildland Branch
Illegal
Un-permitted
Unregulated
Arson
~1% may go
to Burn Auth.
Intentional
Ignition
Native
American
Cultural
Burn
A
A
Hazard
Reduction
Religious or
Ceremonial,
Traditional
3N
4A
Prescribed
Fire
Ecosystem
Health
Wildland
Escaped
Prescribed
Fire
Accidental
Human
Ignition
Breakout
Group
D
Suppress
Wildfire
Burn
Authorization
Process
SMP
Authorized
1 Mix
6A
Waste
Disposal
Legal
Un-permitted
Unregulated
Natural
Ignition
Suppress
1 Mix
6N
A
Commodity
Production
2-21-01 Representation
I-25
Hazard
Reduction
A
Restore or
Attain
Sustainable
Ecosystem
3N
4A
Maintain
In Natural
Fire Season
3N
3A
Maintain
3N
Out of Natural
3A
Fire Season
Commodity
Waste
A
NonCommodity
Waste
A
1 Mix
6A
Breakout Group E
Dana Stotsky, EPA - Facilitator
Shelley Nolde, FS - Scribe/NBTT Resource Person
Ann Acheson
USDA Forest Service - Reg. 1
Missoula, MT
Brian Finneran
Oregon Dept. of Environ. Quality
Portland, OR
Bill Leenhouts
U.S. Fish & Wildlife Service
Boise, ID
Paige Lewis
Colorado State Forest Service
Denver, CO
Bernie Dailey
Wyoming DEQ- Air Division
Cheyenne, WY
Don Motanic
Intertribal Timber Council
Portland, OR
Top 3-5 Group Results
“Natural” vs. “Desired”
1. One option is to classify all Prescribed Fire as “Anthropogenic” but treat “all” [Legal or SMP
Authorized] smoke as “Natural” in implementation of the Regional Haze Rule. (1 vote)
2. All Prescribed Fire in “Anthropogenic”. Only box to treat as “Natural” is the Maintain
Ecosystem Health. (1 vote)
3. Hazard Reduction, Restore/Attain Ecosystem Health, and Maintain Ecosystem Health –
“Natural” classifications. (2 votes)
4. Same as #3 above, but Waste Disposal is “Natural” if it is Ecosystem Waste. Anything
Commodity oriented is Anthropogenic.
Another Option
5. Entire board is “Anthropogenic” with no asterisks (i.e., exceptions), except the 3 “Natural
Ignition” green boxes (includes “Prescribed Natural Fire”). (2 votes)
[Note: Breakout Group E did not address the Agricultural Land Branch.]
Opening/Methodology Discussion
Alternative Methodology/Approach:
Source of ignition is irrelevant. What matters is the social goal the fire is moved toward
(desirable? not?).
! Need to understand/clarify the policy implications BEFORE doing the classification (feel it
leads to exemptions under Regional Haze Rule – impacts won’t count).
! Trouble with calling anything that is man-made or man-caused “Natural”: Linguistic
Honesty.
! Native American Cultural burning should be Natural, but may not add up to enough smoke to
matter.
! Could say that all smoke resulting from human decisions is Anthropogenic; but certain kinds
of fire/smoke should be regulated differently (perhaps through “accounting” or a “banking”
system).
! We lose “asterisks” as information goes higher. Risk is that all Anthropogenic smoke will be
REGULATED, not just managed.
I-26
Group E/Opening Discussion cont’d.
!
!
!
!
!
!
!
!
!
!
“Anthropogenic emissions, which substitute for Natural emissions (which don’t happen).”
EPA may have created a “third category” in the preamble.
One interpretation is that the Preamble language applies only to the calculation of
background, not to future treatment. However, seems illogical to say this (different rules for
inventory development and future treatment).
Need to distinguish preferences on Anthropogenic vs. Natural:
! With accounting system.
! Without accounting system.
! Current vegetation.
! Previous or alternate vegetation
Natural Events Policy refers to “wildfire” – doesn’t distinguish natural from man-caused.
Issue is “controllable” vs. decision to manage.
Natural = without human involvement or intervention?
“Man-made Ignition or Human-caused Ignition” with qualifiers added later (to explain fires
to the public).
Some kinds of fire might need to be considered specially:
! Bank account
! Treated as Natural
! Display/discuss consequences
People will change their behavior based on the regulatory and funding mechanisms (they’ll
define the purpose of their fires based on what will gain them the most).
Concern expressed about equity issues – if everything is Anthropogenic, then industry could
demand that fire get decreased at same rate as other anthropogenic sources.
Task 2 and the policy ramifications should have been complete before this workshop.
I-27
Fire Emissions Categorization Decision Tree - Wildland Branch
Arson
Intentional
Ignition
Cultural
Goals ?
Social
Goals?
N
Natural
Ignition
2-21-01 Representation
Natural
Vegetation
Hazard
Reduction
A
N
A
A
N
Illegal
Un-permitted
Unregulated
N
Natural
Vegetation
N
A
A
N
A
N
N
I-28
A
N
N
A
N
A
A
NonCommodity
Waste
N
A
Commodity
Production
A
Commodity
Waste
A
Less
Emissions
than Natural
Vegetation
Commodity
Production
PNF
A
Only Fire
Treatment
Available
Out of Natural
Fire Season
Waste
Disposal
Single
Purpose
Benefit
N
In Natural
Fire Season
Waste
Disposal
A
A
Non-Fire
Treatment
Available
N
Maintain
Ecosystem
Health
Maintain
Ecosystem
Health
A
Legal
Un-permitted
Unregulated
A
N
Restore or
Attain
Sustainable
Ecosystem
SMP
Authorized
Intensively
Managed
Vegetation
WFMRB/PNF
Go To Pres.
Above Fire
Hazard
Reduction
Traditional
Escaped
Prescribed
Fire
Accidental
Human
Ignition
E
Native
American
Cultural
Burn
Intensively
Managed
Vegetation
A
Religious or
Ceremonial
Prescribed Prescribed
Fire
Fire
Wildland
Breakout
Group
N
A
N
N
A
A
More
Emissions
than Natural
Vegetation
Breakout Group F
Jane Leche, FS - Facilitator
John Graves, BIA - Scribe
Jim Russell, FS/BLM - NBTT Resource Person
Lyle Carlile
Bureau of Indian Affairs
Boise, ID
Garry Oye
Acting National Program Leader
for Wilderness, Rivers and Special Areas
USDA Forest Service, Washington Office
Washington, DC
William Malm
National Park Service/CIRA
Fort Collins, CO
Frances Bernards
UT Division of Air Quality
FEJF Member - State Representative
Salt Lake City, UT
Gerry Guay
AK Dept. of Environmental Conservation
Anchorage, AK
Craig R. Derickson
USDA - NRCS
Lincoln, NE
Art Reese
WY Office of Federal Land Policy
Cheyenne, WY
Top 3-5 Group Results
1. Wildfire Managed for Resource Benefit (WFMRB) is managed differently than Prescribed
Fire (varies by state). WFMRB is a calculated decision by the fire manager and therefore it
must go through the Prescribed Fire part of the decision tree, which includes expected smoke
impacts as part of the SMP Authorization process.
2. An escape prescribed fire retains its initial classification.
3. Illegal/Legal, Un-permitted, Unregulated should be classified Anthropogenic & controlled.
4. Accidental Human Ignitions and Natural Ignitions should be considered as a wildland fire
and not controllable therefore they are considered as Natural, which enhances the states
ability to track these ignition/emission sources.
6. Consolidate waste disposal (commodity and non-commodity), single purpose benefit and
commodity production into one emission source that is anthropogenic
7. All agricultural sources of emissions are categorized as anthropogenic.
8. An accidental and natural ignition source that leaves agricultural land onto wildland goes to
the Wildland branch of the decision tree. This also includes any escaped agricultural
prescribed burns.
Classification
Wildland Branch
Natural Ignition to be included (omit).
! Wildland Fire, the term that appears in the Federal Fire Plan, that is Managed for Resource
Benefit (WFMRB) may end up as either Natural or Anthropogenic depending on whether the
burn is considered to be for maintenance of ecosystem health and occurs during the natural
fire season.
I-29
Group F/Classification cont’d.
!
!
!
Natural Ignition branches to Intensively Managed Vegetation and Natural Vegetation are
deleted and changed to the term wildland fire.
Question posed to fire managers is will the Burn and SMP Authorization Process for
WFMRB be stringent enough to account for air quality considerations?
Natural Ignition and Accidental Human Ignition both go to wildland fire – no reason to
separate the two based on vegetation consideration (no natural vegetation left) and both are
uncontrollable.
Management objective is key in determining whether the emission category is Natural or
Anthropogenic.
Native American Burn (Classification: Anthropogenic)
! Anthropogenic, but should not be counted.
! Didn’t understand difference between Traditional/Ceremonial.
! Cannot be controlled (exempt based on tribal sovereignty).
Natural Ignition/Accidental Human Ignition
! WFMRB goes to Prescribed Fire (Escaped Prescribed Fire).
! If it’s Anthropogenic and escapes, it cannot become Natural – stays Anthropogenic.
! An escaped prescribed Anthropogenic fire cannot become Natural.
Restore/Attain Sustainable Ecosystem (Classification: 6 Anthropogenic, 1 Natural)
Anthropogenic Rationale:
! Fuel build-up is not natural. Not operationally feasible.
Natural Rationale:
! Banked emissions because of fire exclusion. Won’t be able to accomplish objective going
toward maintenance mode.
Maintain Ecosystem Health
! By burning year-round, the cleanest 20% days will be impacted.
Burn Authorization and everything thereafter (Classification: Anthropogenic)
The exception being fires occurring in natural fire season (see Maintain Ecosystem Health
section below).
Illegal/Legal Un-permitted, Unregulated (Classification: Anthropogenic)
Should be controlled.
Commodity Production, Less Emission/More Emissions (Classification: Anthropogenic)
! Can’t differentiate between Natural and Anthropogenic.
Hazard Reduction (Classification: Anthropogenic)
! Public health considerations – life/property. No case for Natural classification.
! Remove split – no need to differentiate for tracking purposes. Both are Anthropogenic.
I-30
Group F/Classification cont’d.
Commodity Waste
! No reason for split – “waste is waste.”
Single Purpose Benefit
! Waste, commodity, if all classified as Anthropogenic, why split?
Maintain Ecosystem Health
! In Natural Fire Season: Natural
! Out of Natural Fire Season: Anthropogenic
Rationale: Need to keep separated In/Out due to 20% cleanest, 20% dirtiest days occurring in
and out of the natural fire season (i.e. burning during the spring is out of the natural fire season
and during the 20% cleanest day period).
Agricultural Land Branch
Consensus: All Anthropogenic except Accidental/Natural Ignition " Wildland
Rationale: because wildland accidental/natural ignition was classified as Natural.
Changes made to the Agricultural Decision Tree are as follows:
! Remove splits after Waste Disposal, Commodity Production, and Ecosystem Restoration
because there is no differentiation as far as emissions tracking are concerned.
! Add Native American Cultural Burn for consistency with Wildland branch.
! Reword “Intensively Managed Vegetation” to “Agricultural Lands” for consistency with
Wildland branch.
! Make following change:
Intentional Ignition
Natural Ignition
Agricultural
Wildland
Agricultural
!
Escaped Anthropogenic stays Anthropogenic because an escaped Anthropogenic prescribed
fire cannot become Natural.
I-31
Fire Emissions Categorization Decision Tree - Agricultural Land Branch
Arson
Native
American
Cultural
Burn
Intentional
Ignition
A
A
Waste
Disposal
A
Commodity
Production
A
Ecosystem
Restoration
A
Agricultural
Burn
Agricultural
Land
Escaped
Anthropogenic
Stays
Anthropogenic
A
Accidental
Human
Ignition
Agricultural
Land
Burn
Authorization
Process
A
Wildland
Go To WildBranch land
Natural
Ignition
Breakout
Group
F
Escaped
Agricultural
Burn
Agricultural
Land
SMP
Authorized
Illegal
Un-permitted
Unregulated
A
Legal
Un-permitted
Unregulated
A
A
2-21-01 Representation
Fire Emissions Categorization Decision Tree - Wildland Branch
Arson
Intentional
Ignition
Native
American
Cultural
Burn
A
Escaped
Anthropogenic
Stays
Anthropogenic
Accidental
Human
Ignition
Natural
Ignition
Breakout
Group
F
A
Restore or
Attain
Sustainable
Ecosystem
A
A
Prescribed
Fire
Escaped
Prescribed
Fire
Wildland
Hazard
Reduction
Burn
Authorization
Process
Maintain
Ecosystem
Health
SMP
Authorized
A
Wildland
Fire
N
Illegal
Un-permitted
Unregulated
A
Wildland
Fire
N
Legal
Un-permitted
Unregulated
A
WFMRB/PNF
Go To Pres.
Above Fire
2-21-01 Representation
I-32
Miscellaneous
Resource
Utilization
(i.e., Waste
Disposal,
Commodity,
Single
Purpose
Benefit, etc.)
A
In Natural
Fire Season
N
Out of Natural
Fire Season
A
Breakout Group G
Marion Malinowski, BLM - Facilitator
Susan Ford, FS - Scribe
Dennis Haddow, FS - NBTT Resource Person
Mark Beighley
USDA Forest Service
Washington, DC
Lee Gribovicz
Wyoming DEQ- Air Division
Lander, WY
Art Latterell
Zion National Park
Springdale, UT
Mike Dykzeul
Oregon Forest Industries Council
OR
Rich Fisher
USDA Forest Service - Washington Office
Ft. Collins, CO
Mark Janssen
LADCO
Des Plaines, IL
Lara Autry
USEPA, OAQPS
Research Triangle Park, NC
Tom Larsen
CA Department of Forestry and Fire Protection
Sacramento, CA
Top 3-5 Group Results
Clarification / Definition
1. Agricultural Land not that different from Wildland. Therefore, focused on Wildland.
2. Difficulty placing Escaped Prescribed Burn on the branch. Definition of Escaped Prescribed
Fire?
3. Often the outcome of the fire created difficulty classifying “Natural” vs. “Anthropogenic” Source of Ignition vs. Outcome.
4. Mixed emotions on Native American Burns (Traditional, Ceremonial) – lack expertise to
deal with these burns. Did agree that Native American Burns also managed resources like
prescribed fire.
5. Discrepancy in Hazard Reduction definition.
6. Could not reach complete consensus on classifying Accidental Human Ignition. Came very
close to agreeing it was “Natural” and decision would be made to suppress or not suppress –
just like Natural Ignition.
[Note: Breakout Group G did not address the Agricultural Land Branch.]
Opening Discussion
!
!
!
!
!
!
!
Advantage to categorizing as much as possible Natural?
Target too high for 2064?
Point source and cars won’t bring needed improvement alone.
Need reasonable background – as much as possible needs to go in.
Bad/old technical analysis in past may have misled assumptions.
Manage/decide to manage whether Anthropogenic or Natural.
Suppression decisions may be made based on smoke as well as other conditions (e.g., lack of
firefighters).
I-33
Group G/Opening Discussion cont’d.
!
!
!
Trying to redefine thought process about what is Natural and Anthropogenic: Policy or
technical goal?
Pre-settlement levels are natural background?
Current
Changes here affect glide path steepness
Natural
Natural will also need to go down
2000
!
2064
Annual average improvement vs. worst 20% days.
Methodology Discussion
!
!
!
!
!
!
!
!
!
!
!
!
Not sure land use classification should be overriding decision factor.
Residential burning needs to be included in tree.
Don’t need two branches.
Simplifying the tree is a good idea.
Wilderness a different land use?
Pitting values " not a desired outcome (example fuel reduction vs. air quality).
Branch is not designed to do that --? Is designed to include all sources to categorize.
Burn type rather than land use type.
Need to be careful in how closely to delineate fire (in wood stove) " not our purpose to
describe “inventory” of emission sources.
Too much focus on burning rather than “natural state” as “fire is the preferred tool to
maintain forest health”.
Differing of views of what is natural background.
Everything on agricultural branch is similar on wildland branch.
! Different constituency.
! Different purpose (health vs. production).
Classification
Natural Ignition (Classification: Natural)
! When Prescribed Natural Fire decision escapes plan – blue box (classification).
! Fire exclusion that led to fuel build up does intensive management to lower/higher emissions.
! Is it worth tracking “intensively managed vegetation under ignition?
! Goal is suppression on both (clarification)
! Land Use Objective Perspective – attempt by land manager to reach natural condition or
attempt to continue intensive. [End state perspective]
Maintenance of Natural Condition [Maintain Ecosystem Health] (Classification: Natural)
! Distinction between restore/maintain.
! In/out of fire season – impacts might be different (i.e., in high elevations spring burning will
cause more smoke than normal). Difficult to determine when “fire season.” Temporal issue.
! Historical perspective has little bearing on what is natural today.
I-34
Group G/Classification cont’d.
!
!
Acting smarter when doing restoration may impact smoke outcome. This is a human activity
to burn out of season.
Difficult to determine difference between fire season vs. burn season, management decision
shifts time of burn – is it naturally going to continue to burn?
Accidental Human Ignition (Classification: 2 Natural, 3 Anthropogenic, 3 Undecided)
! Is Native American ignition accidental?
! Agreement that management intensity is not a decision point (same).
! Agreement that this is suppression of fire.
! Distinction between arson and accidental.
! Any fire can be managed for resource benefit.
! What is distinction between arson and illegal/un-permitted?
! Is Accidental Ignition natural or random event?
! Not always an “escape” prescription could be out of smoke or other parameter to require
suppression.
! Escape question needs to be asked in other places on the branch (i.e. maintain ecosystem
health).
! Is classification based on ability to react or prevent – criterion is not ability to control but
rather if it would burn under natural conditions.
! Control isn’t issue, ignition source.
! Can’t take people out, can’t manage outcome.
! The group could come to agreement on classification of Accidental Ignition if…
! Look at source of ignition.
! Look at outcome desired/reached.
! Look at ability to control.
WFMRB/PNF
! Two lines, one to Accidental Human Ignition and one to Natural Ignition, then go to
Prescribed Fire.
Rationale: As long as fire is allowed to continue to burn because of maintenance of ecosystem
health then is it Natural?
! SOURCE vs. OUTCOME – makes decision difficult to reach on Accidental " however
agreement reached that if Accidental Ignition goes to prescription plan, it could be
considered a natural ecosystem management outcome.
Arson (Classification: Anthropogenic)
Native American
! Is distinction significant between Ceremonial and Traditional? More than just
Cultural/Traditional. Don’t have expertise to decide. But would consider looking at
prescribed fire scenario described above. (Classify Natural, until it is a management activity
like logging).
! Several felt unqualified to answer. Two felt it is natural background (Traditional Cultural
Religious).
I-35
Group G/Classification cont’d.
!
All felt that management activities (e.g., timber slash) are in prescribed fire tract.
Waste
! Terminology has negative connotation: “Residue” or “By Product” are better terms.
! Other alternatives exist, such as chipping.
! Can Waste and Commodity be combined?
! Can Hazard Reduction be lumped with Waste and Commodity?
Hazard Reduction
! Definition needs some clarity in order to classify.
! Hazard reduction under certain circumstances equates to healthy ecosystem – where fire was
excluded and natural undesirable changes in vegetation succession occurred.
! Hazard reduction definition from industrial viewpoint is a requirement to support
management activities such as timber harvest.
! Can look at a natural definition when risk is so high that return to a natural state is desired
goal (watershed, ecosystem).
! Take out hazard reduction activities that don’t have anything to do with restoration.
Other Classification Points
! Term “Natural” can be used in many ways and can confuse discussions
! Dam removal for restoration analogy relates to ecosystem benefits. Peak may not be part of
end point.
! Accidental human ignitions have occurred over time – there is some natural background
associated with these.
! What now is Escaped Prescribed burn " does it go back to hazard risk/ecosystem
health/residue?
Other Comments/Issues
! Fugitive dust levels.
! Sulfate controls and autos " hard to achieve goals in west. Surprisingly little improvement
in “modeling” for investments.
I-36
Fire Emissions Categorization Decision Tree - Wildland Branch
Arson
A
N
Intentional
Ignition
A
Religious or
Ceremonial
Native
American
Cultural
Burn
N
A
Not qualified
Traditional
vs Natural
Hazard
Reduction that
Restores/Attains
Sustainable
Ecosystem
Traditional
Prescribed
Fire
Wildland
Escaped
Prescribed
Fire
Accidental
Human
Ignition
Burn
Authorization
Process
2N 3A
2N 3A
Natural
Vegetation
Intensively
Managed
Vegetation
WFMRB/PNF
Go To Pres.
Above Fire
Breakout
Group
G
Natural
Ignition
Intensively
Managed
Vegetation &
Natural
Vegetation
N
2-21-01 Representation
I-37
SMP
Authorized
Maintain
Ecosystem
Health
Illegal
Un-permitted
Unregulated
A
Legal
Un-permitted
Unregulated
A
Commodity
Production &
Residue
Disposal
N
A
Non-Fire
Treatment
Available
A
Only Fire
Treatment
Available
N
A
Breakout Group H
Ellenjean Morris, CODPHE - Facilitator
Mike Ziolko, ODF - Scribe/NBTT Resource Person
Sandy Gregory
BLM
Reno, NV
Mark Gray
WA State Dept. of Natural Resources
Olympia, WA
Donna V. Lamb
USDA Forest Service
Washington, DC
Jim Lawrence
Western State Foresters
Lakewood, CO
Rich Damberg
USEPA OAQPS
Research Triangle Park, NC
Jody A. Gale
UT State Univ. Extension Services
Richfield, UT
Mike George
Arizona DEQ
Phoenix, AZ
Kevin McKernan
Yurok Tribe Environmental Program
FEJF Member - Tribal Representative
Orick, CA
Top 3-5 Group Results
Note: The group started on the Agricultural branch, but only partially completed it before
moving to the Wildland branch and completing those categorizations.
Agricultural Land
Concern about going back generations to determine Historical Treatment.
1. Plan or Unplanned is sufficient; don't need to segregate Accidental Human from Natural
Ignitions
2. Agricultural Burns are the same regardless of who. (Equity between sources and landowners
being the consideration.)
3. Agricultural burning is the same regardless of who does it; religious and cultural aspects are
one and the same for categorization purposes.
Wildland
1. Arson – can have only limited management or control
2. Native American Cultural Burns – not for commodity purposes (i.e., Timber companies).
(Commodity related burning would be categorized as for any other landowner)
3. Question whether something that is Illegal should be in Visibility Rule.
4. Classification based on Today’s Technology. Allow for future changes based on what
evolves. (There may be different management objectives and ways to achieve those
objectives in the future.)
5. If you can’t control it, can’t manage it, OK to classify “Anthropogenic” but need recourse
process so it doesn’t count against you for compliance purposes. (Circle of influence)
6. Maintain Ecosystem – add Fire Treatment Options prior to In or Out of Fire Season – Need
the Flexibility.
I-38
Group H/Methodology cont’d.
Methodology
Agricultural Branch
Commodity Production / Commercial Value
! Does it matter if there are “less or more” emissions than natural when money is being made
from the resource?
! Difference between land use issue and “industrial” source.
Accidental Human Ignition " change to “ Planned” or “Unplanned”
Rationale: there is no such thing as Accidental Human Ignition. What is primary is whether it is
planned or unplanned. Also, don’t need to separate Accidental Human from Natural Ignition.
Native American
Agricultural goes straight to “Agricultural Box”, no need to go through Native American box.
Religious, Cultural, Traditional
Agricultural Assumption: (carried over to Wildland as well)
! Native American Cultural – based on agricultural burns are agricultural burn for all.
! Cultural Burn of an agricultural field as determined by tribe.
Smoke Management Program or no Smoke Management Program
Either Smoke Management Program (SMP) or Burn Authorization Process or no SMP in place.
(The idea here being that the Smoke Management Program is a part of the burn authorization
process. Therefore, is there a need to differentiate between the two?)
Wildland Branch
! Some states require a burn authorization process for prescribed fire prior to burning.
! Classifications are based on technology we have now.
Classification Discussion
Wildland Branch
Arson (Classification: 6 Anthropogenic, 2 Natural)
Rationale for Natural – can’t manage or control.
Rationale for Anthropogenic – human caused, may be able to reduce through fire prevention
programs or other means.
I-39
Group H/Classification cont’d.
Native American Cultural (Classification: 6 Natural, 2 Undecided)
Rationale:
! Issues of treaty; hunting & fishing; subsistence rely upon burning.
! Not for commodity purpose burning (goes to prescribed fire).
Legal Un-permitted Unregulated (Classification: 7 Anthropogenic, 1 Undecided)
Rationale: Has an anthropogenic purpose but doesn’t need a Smoke Management Program
(SMP). Must go through SMP route to get a Natural classification.
Illegal Un-permitted Unregulated (Classification: 6 Anthropogenic, 1 Natural, 1 Undecided)
! Does this fit in the visibility role?
! Are there other rules that apply to this source (exceptional events policy)?
! How does this fit? (i.e., it is something that shouldn’t happen? A compliance issue)
Accidental Ignition
! Intensively Managed Vegetation (Classification: 3 Anthropogenic, 3 Natural, 2 Undecided)
Rationale for Anthropogenic: it is human managed.
Rationale for Natural: it is not an intentional act.
! Natural Vegetation (Classification: 6 Natural, 2 Undecided)
Natural Ignition
! Intensively Managed Vegetation (Classification: 1 Anthropogenic, 5 Natural, 2 Undecided)
! Natural Vegetation (Classification: 6 Natural, 2 Undecided)
Restore/Attain Sustainable Ecosystem
! Changed to a criterion box and added two decision boxes:
! Non-Fire Treatment Available (Classification: 6 Anthropogenic, 1 Natural)
! Only Fire Treatment Available (Classification: 1 Anthropogenic, 5 Natural, 1
Undecided).
Rationale for Anthropogenic: Management decisions brought us there so it should be
Anthropogenic.
Hazard Reduction
! Non-Fire Treatment Available (Classification: 6 Anthropogenic, 1 Natural)
! Only Fire Treatment Available (Classification: 1 Anthropogenic, 5 Natural, 1 Undecided).
Maintain Ecosystem Health
! Non-Fire Treatment Available (Classification: 2 Anthropogenic, 4 Natural, 1 Undecided)
! If you are maintaining, do what the ecosystem requires.
! Only Fire Treatment Available (Classification: 1 Anthropogenic, 5 Natural, 1 Undecided).
! To maintain ecosystem regardless of in/out of fire season.
! Burns in and out of season will be done to maintain or wouldn’t be done at all.
I-40
Group H/Classification cont’d.
Waste Disposal
! Commodity Waste (Classification: Anthropogenic)
! Non-Commodity Waste (Classification: Anthropogenic)
Rationale: Revert back to all Waste being Anthropogenic, strictly done for Anthropogenic use.
Single Purpose Benefit (Classification: Anthropogenic)
Rationale: Not done for overall ecosystem.
Commodity Production
! Less Emissions than Natural Vegetation (Classification: Anthropogenic)
! More Emissions than Natural Vegetation (Classification: Anthropogenic)
Note: Look at distinction or exemption for small landowners regarding less or more, may be
dealt with under SMP.
Agricultural Branch
Native American Cultural Burn (Classification: Natural)
! Includes religious and traditional
Escaped Burn (Classification: 6 Anthropogenic, 1 Natural)
I-41
Fire Emissions Categorization Decision Tree - Agricultural Land Branch
Native
American
Cultural
Burn
N
Plan
Agricultural
Burn
Escaped
Agricultural
Burn
Illegal
Un-permitted
Unregulated
A
Legal
Un-permitted
Unregulated
A
UnPlanned
NonCommodity
Waste
Burn
SMP
Authorization Authorized
Process
More
Emissions
than Natural
Vegetation
Commodity
Production
Wildland
Go To Wildland
Tree
Less
Emissions
than Natural
Vegetation
Yield
Improvement
Intensively
Managed
Vegetation
Links not completed
Less
Emissions
than Natural
Vegetation
Weed/
Pest/Disease
Mgt.
A
Intensively
Managed
Vegetation
Agricultural
Land
Waste
Disposal
Commodity
Waste
More
Emissions
than Natural
Vegetation
Ecosystem
Restoration
Arson
Breakout
Group
H
2-21-01 Representation
Accidental
Human
Ignition
Fire Emissions Categorization Decision Tree - Wildland Branch
Arson
Intentional
Ignition
Native
American
Cultural
Burn
A
N
Prescribed
Fire
Escaped
Prescribed
Fire
Wildland
Illegal
Un-permitted
Unregulated
A
Legal
Un-permitted
Unregulated
A
Breakout
Group
H
Natural
Ignition
2-21-01 Representation
Restore or
Attain
Sustainable
Ecosystem
Burn
SMP
Authorization Authorized
Process
Maintain
Ecosystem
Health
5 N 1 A 2 Abstain
Accidental
Human
Ignition
Hazard
Reduction
Intensively
Managed
Vegetation
Natural
Vegetation
N
Waste
Disposal
A
Natural
Vegetation
N
Single
Purpose
Benefit
A
Intensively
Managed
Vegetation
N
Commodity
Production
WFMRB/PNF
Go To Pres.
Above Fire
I-42
Non-Fire
Treatment
Available
A
Only Fire
Treatment
Available
N
Non-Fire
Treatment
Available
A
Only Fire
Treatment
Available
N
Non-Fire
Treatment
Available
N
Only Fire
Treatment
Available
Less
Emissions
than Natural
Vegetation
More
Emissions
than Natural
Vegetation
In Natural
Fire Season
N
Out of Natural
Fire Season
N
A
A
Fire’s Contribution to Natural Visibility
Senior Staff Workshop
January 24 & 25, 2001
Adams Mark Hotel, Denver, CO
(303) 893-3333 Phone; (800) 444-2326 Phone; (303) 626-2542 Fax
Workshop Objective: To categorize fire emissions sources into two
classifications, “natural” & “anthropogenic”, and to assess the policy and
technical implications. These classifications will help define the natural
visibility conditions in the Federal Class I parks and wilderness areas in the
West.
Workshop Registration
Noon – 1:00 p.m.
Columbine Room, Terrace Level
AGENDA
Day 1: January 24, 2001, 1:00 – 5:30 p.m. MST
I.
Welcome
1:05 – 1:10
Pete Lahm, USDA FS
FEJF Co-Chair
II.
Keynote
1:10 – 1:30
Patrick Cummins, WGA
III.
Introductions
1:30 – 1:40
Carl Gossard, BLM
NBTT Co-Chair
IV.
Review Agenda, Workshop Outcomes
Describe Process
1:40 – 2:00
Rebecca Reynolds
Facilitator
V.
Visibility
2:00 – 2:15
The importance of good visibility.
Dennis Haddow, USDA FS
The impact of smoke on visibility: the state of the science. William Malm, Ph.D.
NPS/CIRA
VI.
Regulatory Context
2:15 – 2:30 Richard Hayslip
The regulatory evolution of visibility protection and
Salt River Project
prescribed fire policy, from the Clean Air Act and the
Grand Canyon Visibility Transport Commission
Recommendations, to the Regional Haze Rule and the WRAP.
VII.
Break
2:30 – 2:45
I-43
Fire’s Contribution to Natural Visibility
Senior Staff Workshop
January 24 & 25, 2001
Adams Mark Hotel, Denver, CO
Page 2
Day 1 continued
VIII.
Role of Fire Panel
2:45 – 4:00 David Sandberg, Ph.D.
Building a common baseline of understanding: the role
USDA FS (moderator)
of fire on wildlands; the inter-relationship of fire in
agriculture; and the use of fire by Native American
cultures.
Wildlands
James Agee, Ph.D., U. of WA
Native American Cultural Practices
Philip Omi, Ph.D., CO State U.
Agricultural Lands
Robert Quinn, Ph.D., Eastern WA U.
IX.
Categorization Method
4:00 – 5:00
Introduction of the decision tree fire emissions source
categorization method, giving background and context
including operating assumptions, definitions and
important terms.
A. Introduce Process
5 min
B. Definitions/Assumptions Review 10-15 min
C. Decision Tree Introduction
D. Questions
X.
XI.
15 min
20 min
Group Classification Exercise
5:00 – 5:30
Each participant will have the opportunity to select
classifications for the fire emissions sources represented
on the Decision Tree. The exercise will capture the
participants’ first impressions so as to measure the
workshop’s progress toward increased consensus.
A. Introduce Exercise
5 min
B. Group Classify
25 min
(Turn in at door on way out)
Question & Answer Session
7:30 – 8:30
Members of the NBTT will be available to participants
to answer questions regarding the decision tree fire
emissions source categorization method, the
development process, how this effort fits into the larger
FEJF/WRAP picture, etc. This will be an informal
session, open to any participants who are interested.
I-44
R. Reynolds
Darla Potter, WDEQ
NBTT Co-Chair
D. Sandberg
R. Reynolds
R. Reynolds
All
Optional (Tower Court D)
Fire’s Contribution to Natural Visibility
Senior Staff Workshop
January 24 & 25, 2001
Adams Mark Hotel, Denver, CO
Page 3
Day 2: January 25, 2001, 8:00 a.m. – 4:00 p.m. MST
I.
Welcome Back
8:00 – 8:10
C. Gossard
II.
Day 1 Review
A. Q&A Session Review
B. New Questions/Comments
8:10 – 8:30
R. Reynolds
III.
Breakout Groups
8:30 – Noon
Work in small groups, with stakeholder representation,
to review the Decision Tree, test it for thoroughness,
then use it to classify fire emissions.
A. Breakout Instructions
10 min
R. Reynolds
B. Breakouts Work
3.25 hrs
All (w/ facilitators)
1.5 hrs - Understand the Tree - Have all of the
sources been accounted for in the Tree?
2.0 hrs - Assign Classifications - Document
rationale/explanation with examples for
each classification.
0.5 hr - Finalize Group Product to be used during
Report Back. Discuss tracking issues/
implications (if there is time).
IV.
Lunch Break
Buffet provided.
Noon – 1:00
(Tower Court D)
V.
Breakouts Continued
1:00 – 2:00
All (w/ facilitators)
VI.
Break
2:00 – 2:15
VII.
Report Back
2:15 – 3:45 All Groups
Small groups bring back their progress on Classification and
present to each other.
A. Group Classification Exercise Results
15 min
R. Reynolds
B. Breakout Group Reports
1.25 hrs
Facilitators
VIII.
Close
3:45 – 4:00
I-45
C. Gossard
[This page intentionally left blank.]
I-46
Fire’s Contribution to Natural Visibility
Senior Staff Workshop
January 24 & 25, 2001
Adams Mark Hotel, Denver, CO
Presenters’ Information
James K. Agee, Ph.D. -- Professor of Forest Ecology, Division of Ecosystem Sciences, College
of Forest Resources. University of Washington, Seattle, WA. Dr. Agee’s specialty is fire ecology
and the historical role of fire in western forests.
Patrick Cummins -- Air Quality Program Manager, Western Governors’ Association (WGA),
Denver, CO. Mr. Cummins also serves as the Co-Project Manager for the Western Regional Air
Partnership. Over the last 14 years, he has held environmental planning and management
positions at the federal, state, and local levels, and has worked in the private sector as a corporate
planner.
Carl W. Gossard -- Smoke Management Specialist, Bureau of Land Management, Boise, ID.
Mr. Gossard started his career as a range conservationist in Safford Arizona. He has served as
District Fire Management Officer on the Arizona Strip, Fire Staff Specialist in the Oregon State
Office, and State Fire Management Officer in Colorado.
Dennis Haddow -- Air Program Manager, USDA Forest Service, Denver, CO. Mr. Haddow
coordinates visibility protection and smoke management programs for two Forest Service Regions
focusing on regulatory development and wilderness protection.
Richard M. Hayslip -- Manager, Environmental, Land & Risk Management, Salt River Project,
Phoenix, AZ. Mr. Hayslip has been involved in the activities of the GCVTC and WRAP since
1994. He served on the Public Advisory Committee of the GCVTC and was instrumental in
negotiating the recommendation relating to stationary sources. In addition, he participated in
Commission activities relating to prescribed fires. He is currently a member of the WRAP
Initiatives Oversight Committee.
Pete Lahm -- Air Resource Program Manager, USDA, Forest Service, Phoenix, AZ. Mr. Lahm
is currently Co-chair of the Western Regional Air Partnership-Fire Emissions Joint Forum. He
led the Fire Emissions Project of the Grand Canyon Visibility Transport Commission 1991-1996.
Since 1991, he has managed the Interagency Smoke Management Program in Arizona and has
worked on smoke management issues since 1987.
William C. Malm, Ph.D. -- Research Physicist, National Park Service Visibility
Program/Cooperative Institute for Research in the Atmosphere, Air Resources Division, National
Park Service, Fort Collins, CO. Dr. Malm has been involved in visibility and air quality research
since 1972, first as a professor of Environmental Science at Northern Arizona University, then as an
Environmental Protection Agency Research Scientist, and finally as a Research Physicist in charge
of the National Park Service visibility/particulate research monitoring program.
I-47
Fire’s Contribution to Natural Visibility
Senior Staff Workshop
January 24 & 25, 2001
Adams Mark Hotel, Denver, CO
Page 2
Presenters’ Information continued
Philip N. Omi, Ph.D. -- Professor and Director, Western Forest Fire Research Center
(WESTFIRE), Colorado State University, Fort Collins, CO. Dr. Omi specializes in forest fire
management, fuels treatment, and prescribed fire.
Darla Potter -- Visibility, Smoke Management, & EIS Coordinator, Wyoming Department of
Environmental Quality - Air Quality Division, Cheyenne, WY. Ms. Potter is a co-chair of the
Natural Background Task Team. She coordinates visibility and smoke management issues for
the State of Wyoming with a focus on stakeholder involvement.
Robert Quinn, Ph.D. -- Professor of Geography, Meteorologist, Eastern Washington University,
Cheney, WA. Dr. Quinn is also a member of the Agricultural Air Quality Task Force, USDA.
Rebecca Reynolds -- President, Rebecca Reynolds Consulting, Inc., Denver, CO. Ms. Reynolds
is a planning consultant, facilitator, and meeting design consultant. She has worked with the
Forest Service, agencies of local government, and broadly in the non-profit sector, including
environmental organizations.
David (Sam) Sandberg, Ph.D. -- Team Leader, Fire and Environmental Research Applications,
Pacific Northwest Research Station, USDA Forest Service, Corvallis, OR. Dr. Sandberg’s
specialty includes assessing changes in flammability and fire effects caused by climate change,
land use, and ecosystem management policy. He is also an expert in the effects of wildland fire
on air quality.
Rebecca Reynolds Consulting
1/17/01
I-48
Fire’s Contribution to Natural Visibility – Senior Staff Workshop
Group Classification Exercise, January 24, 2001
Purpose
This exercise was designed to capture the Senior Staff Workshop participants’ first impressions
of the fire emissions source classifications. The results of the exercise demonstrate the areas
where there was greater consensus and those where there were differing opinions. The exercise
also gave the Natural Background Task Team (NBTT) a tool for measuring the workshop’s
progress toward increased consensus.
Exercise
As the last task of the first day of the workshop, Senior Staff Workshop participants were given a
copy of the Fire Emissions Source Categorization Decision Tree Wildland Branch and
Agricultural Land Branch. They were asked to take a moment to review the branches and to
quickly assess how they would classify each white (rectangle) box: “natural” or “anthropogenic”.
The participants were given approximately 30 minutes to complete both branches by indicating
their choice by clearly marking a CAPITAL “N” or “A” to the UPPER RIGHT of each white
(rectangle) box (representing a fire emissions source). See Example 1.
The participants were also instructed that if they either did not understand the logic or the
description, or they did not agree with them, please leave the box blank. See Example 2.
Example 1.
Example 2.
N
N
A
Results
The classifications resulting from the exercise are summarized in the following two diagrams of
the Fire Emissions Categorization Decision Tree Agricultural Land Branch and Wildland
Branch. The classifications are indicated to the right of each rectangle with an A representing
“Anthropogenic” classifications, N representing “Natural” classifications, and * representing
classifications that were left blank by a participant.
I-49
Group Classification Exercise Results - Agricultural Land Branch
Arson
Intentional
Ignition
A 48
N5
*2
Native
American
Cultural
Burn
Religious or
Ceremonial
A 26
N 25
*4
Traditional
A 28
N 21
*6
Accidental
Human
Ignition
Land Use
NonCommodity
Waste
A 47
N5
*3
Weed/
Pest/Disease
Mgt.
Escaped
Agricultural
Burn
Intensively
Managed
Vegetation
A 48
N4
*3
Waste
Disposal
Agricultural
Burn
Agricultural
Land
Commodity
Waste
Burn
Authorization
Process
A 42
N7
*6
Wildland
Go To
WildBranch
land
SMP
Authorized
Commodity
Production
Illegal
Un-permitted
Unregulated
A 46
N4
*5
Legal
Un-permitted
Unregulated
A 44
N5
*6
Yield
Improvement
Ecosystem
Restoration
A 22
N 20
* 13
Less
Emissions
than Natural
Vegetation
A 38
N 12
*5
More
Emissions
than Natural
Vegetation
A 44
N6
*5
Less
Emissions
than Natural
Vegetation
A 39
N 11
*5
More
Emissions
than Natural
Vegetation
A 45
N6
*4
Natural
Ignition
Intensively
Managed
Vegetation
A 18
N 33
*4
A - number classifications Anthropogenic
N - number classifications Natural
* - number classifications blank
I-50
Group Classification Exercise Results - Wildland Branch
Arson
Land
Use
Intentional
Ignition
A 45
N5
*4
Religious or
Ceremonial
Native
American
Cultural
Burn
Traditional
A 25
N 25
*4
A 27
N 21
*6
Hazard
Reduction
Restore or
Attain
Sustainable
Ecosystem
A 20
N 28
*6
Prescribed
Fire
Wildland
Escaped
Prescribed
Fire
Accidental
Human
Ignition
Natural
Ignition
A - number classifications
Anthropogenic
N - number classifications
Natural
* - number classifications
blank
Intensively
Managed
Vegetation
Natural
Vegetation
Intensively
Managed
Vegetation
Natural
Vegetation
Burn
Authorization
Process
A 37
N 10
*7
A 27
N 22
*5
A 18
N 33
*3
A6
N 46
*2
WFMRB/PNF
Go To
Pres.
Above
Fire
I-51
Non-Fire
Treatment
Available
A 37
N 12
*5
Only Fire
Treatment
Available
A 27
N 23
*4
In Natural
Fire Season
A 17
N 33
*4
Out of Natural
Fire Season
A 25
N 25
*4
Commodity
Waste
A 48
N3
*3
NonCommodity
Waste
A 41
N9
*4
Less
Emissions
than Natural
Vegetation
A 38
N 12
*4
More
Emissions
than Natural
Vegetation
A 44
N6
*4
Maintain
Ecosystem
Health
SMP
Authorized
A 46
Illegal
Un-permitted N 5
Unregulated * 3
A 42
Waste
Disposal
Single
Purpose
Benefit
Legal
Un-permitted N 7
Unregulated * 5
Commodity
Production
A 30
N9
* 15
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I-52
Fire’s Contribution to Natural Visibility - Senior Staff Workshop
January 24-25, 2001 – Denver, Colorado
Decision Tree Materials
Fire Emissions Source Categorization Decision Tree Overview
Background Assumptions
Definitions
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[This page intentionally left blank.]
I-54
Fire Emissions Source Categorization Decision Tree Overview
Utilized by the Fire Emissions Joint Forum – Natural Background Task Team
January 11, 2001
A Senior Staff Workshop will be conducted January 24-25, 2001 by the Western Regional Air
Partnership Fire Emissions Joint Forum and its Natural Background Task Team to define fire’s
contribution to natural visibility conditions within Federal Class I areas.
Senior Staff Workshop Objective: To categorize fire emissions sources into two
classifications, “natural” and “anthropogenic”, and to assess the policy and technical
implications. These classifications will help define the natural visibility conditions in the
Federal Class I parks and wilderness areas in the West.
The Natural Background Task Team has developed a Fire Emissions Source Categorization
Decision Tree (Decision Tree) as the method to be utilized in the workshops to classify fire and
its subsequent emissions into two visibility classifications. Either classification may include
natural and human-caused ignitions. The two visibility classifications and their associated
definitions follow:
# Natural Source Classification - A categorization that designates which fire emissions result
in a natural reduction of visibility for each Federal Class I area in the West.
# Anthropogenic Source Classification - A categorization that designates which fire
emissions contribute to visibility impairment and must be managed to achieve progress
toward the 2064 natural visibility goal for each Federal Class I area in the West.
There are several overarching background assumptions, operating definitions, and glossary terms
that were utilized by the Natural Background Task Team in the development of the Decision
Tree. Please refer to the Background Assumptions and Definitions papers that accompany this
overview for additional information. One of the main assumptions utilized is that Smoke
Management Programs are an effective method to manage smoke and will be applied to all
natural ignitions and human-caused fire and associated emissions.
Fire Emissions Source Categorization Decision Tree
A brief description of the Decision Tree is provided below to assist you in the classification of
fires and their subsequent emissions into two visibility classifications.
The Decision Tree considers agricultural burns and wildland fires as the two primary sources of
smoke emissions. The Decision Tree is built from several factors to be considered in the
classification of fire. (See Figure I) On the Decision Tree these factors appear as yellow
hexagons and are described as ignition classification criteria.
The ignition classification criteria have connectors to emission source types that appear as white
rectangles on the Decision Tree. As you proceed through the ignition classification criteria to an
emission source type, you will be asked to assign a visibility classification, natural or
anthropogenic, to each emission source type on the Decision Tree. You will also be asked to
identify the supporting criteria, which will lead directly to the methods, and processes needed for
tracking those emissions.
I-55
The Natural Background Task Team recognizes that a fire may be conducted for a variety of
reasons. However, due to the complexity of tracking fires and their subsequent emissions, the
Decision Tree was developed under a presumption that a fire event will receive only one
visibility classification.
At the workshops, breakout groups will be asked whether or not the Decision Tree needs
modification. Breakout groups will be allowed to modify the Decision Tree but are asked to
keep in mind that all ignition classification criteria and emission source types need to be
trackable in association with the fire’s emissions.
Conceptual Ideas
The Natural Background Task Team compiled some conceptual ideas in the development of the
Decision Tree. Please consider the following conceptual ideas as you work through the Decision
Tree to assign a visibility classification, natural or anthropogenic, to each emission source type.
The following list is not meant to be inclusive of all conceptual ideas that may arise from
working through the Decision Tree, so please note your own conceptual ideas to foster
discussion in the breakout groups at the workshops.
•
•
•
•
•
•
How should emissions be classified that are generated from hazard fuel reduction fire when
non-fire alternatives are available and the fuels are burned anyway? Why?
If no non-fire alternatives are available then how should the emissions be classified? Why?
Should the emissions be classified differently if the wildland fuels are due to a natural buildup or an unnatural accumulation due to management practice? Why?
If management has changed the fuel/vegetation to support a more infrequent use of fire than
the previous role of fire in the natural vegetation (i.e., agricultural conversion) should the
emissions be classified differently? Why?
How should emissions be classified when they are produced from fire during the natural fire
season? Why?
How should the emissions produced from fire outside of the natural fire season be classified
if:
• The total emissions produced are less than if the fire was conducted during the natural
fire season? Why?
• The total emissions produced are more than if the fire was conducted during the natural
fire season? Why?
I-56
Figure I. Decision Tree Ignition Classification Criteria
$ Land Use Type
% Agricultural Land
% Wildland
$ Ignition Sources
% Intentional
! Prescribed Fire
! Agricultural Burn
! Native American Cultural Burn
% Accidental Human
% Natural
$ Regulatory Framework
% Burn Authorization Process
% Smoke Management Program
! Best Management Practice Requirements
! Permit Exemption by Rule
$ Purpose and Objective of Fire
% Wildland Hazard Reduction
% Desired Condition of the Wildland
! Ecological Role of Fire
! Natural Fire Season
% Commodity Production
! Agricultural Land
! Wildland
I-57
Fire Emissions Source Categorization
Decision Tree
See
Agricultural Land
Branch
Agricultural
Land
Land Use
Wildland
See
Wildland
Branch
I-58
Agricultural
Land Branch
Intentional
Ignition
Arson
Native
American
Cultural
Burn
Waste
Disposal
Religious or
Ceremonial
NonCommodity
Waste
Traditional
Weed/
Pest/Disease
Mgt.
Agricultural
Burn
Escaped
Agricultural
Burn
Agricultural
Land
Accidental
Human
Ignition
Commodity
Waste
Burn
Authorization
Process
SMP
Authorized
Intensively
Managed
Vegetation
Illegal
Un-permitted
Unregulated
Wildland
Go To Wildland
Tree
Legal
Un-permitted
Unregulated
Natural
Ignition
Intensively
Managed
Vegetation
I-59
Commodity
Production
Yield
Improvement
Ecosystem
Restoration
Less
Emissions
than Natural
Vegetation
More
Emissions
than Natural
Vegetation
Less
Emissions
than Natural
Vegetation
More
Emissions
than Natural
Vegetation
Wildland Branch
Intentional
Ignition
Arson
Native
American
Cultural
Burn
Hazard
Reduction
Religious or
Ceremonial
Restore or
Attain
Sustainable
Ecosystem
Traditional
Prescribed
Fire
Escaped
Prescribed
Fire
Wildland
Accidental
Human
Ignition
Burn
Authorization
Process
Intensively
Managed
Vegetation
Illegal
Un-permitted
Unregulated
Waste
Disposal
Legal
Un-permitted
Unregulated
Single
Purpose
Benefit
Natural
Vegetation
Intensively
Managed
Vegetation
Natural
Ignition
SMP
Authorized
Maintain
Ecosystem
Health
Natural
Vegetation
Commodity
Production
WFMRB/PNF
Go To Pres.
Above Fire
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Non-Fire
Treatment
Available
Only Fire
Treatment
Available
In Natural
Fire Season
Out of Natural
Fire Season
Commodity
Waste
NonCommodity
Waste
Less
Emissions
than Natural
Vegetation
More
Emissions
than Natural
Vegetation
Background Assumptions
Utilized by the Fire Emissions Joint Forum – Natural Background Task Team
January 5, 2001
1. The preamble to the Regional Haze Rule states “The EPA also recognizes that fire of all kinds
(wildfire, prescribed fire, etc.) contributes to regional haze, and that there is a complex
relationship between what is considered a natural source of fire versus a human-caused source of
fire.” 64 FR 35735 (July 1, 1999) “Consequently, in determining natural background for a Class
I area, EPA believes States [and Tribes] should be permitted to consider some amount of fire in
the calculation to reflect the fact that some prescribed fire effects serve merely to offset what
would be expected to occur naturally.” 64 FR 35735-35736 (July 1, 1999), “[and Tribes]” added
2. One of the primary recommendations of the Grand Canyon Visibility Transport Commission
states “The Commission recognizes that fire plays a significant role in visibility on the Plateau.
In fact, land managers propose aggressive prescribed fire programs aimed at correcting the
buildup of biomass due to decades of fire suppression. Therefore, prescribed fire and wildfire
levels are projected to increase significantly during the studied period (sic. 1995-2040). The
Commissions recommends the implementation of programs to minimize emissions and visibility
impacts from prescribed fire, as well as to educate the public.” Report of the Grand Canyon
Visibility Transport Commission to the United States Environmental Protection Agency,
Recommendations for Improving Western Vistas, June 1996, page ii.
3. A change in type and accumulation of fuels in the West has occurred because of the past land
management practices and climate variability. Fire is an essential component of most natural
systems, and perpetuation of fire at a level required to maintain ecosystem processes is
necessary. The Federal Wildland Fire Management Policy calls for the reintroduction and
continued use of fire in order to restore natural fuel densities, and to restore wildland ecosystems
to their healthy natural states.
4. Smoke Management Programs are an effective method to manage smoke and will be applied
to all natural ignitions and human-caused fire and associated emissions. Smoke management
programs may be individually tailored, as set out by each regulatory agency’s needs, but should
contain the minimum elements specified in EPA’s Interim Air Quality Policy on Wildland and
Prescribed Fires (April 23, 1998) as well as in the Agricultural Air Quality Task Force’s
recommendation titled Air Quality Policy on Agricultural Burning (November 10, 1999).
5. EPA’s Interim Air Quality Policy on Wildland and Prescribed Fires (April 23, 1998)
integrates two public policy goals: 1) to allow fire to function, as nearly as possible, in its natural
role in maintaining healthy wildland ecosystems; and 2) to protect public health and welfare by
mitigating the impacts of air pollutant emissions on air quality and visibility.
I-61
6. “Fire has been an integral part of agricultural management as long as man has systematically
grown crops. Modern technologically based agriculture still utilizes burning and for some crops
is the only economical means available to deal with residue.” Agricultural Air Quality Task
Force’s recommendation titled Air Quality Policy on Agricultural Burning, page 5 (November
10, 1999)
7. The November 10, 1999 recommendations regarding an Air Quality Policy on Agricultural
Burning from the Agriculture Air Quality Task Force addresses two public policy goals: 1) to
allow the use of fire as an accepted management practice, consistent with good science, to
maintain agricultural production on agricultural land; and 2) to protect public health and welfare
by mitigating the impacts of air pollution emissions on air quality and visibility.
8. With the suppression of Native American burning in the past century through federal presence
in Indian Country, many ignition sources have been absent from the landscape (i.e., ignitions by
Native people). Furthermore, with the increased trend of Tribal self-governance, Tribes may
choose to permit and/or manage and/or increase the number of burns on their lands as part of a
cultural restoration and preservation program. In several cases, fire is the only treatment
available or appropriate.
9. Land use patterns have changed historically and are expected to continue to change in the
future. This may affect the use of fire as a land management tool and may also affect fire’s
contribution to natural background.
10. Fires play a role in the wildlands and agricultural lands of the west. The natural fire return
interval should be considered when assessing the pattern of natural visibility impairment.
11. The use of alternatives to burning on wildlands and agricultural lands to accomplish land
management objectives may result in fewer atmospheric emissions. However, several factors
including the costs of treatment, the environmental impacts, and whether fire must be used to
meet management objectives must be considered when selecting appropriate treatment.
12. The regulatory approach for smoke and visibility protection is intended to be applied equally
on all agricultural land and wildland.
13. Emissions from fire are an important contributor to episodic visibility impairment. Visibility
monitoring and some form of source apportionment will be necessary to demonstrate reasonable
progress.
14. An emission tracking system should be established for all natural and human-caused fire.
The same categorization of emissions for natural and human-caused fire should be used by all
agencies.
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Definitions
Utilized by the Fire Emissions Joint Forum – Natural Background Task Team
January 5, 2001
Operating Definitions
Agencies1 - When this term appears, it refers inclusively to federal, state, tribal, and local
agencies.
Agricultural Fire/Burning1 - Any fire ignited by management actions to meet specific objectives
(i.e., managed to achieve resource benefits) on agricultural land.
Agricultural Land1 - Agricultural land includes croplands, pasture, and other lands on which
crops or livestock are produced (PL 104-127, Section 1240A). Rangeland will be included with
wildland for the purposes of the FEJF work.
Anthropogenic Source Classification - A categorization that designates which fire emissions
contribute to visibility impairment and must be managed to achieve progress toward the 2064
natural visibility goal for each Federal Class I area in the West. This classification may include
natural and human-caused ignitions.
Fire1 - When this term appears, it refers inclusively to wildfire, prescribed natural fire/wildland
fire managed for resource benefits, prescribed fire, rangeland fire, and agricultural fire.
Land Managers1 - When this term appears, it refers inclusively to federal, state, tribal, and
private land managers.
Natural Conditions - Includes naturally occurring phenomena that reduce visibility as measured
in terms of light extinction, visual range, contrast, or coloration. 64 FR 35764 (July 1, 1999)
Natural Source Classification - A categorization that designates which fire emissions result in a
natural reduction of visibility for each Federal Class I area in the West. This classification may
include natural and human-caused ignitions.
Pasture Land - Grazing lands comprised of introduced or domesticated native forage species that
are used primarily for the production of livestock. They receive periodic renovation and/or
cultural treatments such as tillage, fertilization, mowing, weed control, and may be irrigated.
They are not in rotation with crops. Natural Resources Conservation Service National Range
and Pasture Handbook, 1997.
Prescribed Fire1 - Any fire ignited by management actions to meet specific objectives (i.e.,
managed to achieve resource benefits).
I-63
Rangeland - Land on which the historic climax plant community is predominantly grasses,
grasslike plants, forbs, or shrubs. Includes lands revegetated naturally or artificially when
routine management of that vegetation is accomplished mainly through manipulation of
ecological principles. Rangelands include natural grasslands, savannas, shrublands, most
deserts, tundra, alpine communities, coastal marshes and wet meadows. Natural Resources
Conservation Service National Range and Pasture Handbook, 1997.
Silviculture - The theory and practice of controlling forest establishment, composition, and
growth. The art of producing and tending a forest.
Smoke Effects1 - The effects on visibility (both plume blight and regional haze), public nuisance,
and the health-based NAAQS due to emissions from fire.
Smoke Management Program (SMP) - The objectives of a basic or enhanced smoke management
program are to ensure: 1) no health-based NAAQS are exceeded; 2) nuisance smoke is mitigated;
and 3) smoke impacts on visibility are minimized in Class I areas and meet the Grand Canyon
Visibility Transport Commission recommendations. A Basic SMP will provide a framework of
procedures and recommendations for managing smoke, and an Enhanced SMP will focus on the
issues of advanced emissions reduction techniques, the reduction of visibility impact, and
provide the framework to develop an emission tracking system.
Wildfire1 - Any unwanted, non-structural fire.
Wildland1 - An area where development is generally limited to roads, railroads, power lines, and
widely scattered structures. The land is not cultivated (i.e., the soil is disturbed less frequently
than once in 10 years), is not fallow, is not in the USDA Conservation Reserve Program. The
land may be neglected altogether or managed for such purposes as wood or forage production,
wildlife, recreation, wetlands, or protective plant cover (EPA Interim Air Quality Policy on
Wildlands and Prescribed Fires). The land is not “agricultural land” as operationally defined
above. Silvicultural land and rangelands (per the FEJF charge), woodlots, and private
timberlands will be included with wildlands for the purposes of the FEJF work.
Wildland Fire - All types of fire (see definition of fire above), except fire on agricultural land.
Wildland Fire Managed for Resource Benefits/Prescribed Natural Fire1 - These terms both have
current use in regulations and policies. They are considered to be synonymous and are used
interchangeably in this workplan. These terms refer to the management of naturally ignited fires
to accomplish specific, prestated resource management objectives in predefined geographic areas
outlined in the fire management plan.
1
Operating Definitions from Section 1.1 of the WRAP FEJF Workplan dated February 25, 1999.
I-64
Decision Tree Glossary
Accidental Human Ignition - An unintentional random event.
Examples: fire ignited by a cigarette butt or an escaped campfire, fire ignited by a
combine.
Arson - A person intentionally, by starting a fire or causing an explosion, maliciously or
fraudulently damages property of their own or another party.
Examples: A fire intentionally ignited to accrue ill-gotten gains, such as from an
insurance settlement, or a fire intentionally ignited as retribution against a land manager.
Burn Authorization Process - A process set in place at the local, state, and/or tribal level
designed to account for and/or regulate prescribed fires, agricultural burning, and native
american cultural burning.
Example: Process to notify fire departments and/or forestry agencies that burning is
going to take place.
Commodity Waste - Burning of land management related fuel or vegetation that is the byproduct of a commercial operation. Alternatives exist to dispose of or alleviate the fuel
accumulation, but they may not be cost effective.
Examples: Burning of orchard prunings, orchard or vineyard removals, leftover
christmas trees, landing residues, or stumps from clearing/grubbing operations.
Emissions Potential Relative to Natural Vegetation - The emissions from prescribed fire or
agricultural burning are less or more than what would be expected to occur from natural fires in
natural vegetation (i.e., that which would occur in the absence of human
intervention/management).
Examples: Less Emissions – Apple orchard replacing sagebrush or maintenance burning
on green fuel-breaks planted with saltbrush.
More Emissions – Grass field burning replacing oak forest or pine plantation replacing
mixed hardwood forest. Grasslands that historically burned naturally, or were burned by
indigenous people, have been replaced by a field crop that is burned for improvement of
the future yield of the crop.
Illegal, Un-permitted, Unregulated - Intentionally ignited burning conducted during a burn ban in
an area that is exempt from permitting or external regulatory control.
Intensively Managed Vegetation - Vegetation or a vegetative condition that has been
intentionally replaced or simplified ecologically by maintaining a silvicultural/vegetation
management bias to commodity and non-commodity value.
Examples: Dry land wheat farm, pastureland, christmas tree farms, agricultural land,
silvicultural land, vegetation manipulation for off-road vehicle use, or intensive grazing
management.
Intentional Ignition - The deliberate or calculated ignition of wildland and/or agricultural fuel
and/or vegetation.
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Legal, Un-permitted, Unregulated - Intentionally ignited burning conducted in an area that is
exempt from permitting or external regulatory control.
Examples: Wildland forest fire not covered by forestry burning regulations. An
agricultural burn where legislative authority to regulate agriculture is not granted to state,
tribe, or local agency.
Native American Cultural Burn - Classified by individual tribes through resolution, rule, or
ordinance established by the tribal council for traditional, ceremonial, and religious use.
Examples: Burning for tule production to weave baskets or the propagation of
subsistence plant materials.
Natural Ignition - Fire/Burn ignited due to a natural (i.e., non-anthropogenic) event.
Examples: Fire ignited by lightning or volcanic eruption.
Non-Commodity Waste - Burning of land management related fuel or vegetation that is not the
by-product of a commercial operation. Alternatives exist to dispose of or alleviate the fuel
accumulation.
Examples: Burning of fuel accumulation (slash) resulting from road building, land
clearing, ditch burning, or vegetation removal for conversion to residential land.
Smoke Management Program (SMP) Authorized - A prescribed fire, wildland fire managed for
resource benefit or agricultural burn authorized under a basic framework of procedures and
requirements called a Smoke Management Program (SMP).
Exclusive Agricultural Land Decision Tree Terms
Commodity Production - The use of an agricultural burn in support of economic activities
usually related to increasing or maintaining agricultural output.
Examples: Removal of competing weeds, reducing pests between crops or stimulation of
next seasons growth.
Ecosystem Restoration - Burning on land that has been returned from cropland to its former
vegetation land cover (usually grasses or trees).
Example: Burning to shape the vegetative mosaic in a fire dependent ecosystem on
Conservation Reserve Program (CRP) lands. CRP lands may have been retired to reduce
soil erosion, protect the Nation’s longrun capability to produce food and fiber, reduce
sedimentation, improve water quality, foster wildlife habitat, curb the production of
surplus commodities, address environmental concerns, and/or provide income support for
farmers.
Escaped Agricultural Burn - Any fire ignited by management actions on agricultural land to meet
specific objectives that goes out of control and burns an unintended area.
Example: Wheat stubble burn that escapes into dry rangeland or that burns an adjacent
wheat field.
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Weed/Pest/Disease Management - Burning with the pre- and post-harvest objective of
controlling and/or reducing the incidence of weeds, pests and disease impacting a crop.
Examples: Weed – goat crass, star thistle control, cheat grass, dodder; Pest – hessian fly,
lygus bugs, weevils; Disease – cepholosporium stripe rust, fire blight, tristeza virus.
Yield Improvement - Burning with the pre- and post-harvest objective of reducing and/or
eliminating competing weeds or other non-target vegetation during a standard crop rotation,
burning that improves growing conditions for subsequent crops (i.e. by adding nutrients or
available water to the soil), or burning that stimulates new growth.
Examples: Field burning on seed production fields, wheat stubble for no-till seeding or
for multiple cropping, or for pasture stimulation.
Exclusive Wildland Decision Tree Terms
Commodity Production - The use of prescribed fire in support of economic activities related to
meeting production activities.
Examples: Increasing forage values (animal unit months) or silvicultural output (board
feet).
Escaped Prescribed Fire - Any fire ignited by management actions on wildland to meet specific
objectives that goes out of prescription (e.g., fire intensity greater than specified in a pre-set fire
plan, pre-set wind speeds exceeded, fire jumps pre-established boundaries, etc.) in a predefined
geographic area.
Hazard Reduction - Burning of accumulated wildland fuels to reduce the risk of wildfire.
Examples: Wildland/Urban interface burning, areas of especially combustible fuels.
Maintain Ecosystem Health - Maintenance fire in a wildland ecosystem in balance can be either
prescribed fire or wildland fire managed for resource benefit depending on the land use
objective.
Examples: An underburn in a ponderosa pine stand which has had previous fire
treatments within the range of ecological variability.
Natural Fire Season - The time of year when the fuels are cured to a point that a wildland fire
spreads readily and lightning ignitions are likely. The Natural Fire Season varies geographically.
Natural Vegetation - The vegetative community that would be indigenous or natural to the
geographic area had the area not been exposed to a disturbance event other than lightning.
Disturbance events include development of farmland or pasture land, extensive grazing, invasion
by exotic species, exclusion of fire, etc.
Examples: Pasture (irrigated or dry land), season-long grazing management, wilderness
areas, roadless areas.
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Non-Fire Treatment Available - Wildland areas in which mechanical or other means of fuel
removal or reduction are economically available.
Examples: Logging slash accessible to chippers, mechanical thinning.
Only Fire Treatment Available - Wildland areas in which mechanical treatment is not allowed or
where accessibility for mechanical work is limited or not possible.
Examples: Wilderness, roadless, and scenic areas where mechanical equipment is not
allowed.
Restore or Attain Sustainable Ecosystem - Burning accomplished to bring a wildland ecosystem
into a state consistent with its historical fire cycle. Burning fuels of non-natural species to allow
for the re-establishment of natural vegetation. Fuels are managed to levels consistent with that
which is considered normal for the fuel type.
Examples: Returning conifer to pine forests or restoring natural fire cycles onto the
rangelands.
Single-Purpose Benefit - Burning that is conducted to meet the need of an individual flora or
fauna species or human use or sensibility and is not vital to overall wildland ecosystem
management.
Examples: Burning of brush or forest fuels to improve a scenic vista, burning to improve
forage and/or habitat that increases hunting opportunities.
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Fire’s Contribution to Natural Visibility - Senior Staff Workshop
January 24-25, 2001 – Denver, Colorado
Presenter Materials
Focus on Workshop Tasks Graphic
Context – Natural Background Scope and Objectives
WHY ARE WE HERE – The Treasure
Effects of Smoke on Visibility
Background and Context of Regional Haze Regulation
Historic Fire Regimes of Western U.S. Forests
Contribution of Native American Firing Practices to Historic Fire
Regimes
Fire and Agriculture: Historical Perspective to the Present
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I-70
Stay
Stay Focused
Focused on
on the
the Workshop
Workshop Tasks
Tasks
Quantify Fire’s
Contribution to
2064 Visibility Goal
INTENT:
Clean Air Act
Regional Haze Rule
NAAQS
NSR
PSD
Fire Emissions
Tracking System
Federal Class I
Area Visibility
Protection
Other Sources of
Natural Visibility
Impairment
WORKSHOP TASKS
•Review Categorization
Methodology
•Assign Classifications
Market Trading
(offsets)
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FEDERAL AGENCY
MANDATE:
Endangered Species Act
Food Security Act
Organic & Wilderness Acts
FLMPA
NFMA
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I-72
Context -- Natural Background Scope and Objectives
Fire Emissions Joint Forum – Natural Background Task Team
January 9, 2001
The Regional Haze Rule requires states and tribes to develop a reasonable progress goal for each
Class I area to improve manmade visibility impairment on the 20% most-impaired days and to
allow no degradation on the 20% best days. States and tribes must:
1) determine baseline conditions based on monitoring data,
2) estimate natural visibility impairment and contribution of natural emission sources, and
3) periodically track progress towards the goal of eliminating visibility impairment from
anthropogenic emission sources.
NBTT -- Scope and Objectives
The Natural Background Task Team (NBTT) determined that three processes must be developed
for the states and tribes to meet the requirements of the Regional Haze Rule as it applies to fire
emissions.
1. Develop a methodology to categorize fire emissions (wildland/Native American
cultural/agricultural) into “anthropogenic” and “natural” source classifications.
2. Develop approaches for estimating the contribution of fire emissions to natural
background visibility conditions.
3. Establish methods for tracking and apportioning fire emissions into the Task 1
classifications.
Current Work – Task 1: Methods for Categorizing Fire Emission Sources
The NBTT has elected to take on these tasks one by one, beginning with Task 1. This task is the
focus of all of the NBTT products to date, including the outcome of the workshops in 2001. We
realize that this is a first step, and all three tasks are interrelated. But until we have agreement
on what fire sources are considered natural or anthropogenic, it will be impossible to proceed on
to the other tasks. Task 1 will not estimate the magnitude of natural fire emissions in the past,
present or future.
Future Direction – Task 2: Contribution of Fire Emissions to Natural Background
Estimating natural background and fire emissions will be difficult and is the focus of Task 2.
The complexity of this issue has been discussed at length in various venues including the
Environmental Protection Agency Natural Conditions Guidance Committee and the Federal
Advisory Committee Act Clean Air Group that led up to the issuance of the Regional Haze Rule.
For this reason, the NBTT decided to defer the task of estimating the magnitude of fire emissions
and background visibility reduction until after Task 1 is complete.
The term “natural” is not necessarily synonymous with historical conditions. Pre-settlement
history provides one estimate of natural emissions from fire. Knowledge of fire history is a
useful starting point for analysis, but not a surrogate for the natural role of fire in the future.
Patterns of land use, vegetation change, and climate variability can and will affect the role of
fire.
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Future Direction – Task 3: Tracking and Apportioning Fire Emissions
The Regional Haze Rule requires that fire emissions and their impact be tracked over time in
order to measure progress toward the 2064-visibility goal. Task 3 will establish the methods for
tracking and apportionment of fire emissions. Part of this tracking must discriminate between
emissions that are considered natural and those that are considered anthropogenic. It is currently
not possible to apportion fire emissions on a filter-based system with current monitoring
technology. Because of this, a source-based inventory tracking system must be established,
reflecting the criteria established in Task 1. New or improved data collection systems or
modeling systems may be necessary.
I-74
WHY ARE WE HERE - The Treasure
Dennis Haddow
Air Program Manager Rocky Mountain and Intermountain Regions
USDA Forest Service
Why are we here? Why have we spent years working on the Grand Canyon Visibility Transport
Commission, Regional Haze Regulations and the Western Regional Air Partnership? What is it we are
trying to accomplish? What is it we are trying to protect? What was Congress trying to protect when
they passed the 1977 and 1990 Clean Air Act Amendments, which included the National Visibility Goal.
“…the prevention of any future, and the remedying of any existing impairment, of visibility in
mandatory class I Federal Areas…
In our efforts on the various committees and forums of WRAP it is easy to become wrapped up in issues
such as market trading, expectancy values, fire emissions, deciviews, sulfate, nitrate, and PM-2.5 levels
and cost benefit ratios. Why is it we are really here? The simple answer is that we have a treasure of
great value that belongs to all of us. Some of us value this scenic treasure more that others but I believe
that all of us believe there is a treasure.
The treasure is the scenic beauty of some of most spectacular natural resources in the world. In the West,
we are truly blessed with visual resources that may best be described in non-technical terms.
“Spectacular”, “awesome”, “fantastic”, “humbling”, or just “wow” may be a better way to describe these
scenic wonders than terms such as unique landforms, texture, color, visual range, contrast or extinction.
Many of us have jobs that pay us to support other public and private benefits such as cheap electricity and
gasoline, affordable automobiles, or fire resistant communities. No one will deny that these are all
important. We work hard to make sure that our source of air pollution emissions gets its share of the
pollution pie and that no one else gets a part of our share. However, we need to remember that the
American public, through Congress has declared that the ability to view our scenery through clean air is
also very important and that its protection is worth the effort. And remember, it is best described as
viewing OUR scenery, not just viewing THE scenery. The prize is not just natural scenic treasures but
national scenic treasures. We are guided to protect this scenic natural beauty not for only of those of us
fortunate to live in the West but for all of the American public, even those who are so unfortunate as to
live somewhere else.
The amount of protection that we give to any resource should be determined by its value and the degree to
which it is threatened. Congress believes that our national scenic treasures have great value, as does most
of the American public. Our visitors to National Parks and Wildernesses rate viewing the scenery as a
major reason if the not the main reason for coming to these areas. I believe all of us have seen what air
pollution can do to interfere with out ability to enjoy these values. Few of us deny the threat is real.
As we work through the vast tangle of terms and minutia, we need to remember that there truly is a prize
worth protecting and that protecting it is why we are really here.
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Effects of Smoke on Visibility
Draft 01/12/01
William Malm
Doug Fox
Rodger Ames
INTRODUCTION
The history of fire on the North American Continent is a diverse topic that has warranted
numerous publications in the form of books, peer-reviewed journal articles and presentations.
Only in the last 100 years or so has the management of fire evolved into a formal public policy
with guidelines being dictated by governmental agencies. Pyne (1997) and others (Chi et al,
1979; Sandberg et al, 1979; EPA, 1992) have written superb reviews of fire history and it is not
the purpose of this proposal to review that history here.
However, it is of interest to point out how attitudes about fire management have changed
over the years. Early in this century, Chief Forester Henry Graves (1913) stated, “the necessity
of preventing losses from forest fires requires no discussion. It is the fundamental obligation of
the Forest Service and takes precedence over all other duties and activities” (Graves, 1913).
Chief Forester William Greeley (1920-1928) stated, “The conviction burned into me that fire
prevention is the number one job of American foresters...” (Pyne, 1997 p. 268).
These attitudes have changed as awareness of the role fire plays in the development and
sustainability of healthy and natural ecosystems has been better understood. For some time, we
have recognized that humans have co-evolved with the natural landscape. For instance,
MacCleery et al., wrote, “Whether we perceive it or not, humans are embedded in nature. We
are a part of nature and subject to its processes. We affect the land and the land affects us. This
was as true in pre-industrial society as it is today. People have never been ecologically invisible
upon the landscape. There is no such thing as people who are outside of nature.” They further
state, “All concepts of sustainability are social/cultural constructs.” The point being that our
view of what is sustainable and acceptable is very much a consequence of the cultural
background from which we operate. Pyne (1997) quotes E. V. Komarek arguing that mankind is
a grassland animal and a fire creature. “Our bread comes from cereals which are grasses that
were developed from fire-adapted grasses. The meat in our diet comes largely from animals that
eat grass, forbs, or shrubs and cannot in any manner be considered forest animals. Nearly all, if
not all, of the major cereal food plants and our major domestic livestock apparently came from
fire environments” (Komarek, 1971).
Research has documented that most natural forest ecosystems require fire at regular intervals
to maintain themselves. Further, we have learned that the efforts to suppress fire, especially over
the past 80 years in the western United States, have had two unintended consequences. First, it
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has allowed extreme and unnatural fuel build-up to the point where naturally occurring fire
cannot be accommodated without unacceptable threats to human life and natural/cultural
resources. The 1988 Yellowstone National Park fires presented a graphic example. While
unnatural fuel buildup presents problems, especially in rapidly growing urban interface areas
throughout the west, forest health may be an even greater potential threat. Fire exclusion allows
insect and disease ecosystem components to gain ground. Dead and dying forests accelerate fire
risks. For these reasons, federal land management agencies, in recent years, have joined together
with state and tribal governments to develop a new, more consistent wildland fire policy. The
policy is intended to restore healthy and more natural forests in the western United States.
Two key goals of the new wildland fire policy are:
•
Protection of human life remains the first priority of wildland fire management. Property
and natural/cultural resources jointly become the second priority, with protection
decisions based on values to be protected and other considerations.
•
Wildland fire, as a critical natural process, must be reintroduced into the ecosystem. This
will be accomplished across agency boundaries and will be based upon the best available
science.
Wildland fire policy will continue to evolve. The rate and extent of reintroduction of fire into
the forest ecosystem, although a positive effect on the ecosystem is expected, could fly in the
face of clean air and water quality acts. The Amendments to the Clean Air Act of 1977 had as a
goal the prevention of any future and remedying of existing air pollution including visibility in
certain national parks and wilderness areas that are referred to as class I areas. As a result of the
1977 Clean Air Act, visibility regulations were developed that addressed “plume blight” in class
I areas, while regional haze issues were put off to a later date. That later date is now here with
the proposed regional haze regulations that will require about a 10% improvement in visibility
every ten years or about 1% per year. Furthermore, the proposed PM2.5 National Ambient Air
Quality Standard (NAAQS) further reduces the amount of particulate matter allowed in the
atmosphere in any given 24-hr period. States will be developing and modifying State
Implementation Plans (SIP) to include strategies for meeting these standards that will include the
regulation of smoke emissions.
As emissions from industrial sources, such as SO2 and associated sulfate and carbon from urban
areas, were reduced to meet current standards, sulfate and organic levels have decreased and thus
visibility improved in many of our most scenic areas. For instance, Figure 1 shows that in many
parts of the United States there has been an increase in the frequency of both low concentration
(clean) days and a decrease in the frequency of high concentration (dirty) days for organics in
almost all areas of the western United States. However, by implementing the federal wildland
fire policy, increases in prescribed fire could easily offset these gains. Therefore, both these
proposed regulations, in principle, could limit the amount of smoke allowed in the atmosphere
over the long term (regional visibility regulation) and short term (PM2.5 standard).
I-78
ASSESSING THE IMPACT OF WILDFIRE ON VISIBILITY
To what extent is it possible to quantify the impact fire has on PM 2.5 loadings and on visibility
in the west? This is a scientific question that is only now being asked. Determining the
contribution of fire to PM2.5 concentrations will remain a key research question for the
emerging PM monitoring networks to address. It is also difficult to estimate specific
contributions that forest and agricultural burning fires make on visibility. However, the authors
have recently considered the association between IMPROVE aerosol monitoring and wildfire in
the west.
Figure 1. Map of the United States showing increases in frequency of low concentration (clean)
days and decreases in frequency of high concentration (dirty) days for organics.
Over the past thirty years, on average between 3 and 4 million acres of forests have been
consumed by forest fires annually. Forest service fire statistics compiled from five western
regions (excluding Alaska and Hawaii) indicate a total of 28 million acres were burned by
wildfires during 1984 to 1997 (Petterson, 2000). The median annual average for this 14-year
period is 1.5 million acres burned. Among the three years with the highest annual fire totals,
1988, 1994, and 1996, the acres burned by wildland fires is approximately 3 times greater than
the 14-year median. This large inter-annual wildland fire variability presumably translates
variability in wildland fire emissions, primarily as fine particle carbon precursors. If wildland
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fires constitute a large component of measured particle mass, the inter-annual variability in acres
burned should be captured by the monitoring data.
The organic carbon (OC) contribution to annual average fine mass concentration ranges from
40%–60% throughout much of the non-urban western United States (Malm et al., 2000). The
same IMPROVE data indicate OC contributions on the haziest days, that is when particle mass
concentrations are highest, can reach 80% of fine mass at some western monitoring locations.
Figure 2 shows the spatial pattern of OC contribution to the haziest days during 1994-1996. The
values shown in Figure 2 represent the upper five percentile OC contribution subtracted from the
median OC contribution, or excess OC contributions. The spatial pattern in Figure 2 indicates
accentuated OC contribution to the highest fine mass, or haziest days, throughout much of the
western United States 1994-1996 period is shown in Figure 2 because of above normal fire
activity during these years. It suggests wildland fires have a discernable contribution to fine
particle OC measured at western IMPROVE monitoring sites. Excess OC contributions similar
to those in Figure 2 are not observed during years with low wild fire activity.
Figure 2. OC contribution to RCFM upper 5 percentile (expressed as difference above the
median OC contribution) for the three year 1994 to 1996 period. Contour intervals are
5% and are shown for positive values only. Elevated contributions in the western U.S.
may represent the contribution from wildland fires.
To determine whether elevated OC levels measured at IMPROVE sites are related to wildland
fires, we test for significant relationships using Theil liner regression. Figures 3 and 4 are
examples of wildland fire and OC data for California and Colorado. Annual OC data are broken
down to the L20 (mean of the lower 20th percentile), M20 (mean of the middle 20th percentile)
and U20 (mean of the upper 20th percentile) in the respective states. The regression analysis only
uses IMPROVE sites with 10-years of data. In California, coastal sites and sites in close
proximity to urban areas are excluded. Error bars in Figures 3 and 4 indicate ± one standard
deviation in the annual OC mean of each percentile group. Notice that the U2O OC
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Figure 3.
Acres burned by wildfire in California (bold black line) and OC mass
concentrations at selected IMPROVE monitoring locations in California. The OC
mass concentrations are shown as annual means for Yosemite (YOSE) and Lassen
(LAVO) at the U20, M20, and L20 fine mass concentration groups.
Figure 4.
Acres burned by wildfire in Colorado (bold black line) and OC mass concentrations
at selected IMPROVE monitoring locations in Colorado. The OC mass
concentrations are shown as annual means for Mesa Verde (MEVE), Weminuche
(WEMI), Great Sand Dunes (GRSA) and Rocky Mountain (ROMO) at the U20,
M20, and L20 fine mass concentration groups.
concentrations have the largest inter-annual variability, while M20 and L20 are relative constant
from year to year.
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Table 1 shows regression results, where wildland fire acres burned is the dependent variable and
OC particle mass concentrations is the independent variable. Five western states have at least
two IMPROVE sites with 10 years of monitoring data to compare to annual wildland fire data.
In Table 1 the regression intercept, B0, and slope, B1, are shown for the L20, M20, and U20
regressions. The p-values indicate the confidence level at which we can reject the null
hypothesis that either intercept or slope equals zero. Among all states the U20 regressions slopes
have positive magnitudes, and among four of five states, the slopes are significant (p-values less
than 0.1) at a 90% confidence level. In no cases are the regression slopes significant for L20 or
M20 regressions. These results lead us to conclude that wildland fires are the driving force
behind much of the variability associated with OC particle mass concentrations during hazy, or
high fine mass concentration days, among the states considered.
STATE GROUP
AZ
90
50
20
PB0 B1 (NG/M3/1000ACRES)
PB1 N
B0(µG/M3)
1.5
0.031
1.98
0.073 10
1.0
0.031
0.17
0.727 10
0.8
0.031
-0.30
0.291 10 a
CA
90
50
20
2.4
1.4
0.3
0.031
0.031
0.031
3.70
0.08
0.08
0.005 10
0.727 10
0.381 10
CO
90
50
20
1.2
0.9
0.4
0.031
0.031
0.188
5.71
-0.54
-1.11
0.047 10
0.381 10
0.216 10
UT
90
50
20
1.3
0.7
0.4
0.031
0.031
0.031
1.34
-0.03
-0.10
0.484 10
1.000 10
1.000 10
WY
90
90
50
20
1.3
1.3
0.7
0.4
0.188
0.188
0.031
0.188
3.82
6.07
0.12
0.16
0.002
0.000
0.291
0.108
10
10 a
10
10
Table 1. Theil regression statistics for five western states. Group represents the mean of the
upper (U20), middle (M20), and lower (L20) fine mass 20th percentile. B1 is the
regression slope, and P is the p-value showing the significance level at which the null
hypothesis that the slope equals zero can be rejected. All regressions use 10 years of
monitoring data and annual fires statistics. a denotes sampling periods when OC >
PM2.5 by mass was kept in regression.
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While OC in the fine mass U20 and wildland fires acres burned are significantly correlated on an
annual basis for a number of western states, the uncertainty associated with the slope coefficients
is typically 50% or more. Apportionment of OC to wildland fires using this technique will
therefore have uncertainty of similar magnitude. An obvious limitation of the method applied
here is the simplistic spatial limitation of fires impacts within a given state. For example, the
selected IMPROVE sites may not be influenced by some fires that occur in their state, and
emissions from fires in outlying states can cross-state boundaries.
Nonetheless, the regression analysis provides rough estimates of particle OC apportionment to
wildland fires. Table 2 shows the 10-year average group 90 OC apportionment to wildland fire
ranges from approximately 10% to 50%, depending on the state. A caveat in the regression
analysis arises from the definition of the gravimetric fine mass sort variable. Because fine mass
measurement can be missing when OC measurements are not, setting gravimetric fine mass
concentration to OC (from TORR) when fine mass is missing or less than OC retains more OC
measurements in the analysis. Regressions retaining OC when OC > PM2.5 are denoted by a in
Tables 1 and 2. In general, both data processing approaches gave similar results, except for
Wyoming where results from both approaches are shown. High OC at the Yellowstone (during
the 1988 Yellowstone fires) coincided with missing PM2.5. Incorporating these data gives a
larger regression slope, and therefore increased OC apportionment to wildland fire. Also,
additional OC measurements were necessary for sufficient group 20 OC measurements for
Arizona sites to meet the minimum annual data requirement.
STATE WILDLAND FIRE OC GROUP 90
AZ
CA
CO
UT
WY
WY
(1000 Acres
Burned )
121
276
47
128
240
240
%
(µg/m3)
WILDLAND
FIRE
(µg/m3)
NONWILDFIRE
(µg/m3)
1.7
3.3
1.5
1.5
2.0
2.8
0.2
1.0
0.3
0.2
0.9
1.5
12
30
20
13
45
54
1.5
2.3
1.2
1.3
1.1
1.3
%
88
70
80
87
55
46 a
Table 2. OC apportionment for wildland fire and background components by state.
Time lines of annual group 90 OC apportionment to wildland fire are shown for California,
Colorado, and Wyoming in Figures 5, 6 and 7, respectively. The background, or non-wildland
fire component, is give by the regression intercept and remains constant from year to year.
Implicit assumptions in the regression model are background OC contributions do not have large
inter-annual variability, and the wildland fire contribution explains most of the observed
variability in group 90 OC. Figures 5, 6 and 7 show the annual variability in the wildland fire
OC contribution, ranging from a few percent during low fire years to over 80% during the 1988
Yellowstone fires in Wyoming. The non-wildland fire OC component can originate from
biogenic emissions, prescribed burns, or other anthropogenic OC sources. It is interesting to
note the background OC component in California, 2400 ng m-3, is approximately twice that of
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the interior western states. This may be due to aggressive prescribed burn practices and large
scale agricultural burning in California.
This analysis strongly suggests wildland fires have a significant, and in some years dominant,
contribution to group 90 OC measured at many western U.S. IMPROVE sites. Due to
uncertainty in the regression approach use here, we do not propose the derived apportionments
are suitable for regulatory purposes. It may be possible to reduce the uncertainty associated with
apportionments based on monitoring data. Possible modifications are:
1. Reclassification of monitoring site clusters.
2. Use of more highly resolved spatial and temporal fire and monitoring data.
3. Incorporating smoke transport patterns.
4. Using fire emissions rather than acres burned.
5. Using other chemical species available in IMPROVE monitoring data, or
developing specific smoke tracers.
The value of fire apportionment derived from monitoring data is its independence from many
assumptions used in air quality models, such as particle precursor transformation and dispersion.
Apportionment techniques described here provide a useful and necessary tool for air quality
model validation.
OC Apportionment
California -Yosemite, Lassen
6000
OC (ng/m3)
5000
4000
Wildfire
3000
Background
2000
1000
19
88
19
89
19
90
19
91
19
92
19
93
19
94
19
95
19
96
19
97
0
Year
Figure 5. Wildland fire and background group 90 OC components at IMPROVE monitoring
sites in California from regression model.
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2000
1800
1600
1400
1200
1000
800
600
400
200
0
Wildfire
Background
19
88
19
89
19
90
19
91
19
92
19
93
19
94
19
95
19
96
19
97
OC (ng/m3)
OC Apportionment
Colorado - MEVE, WEMI, GRSA, ROMO
Year
Figure 6. Wildland fire and background group 90 OC components at IMPROVE monitoring
sites in Colorado from regression model.
8000
7000
6000
5000
4000
3000
2000
1000
0
Wildfire
Background
19
88
19
89
19
90
19
91
19
92
19
93
19
94
19
95
19
96
19
97
OC (ng/m3)
OC Apportionment
Wyoming -Yellowstone, Bridger
Year
Figure 7. Wildland fire and background group 90 OC components at IMPROVE monitoring
sites in Wyoming from regression model. The apportionment shown results from
a regression slope of 3.82ng m-3/1000acres burned/yr.
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ASSESSING THE IMPACT OF PERSCRIBED FIRE
The above discussion estimates impacts on western visibility from wildfire. While this is
significant, of potentially greater concern, especially for regulators, is the role of prescribed fire
and agricultural burning. The argument can always be made that wildfire is natural – of course,
because of human manipulation of the landscape there are many flaws in the argument, but
prescribed fire and agricultural burning require specific human involvement and decisionmaking. For example, as a result of efforts to suppress fires, the annual acreage consumed by
wildfires in the lower 48 states dropped from 40 to 50 million acres a year in the early 1930s to
range from about 3-5 million acres in the past three decades. Among the consequences of this
order of magnitude difference, are unhealthy forests and unnatural fuel buildups. For example,
“…the Forest Service has identified 89 million acres of National Forest System land that have a
moderate to high risk of catastrophic fire.” Table 3 illustrates the trajectory of change in the use
of prescribed fire as a tool to reduce wildfire hazard by reducing fuel buildup. While not the only
means of treating fuel buildup, prescribed fire accounts for well over 90% of the acres in Table
3. Furthermore, the use of prescribed fire to improve habitat for threatened species or to restore
healthy ecosystems adds even more acreage to prescribed fire. Current planning calls for the
number of prescribed fire treated acres to grow into the 3 million acre per year by 2005.
Year
1993
1994
1995
1996
1997
1998
1999
USDA Forest Service
385
384
570
617
1,097
1,489
1,412
Department of the Interior
368
334
348
298
503
620
765
Table 3. Acres (in thousands) treated of fuel reduction by federal agencies. The vast majority of
these acres are treated with the use prescribed fire. Source: Managing the Impact of
Wildfires on Communities and the Environment: A Report to the President In
Response to the Wildfires of 2000. September 8, 2000 http://www.fs.fed.us/fire/
Coupled with the reduced but continuing use of agricultural burning in the western states, it is
clear that this added loading of smoke has potential to deteriorate ambient air quality and set
back regional haze visibility goals. Addressing this concern the EPA in 1998 issued an Interim
Policy on Wildland and Prescribed fire (U.S. EPA. Interim Air Quality Policy on Wildland and
Prescribed Fire, April 23,1998. 43 pages. Office of Air Quality Planning and Standards.
Available from the OAR Policy and Guidance Metarecord. http://www.epa.gov
/ttn/oarpg/t1/memoranda/firefnl.pdf)
The draft policy recognizes that linkages exist between wildfire and prescribed fire and that, for
the various reasons stated above, encouraging the latter to reduce the former is a national policy
goal. EPA in this policy draft even goes so far as to suggests that ecologically conducted
prescribed fire smoke which contribute to a violation of ambient air quality standards (or other
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regulatory programs), might be exempted under certain circumstances. Among those is the
presence of an approved “Smoke Management Program (SMP).” Smoke Management Programs
“…establish a basic framework of procedures and requirements for managing smoke from fires
managed for resource benefits and are typically developed by States/Tribes with cooperation and
participation by wildland owners/managers.”
The basic components of a Smoke Management Plan include programs, policy and procedures
that provide for:
• Authorization to Burn;
• Minimizing Air Pollutant Emissions, including:
• Evaluating costs, benefits and environmental impacts of using fire as a land
management tool, including the use of prescriptive criteria that are measurable and
will guide selection of appropriate management actions in response to wildland fires
and prescribed burning;
• Collaborating with State/Tribal air quality managers (air regulators) to achieve goals
of: (a) allowing fire to function in its natural role in the wildlands, and (b) protecting
public health, visibility and regional haze by minimizing smoke impacts;
• Developing mechanisms to notify air quality managers of (1) plans to significantly
increase their future use of fire for resource management, (2) air quality impacts of
fire, and (3) appropriate steps to mitigate those impacts, including appropriate
alternative treatments.
• Smoke Management Components of Burn Plans:
• Actions to minimize fire emissions;
1) Evaluate Smoke Dispersion
• Public Notification and Exposure Reduction Procedures
• Air Quality Monitoring
• Public Education and Awareness
• Surveillance and Enforcement
• Program Evaluation
• Optional Air Quality Protection (for example creating special protection zones or buffers
around wildland/urban interface areas, non-attainment areas, or Class I areas.)
At the very least, land managers will need to pay greater attention to smoke in the future than
they have in the past. The technical ability to forecast smoke production, transport, diffusion, and
its influence on regional visibility needs to improve. The current emphasis of smoke
management is to design and implement smoke management plans that minimize the impact of
smoke on sensitive areas. The strategy is to avoid sensitive areas when possible, pick
meteorological conditions that disperse and dilute smoke and also burn with the intent to
minimize the rate of emissions. However, minimizing emissions isn’t always consistent with
other fire management goals, such as keeping the fire under control. Fire suppression is not
consistent with complete combustion or oxidation of all the fuels.
Achieving these goals in a systematic and predictable way is a daunting problem. The
current strategy used by the federal land management community is the exercising of models to
choose conditions/criteria for achieving the above-mentioned goals. Fire Management Tools
Online is an excellent United States Forest Service (USFS) Internet site, which can be reached at
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(http://www.rarc.org/smoke), where various “tools” can be explored and downloaded for use in
fire management decisions. The models, to some degree, are redundant and few have been
validated to a point of understanding the uncertainty or accuracy of predictions. The system of
models attempts to predict impact, the evolution of fire, amount of material consumed, resulting
emissions, and the transport and dispersion of emissions, and finally the expected ultimate effect
or impact of those emissions.
In terms of these models to accurately assess the effect of fire emissions on regulated health
and welfare issues there are many recognized shortcomings of the existing approach, some more
consequential than others. Some important issues are:
•
Model predictions are only as good as emission estimates. Predicting emissions (gas and
particle fire products) from the many phases of a prescribed fire (pyrolysis and gas and
solid phase oxidation processes) may not only be difficult but also may be impossible.
The complex chemical processes involve the breakdown and evolution of thousands of
organic molecules. Also fuel types and conditions vary and therefore predicting the
evolution of fire is difficult.
•
Current models focus on near field (≅100 km) effects; while impacts on PM2.5
concentrations in urban areas or visibility degradation in class I areas may be occurring at
distances significantly greater than 100 km.
•
Optical properties of smoke in general and more importantly as a function of burn
material and oxidation characteristics are not well understood. Optical absorption, which
is a function of how complete material is oxidized, is many more times effective at
reducing visibility than is the same mass that only scatters light. Current models do not
address in any way the optical anomalies of smoke nor can absorption be measured with
accuracy greater than about 2.
One of the unfortunate consequences of the current strategy is its inability to assess, after the
fact, the actual smoke impact on sensitive areas such as class I areas where visibility is protected
or an urban community that must be responsive to fine particulate standards. There is a need to
not only design good fire management practice, as it relates to air quality, but also to assess
whether those strategies are successful.
There are many sources of organic particulate matter including emissions from combustion
of biomass, gas burning automobiles, heavy and light duty diesels, and food cooking. However,
if an urban area violates a PM2.5 standard because of increases in organic material or a class I
area does not meet regional haze goals, it would be easy to conclude that increased smoke
emissions were the culprit. Thus, it is absolutely essential that monitoring plans be implemented
with the ability to differentiate between carbon from smoke and all other carbon – most
importantly carbon from mobile sources.
In a recent project, supported by the Joint Fire Sciences Program, Technically Advance Smoke
Estimation Procedures (TASET,) we recommended nine specific research activities to improve
the capability of managing smoke from prescribed burning. In brief these included the
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following:
1) Fire community participation in Regional Air Quality Modeling Consortia calling for
land managers to take a more active role in developing and evaluating air quality modeling;
2) National Smoke and Visibility Conference calling for a scientific gathering to asses the
state of knowledge on smoke and visibility;
3) National Smoke Emissions Data Structure or Database System to establish a nationally
uniform emissions reporting system;
4) Remote Sensing for Fuels and Fire Area Emissions Inventories to improve and evaluate
current satellite products for operational application;
5) Fire Gaming System a simplified planning tool for use by regulators to track wildfire, as
well as planned and accomplished prescribed, and agricultural burning;
6) Develop and evaluate a “Smoke Management Version” of the regulatory ‘approved”
CalMet/CalPuff model system;
7) Implement a national screening model, such as the Simple Approach Smoke Estimation
Model (SASEM) for application to smoke planning;
8) On-site Fire Emissions measurement tools so that accurate measurement of smoke
emissions can be made;
9) Tools to determine smoke contributions to visibility impairment.
PROPOSED RESEARCH TOPICS FOR FURTHER INVESTIGATION OF WILDLAND
FIRE & VISIBILITY.
An improved assessment of wildland and prescribed fire requires an understanding of:
• temporal fire emission rates of both primary particles and gases, as a function of
ecosystem type, fuels and fire type;
• transport, diffusion, deposition and chemical conversion of emitted aerosols both in the
near (less than 10 km.), and the far field, and;
•
the optical properties of the resulting smoke haze mixture to determine specific
contributions from wildfire, prescribed fire and agricultural burning to visibility
impairment
Developing a self-consistent reliable assessment methodology for smoke management is a
multiple year effort that will evolve in the coming decades. However, in discussions with smoke
managers in the Federal Land Manager (FLM) community four areas of research and
development have been identified that will contribute significantly to improving existing
assessment tools in the next three to five years.
1) The attribution of smoke to PM2.5 and visibility at points that are 100 km or more distant
from the prescribed and/or wildfire are essential for meeting the requirements of the new
PM2.5 standard and proposed regional haze rules. Attribution of smoke to PM2.5 and
visibility can only be achieved using monitoring techniques. We propose to implement
newly developed measurement methodologies designed specifically to measure “markers”
that will allow for attribution of carbon (elemental and organic) to wood smoke derived
emissions.
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2) Because dispersion model predictions are only as good as the emission estimates that go into
them we propose to develop an instrumentation package having the capability to measure,
with known accuracy, the smoke flux emitted from various fire activities. Having accurate
flux measurements will serve as inputs to dispersion models as well as “ground” truth data
for emission models such as the Emission Production Model (EPM), the BEHAVE Fire
Behavior Prediction and Fuel Modeling System, the First Order Fire Effects Model
(FOFEM), and CONSUME.
3) Assessing the visibility impacts of smoke emission requires knowledge of the optical
characteristics of smoke. The ability to accurately measure atmospheric absorption is
essential for estimating the visibility effects of smoke. (Current techniques have error factors
greater than 2). Smoke particle scattering albedos, particle size distributions, and
microstructure (internal mixing characteristics) are all important for the accurate modeling of
smoke optical properties. We propose to develop and/or refine instrumentation to estimate
atmospheric absorption with known accuracy and precision. The goal would be to make
absorption measurements with 10% accuracy.
4) This past year (2000) has provided an unprecedented opportunity to estimate the impact of
forest fire smoke on regional visibility. Through November 15, 2000, 90,674 fires have
burned 6, 507, 926 acres in the lower 48 states. This is roughly 2 times the annual average
acreage for the past 30 years. A unique opportunity arises because in 2000, the IMPROVE
visibility monitoring network under took a significant expansion of monitoring sites, nearly
doubling the number of sites in the rural United States where twice weekly samples of
speciated PM2.5 are being collected. In addition, 2000 saw the initiation of a real time
geographic information system, the GEOMAC web site (http://geomac.usgs.gov/) that
demonstrated the capability to couple GIS technology with satellite data collection. Figure 8
shows the results of the fire season as of November 3, 2000 as plotted by the GEOMAC
team. The goal of this task will be to utilize NASA, NESDIS and other satellite products to:
1) identify the locations of large fires;
2) fire emissions models to estimate aerosol production from them;
3)
satellite imagery to qualitatively and quantitatively estimate the location and
concentration contributions from fires to regional haze, and;
4)
IMPROVE data to validate the satellite and modeling estimates with on-theground measurements.
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Figure 8. Map showing locations and causes of the wildfires during the fire season of 2000,
until November 3, 2000. Map taken from the GEOMAC web site (see text)
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REFERENCES
Chi, C.T., Horn, D.A., Reznik, R.B., Zanders, D.L., Opferkuch, R.E., Nyers, J.M., Pierovich,
J.M., Lavdoa, L.G., McMahon, C.K., Nelson, R.M., Johansen, R.W., Ryan, P.W., “Source
Assessment: Prescribed Burning, State of the Art,” EPA-600/2-79-019h, U.S. Environmental
Protection Agency, Office of Research and Development, Washington, D.C. 20460, 1979.
Fine, P. 1998, Personal Communication.
Fuller, K.A., Malm, W.C., Kreidenweis, S.M., Effects of mixing on extinction by carbonaceous
particles, J. of Geophys. Res., accepted for publication 1999.
Graves, Henry Report of the Forester 1913, Washington GPO, 1913, p 16.
Hannigan, M.P. Mutagenic Particulate Matter in Air Pollutant Souce Emissions and in Ambient
Air, Ph.D. Thesis, Department of Environmental Engineering and Science, California
Institute of Technology, 1997
Hawthorne, S.B., Miller, D.J., Barkley, R.M., Krieger, M.S. Identification of methoxylated
phenols as candidate tracers for atmospheric wood smoke pollution, Environmental Science
and Technology, 22, 1988, pp. 1191-1196.
Hawthorne, S.B., Krieger, M.S., Miller, D.J., Mathiason, M.B. Collection and quantitation of
methoxylated phenol tracers for atmospheric pollution from residential wood stoves,
Environmental Science and Technology, 23, 1989, pp. 470-475.
Hildemann, L.M., Mazurek, M.A., Cass, G.R., Quantitative characterization of urban sources of
organic aerosol by high-resolution gas chromatography, Environ. Sci. Technol., 25, pp. 13111325, 1991.
Hildemann, L.M., Cass, G.R., Markowski, G.R., A dilution stack sampler for collection of
organic aerosol emissions: design, characterization and field tests, Aerosol Science and
Technology, 10, pp. 193-204, 1989.
Komarek, E. V., “Principles of Fire Ecology and Fire Management in Relation to the Alaskan
Environment,” in C.W. Slaughter et al., eds, “Fire in the Northern Environment: A
Symposium”, U.S. Forest Service, 1971, p. 15.
MacCleery et al.?
Malm,W.C., Sisler, J.F, Pitchford, M.L., Scruggs, M., Ames, R., Copeland, S., Gebhart, K.A.,
Day, D. E. IMPROVE (Interagency Monitoring of Protected Visual Environments):
Spatial and Seasonal Patterns and Temporal Variability of Haze and its Constituents in
the United States: Report III, Colorado State University, ISSN: 0737-5352-47, 2000.
Petterson, J. 2000, Personal Communication.
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Pyne, Stephen J., Fire in America, a cultural history of wildland and rural fire, University of
Washington Press, Seattle, 1997.
Radke, L.F., Hegg, D.A., Lyons, J.H., Brock, C.A., Hobbs, P.V., Weiss, R., Rasmussen, R.,
Airborne measurements on smokes from biomass burning, Aerosols and Climate, Deepak
Publishing, 1988, pp 411-422.
Ramdahl, T., Retene – a molecular marker for wood combustion in ambient air, Nature, 306,
1983, pp. 580-582.
Rogge , W.F. Molecular Tracers for Sources of Atmospheric Carbon Particles: Measurements
and Model Predictions, Ph.D. Thesis, Department of Environmental Science and
Engineering, California Institute of Technology, 1993.
Sandberg, D.V., Pierovich, J.M., Fox, D.G., Ross, E.W., “Effects of Fire on Air,” General
Technical Report WO-9, U.S. Department of Agricultur, U.S. Forest Service, Washington,
D.C., 1979
Schauer J.J., Source Contributions to Atmopsheric Organic Compound Concentrations:
Emissions Measurements and Model Predictions, Ph.D. Thesis, Department of Science and
Engineering, California Institute of Technology, 1998a.
Schauer, J.J, 1998b, Personal Communication.
Simoneit B.R.T, Rogge, W.F., Mazurek, M.A., Standley, L.J., Hildemann, L.M., Cass, G.R.,
Lignin pyrolysis products, lignans, and resin acids as specific tracers of plant classes in
emissions from biomass combustion, Environmental Science and Technology, 27, 1993, pp.
2533-2541.
Standley, L.J. and Simoneit, B.R.T., Characterization of extractable plant wax, resin, and
thermally matured components in smoke particles from prescribed burns, Environmental
Science and Technology, 21, 1987, pp. 163-169.
Standley, L.J. and Simoniet, B.R.T., Resin diterpenoids as tracers for biomass combustion, J.
Atmospheric Chemistry, 18, 1994, pp. 1-15.
U.S. Environmental Protection Agency, “Prescribed Burning Background Document and
technical Information Document for Best Available Control Measures,” EPA-450/2-92-003,
U.S. EPA, Library Services Office (MD-35), Research Triangle Park, NC, 1992.
Ward, D.E. and Hardy, C.C., Smoke emissions from wildland fires, Environment International,
17, pp. 117-134, 1991.
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Organization of the Grand Canyon Visibility
Transport Commission
COMMISSION
PUBLIC ADVISORY
COMMITTEE
OPERATIONS
COMMITTEE
ALTERNATIVES
ASSESSMENT
COMMITTEE
MODELING
TECHNICAL
COMMITTEES
MET
EMISSIONS
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COMMUNICATIONS
COMMITTEE
AEROSOL &
VISIBILITY
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Historical Fire Regimes of Western U.S. Forests
James K. Agee
Professor of Forest Ecology, College of Forest Resources (Box 352100)
University of Washington, Seattle, WA, USA 98195
jagee@u.washington.edu
Introduction
Historical fire regimes were important disturbance processes in western forest ecosystems.
While quite variable over space and time, they served to alter species composition, nutrient
cycling, and other ecosystem structure and function attributes. They acted as a significant
"coarse filter" directing the natural diversity of the ecosystem (Hunter 1990). Accompanying the
variable environments of western forests were a similar variety of fire regimes, defined by
different combinations of fire frequency, intensity, extent, season, and synergism (Agee 1993,
1999; Figure 1). For simplicity, these fire regimes are classified into three types: low
(nonlethal), mixed or moderate, and high (lethal). Each has characteristic signatures on
landscape composition and pattern (Figure 2).
Historical Fire Regimes
The low-severity fire regime was characterized by very frequent but relatively benign individual
fires. The fire environment of low-severity fire regimes is typically warm and dry over an
extended snow-free season. Although the long-term effect of such fires was quite significant, the
individual fire appeared to have little effect on the system: fires occurring every 5-15 years killed
trees when they were small and had little effect on larger, fire-tolerant trees. Patches were often
opened in these forests by other disturbance agents, such as bark beetles killed a small patch of
old pines. Fire would then come in, burn up the branches, logs, and snags over several
"rotations" of fire, and create a new, fuel-limited spot where tree regeneration could be
successful. A typical pine forest would appear to be a mix of many small patches, but mostly
mature forest, with an open understory and limited tree density and basal area (15 m2 ha-1;
perhaps 70-80 trees ha-1). Reconstruction of these historical fires by tree-ring and fire scar
analysis indicates that once burned, a fire would rarely reburn in less than three years (Heyerdahl
1997).
The moderate-severity fire regime was characterized by a complex mix of low- moderate-, and
high-severity fire, which is why it is also known as the "mixed" severity fire regime. Most
forests in this fire regime are higher elevation than those in the low-severity fire regime, with
shorter fire seasons and usually cool summers. Average fire return interval ranges of 25-75 years
were common. Over space and time, fires in these forests had intermediate patch sizes, with
some underburn patches such as in the low-severity fire regime; some thinning patches, where
basal area was reduced by removing smaller or less fire-tolerant species from the stand; and
some stand replacement burning, where all to most of the trees were killed. The result was a
complex set of stands, some even-aged, some multi-aged, and the most edge (Figure 2).
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Alpine
Whitebark pine
Subalpine fir
Moderate Severity
Alpine
High Severity
Mountain hemlock
Red fir
Grand fir
Weather Driven
Moderate Severity
White fir
Douglas-fir
Douglas-fir
Ponderosa pine
Low Severity
Ponderosa pine
Fuel Driven
Oak
Gradients of Forest Types
Gradients of Fire Regimes
Figure 1. An example of gradients in forest types in the Pacific Northwest and associated fire
regimes (from Agee 1999).
Low-Severity Fire Regime
Moderate-Severity Fire Regime
High-Severity Fire Reg
Low-Severity Patch
Moderate-Severity Patch
High-Severity Patch
Figure 2. Landscape patterns of fire regimes. Black dots in low-severity fire regimes are very
old patches of trees likely killed by insects and decomposed by fire, and gray dots are emerging
small-sized stands with less defined edge next to mature stands. The moderate-severity fire
regime is a complex mix of larger patches of the three severity levels, while the high-severity fire
regime has large, stand replacement patches (from Agee 1998).
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The high-severity fire regime was characterized by large patches of stand replacement burning,
occurring usually at intervals exceeding 75-100 years. A typical event may have covered
thousands of hectares. Large even-aged stands resulted from this fire regime, except in subalpine
forests where regeneration was spotty and often delayed by harsh environmental conditions and
lack of seed source. Some stands were much older than the average, acting as refugia (e.g.,
Camp et al. 1997) in mountainous landscapes, or by random chance of not burning in flatter
boreal forests (Bessie and Johnson 1995).
Implications of Changes in Historical Fire Regimes
Fire suppression during the 20th century has had the most significant effects in the low-severity
fire regimes, with less impact in the moderate-severity fire regimes and least in the high-severity
fire regimes. This is largely due to the removal of between 5 and 10 fire "cycles" in the lowseverity fire regimes, in contrast to the suppression of many fewer events in the other fire
regimes. Fire potential has changed in three definable ways: surface fire intensity has increased
due to increased fuels; torching potential, or the ability of a fire to move into the crowns, has
increased due to vertical "fuel ladders" and low height to live crown; and the ability of fire to
move through the crown has increased due to higher crown bulk densities (Graham et al. 1999,
Agee et al. 2000, Edmonds et al. 2000.
The solutions to these problems depend on (a) what forest types that need treatment the most,
and (b) what type of treatment should be applied in a high priority forest type. In general, the
low-severity fire regimes are highest priority. Not only are the fuel buildups and changes due to
fire suppression most significant here, but the result of treatment will be a forest with higher
resistance to stand replacement fire. The species in these forest types (often ponderosa pine or
Douglas-fir) are quite resistant to low intensity fires, in contrast to typical species in the highseverity fire regimes (subalpine fir, lodgepole pine, etc.). Treatment of the latter types that
reduce fireline intensity may be ineffective at preventing stand replacement fires because these
are thin-barked species, so almost any fire will be stand replacement in nature. Moderateseverity fire regimes are an intermediate priority.
The key to successful forest restoration for fire purposes is to reduce potential fire behavior
while leaving fire-resistant vegetation. The order of treatment (Agee et al. 2000) should be to (a)
reduce surface fire behavior, (b) reduce torching potential, and (c) reduce crown fire spread
potential. This can be accomplished through a variety of treatments, with prescribed fire and
mechanical thinning the most likely tools of choice. Reduction in surface fuels and increases in
height to live crown should be a first priority, with reductions in canopy closure as a second
priority. Leaving large trees and removing smaller ones is the means to achieving the fire hazard
goals: essentially a low thinning.
How much of a landscape should be treated, and should riparian zones be excluded from
treatment? The practical limits on treatment will be socially and economically limited. We do
not have answers yet to define a threshold for a "firesafe" landscape, but it is likely to be
something in excess of a third of the landscape. Fuelbreak-type treatments, with burning tying
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into them, may be one way of reducing landscape fire risk. In riparian zones of low- to
moderate-severity fire regimes, fire return intervals are statistically similar (Olson 2000) to
upland forests. While riparian zones may not be a focus of restoration efforts, they needn't
necessarily be excluded from treatment (such as letting prescribed fires creep down into the
riparian zone, as opposed to sealing fire out with firebreaks).
Historical fire regimes can also be useful in defining appropriate targets for ecosystem structure.
For example, in low-severity fire regimes, coarse woody debris (CWD) loads were very limited
due to frequent fire. Highest average CWD loads occurred in moderate-severity fire regimes,
and high-severity fire regimes had boom-and-bust CWD dynamics. Standards for CWD
retention should be scaled to the historical fire regime.
Conclusions
Fire will be in our future whether we like it or not. We can choose the type of fire we want to
deal with, and significantly reduce wildfire damage in low-severity fire regimes by targeting
restoration efforts to change potential fire behavior and effects. Historical fire regimes provide a
means of defining past ecosystem changes due to fire suppression, and also forest structures that
will remain sustainable in the face of inevitable wildfires.
References
Agee, J.K. 1993. Fire ecology of Pacific Northwest forests. Island Press. Washington, D.C. 493 p.
Agee, J.K. 1998. The landscape ecology of western forest fire regimes. Northwest Science 72 (special issue): 2434.
Agee, J.K. 1999. Fire effects on landscape fragmentation in interior West forests. pp. 43-60 In: Rochelle, J.A., L.A.
Lehmann, and J. Wisniewski (eds) Forest fragmentation: wildlife and management implications. Brill
Publishing. Boston, MA.
Agee, J.K., B. Bahro, M.A. Finney, P.N. Omi, D.B. Sapsis, C.N. Skinner, J.W. van Wagtendonk, and C.P.
Weatherspoon. 2000. The use of shaded fuelbreaks in landscape fire management. Forest Ecology and
Management 127: 55-66.
Bessie, W.C. and E.A. Johnson. 1995. The relative importance of fuels and weather on fire behavior in subalpine
forests. Ecology 76: 747-762.
Camp, A., C.D. Oliver, P. Hessburg, and R. Everett. 1997. Predicting late-successional refugia pre-dating European
settlement in the Wenatchee Mountains. Forest Ecology and Management 95: 63-77.
Edmonds, R.L., J.K. Agee, and R.I. Gara. 2000. Forest health and protection. McGraw-Hill Book Co. New York.
630 p.
Graham, R.T., A.E. Harvey, T.B. Jain, and J.R. Tonn. 1999. The effects of thinning and similar stand treatments on
fire behavior in western forests. USDA Forest Service General Technical Report PNW-GTR-463. 27 p.
Heyerdahl, E.K. 1997. Spatial and temporal variation in historical fire regimes of the Blue Mountains, Oregon and
Washington: the influence of climate. Ph.D. dissertation. University of Washington, Seattle. 24 p.
Hunter, M.L. 1990. Wildlife, forests, and forestry. Prentice-Hall. Englewood Cliffs, NJ. 370 p.
Olson, D.L. 2000. Fire in riparian zones: a comparison of historical fire occurrence in riparian and upslope forests
on the Blue Mountains and southern Cascades of Oregon. M.S. thesis, University of Washington, Seattle.
274 p.
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Contributions of Native American Firing Practices to Historic Fire Regimes
Philip N. Omi, Professor and Director
Western Forest Fire Research Center
Colorado State University
Philip.Omi@colostate.edu
Invited Presentation to NBTT Senior Staffers Workshop, January 24, 2001, Denver, CO
The 7 million acres burned during the fires of 2000 provided a wake-up call for many Americans, but we
delude ourselves if we think that this past fire season represented the ultimate catastrophe. The recent
fires have only reinforced the notion that we live on a fire continent that experienced repeated widespread
burning in the past; the fires of 2000 portend future repeat episodes until and unless fuels are managed on
the nation’s wildlands.
In the past, both natural and anthropogenic ignition sources contributed to widespread fires in north
America. The purpose of this paper is to summarize what is known about the extent to which intentional
Native American firings contributed to continental burning in the past. To provide a context for this
summary, I will first share some results from current research that provide perspective on the extent of
our knowledge about continental burning prior to European settlement. Next I will discuss the difficulties
of partitioning the burning that occurred previously into natural and human causes, despite our
considerable knowledge of Native American firing practices. I will conclude with some opinions on the
extent to which our knowledge of Native American firing practices can be incorporated into present-day
emission regulations.
Knowledge about continental burning prior to European settlement
Figure 1 summarizes findings from a study of current knowledge regarding north American fire history
studies during the period 1710-1799 (after Martinson and Omi, in press). The figure indicates the
geographic location of fire history studies that met our screening criteria. Although the studies
represented in the figure document the widespread, but clumped fire frequencies during the century
preceding settlement in north America, no attempt was made in any of the studies to separate natural
versus human igntions. Cross-dated trees rings, charcoal or pollen sediments, and stand reconstructions
(standard fire history dating techniques) document the occurrence of fire but are mute about the cause of
burning. Still we can be quite confident that a portion of the fire history studies represented in Figure 1
included Native American firings. The literature on Indian burning is extensive (e.g., see Barrett 1980,
Lewis 1983, Gruell 1985). Further, the estimates in Figure 1 are conservative, relying solely on fires that
burned with sufficient intensity to create a fire scar in the tree ring record. Fires in grasslands and shrub
fields are not included, although Native Americans may have ignited these vegetation types more than
elsewhere. Note that the period selected (1710-1799) is arbitrary--the pre-settlement time frame extends
far into the past, though our knowledge decreases the farther back we go.
How do we know that anthropogenic fires are represented by the studies in Figure 1? Our knowledge of
native firings stems from a variety of sources, including textbooks and technical papers, websites, early
newspapers, journals of early explorers, and oral accounts handed down through generations of American
Indians. Naturally, the farther back we go, the more we must rely on indirect evidence. Even though the
study of anthropogenic fire has expanded in recent years, our ignorance always will be greater than our
accumulated knowledge, especially as related to how flames first captivated the human imagination, then
aroused utilitarian instincts (Omi 1990).
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Figure 1. Observed mean fire-free periods (MFPP) from North American fire history studies spanning
1710-1799 (after Martinson and Omi in press).
• Observed mean
fire-free periods
(MFFP)
Point
MFFP (yr)
<25
4 Range: 8 to 825 yr
4 Median: 33 yr
25-99
100-250
>250
Further, an abundant literature base documents the many reasons that Native Americans used fire. Native
Americans have used fire in all geographic regions of the United States (Stewart 1951) since migration
from Asia 15,000-30,000 years ago (Phillips 1985). Of course, the incidence of fire in north America
predates the Native American experience (Omi 1990). Lightning has occurred and ignited vegetation for
millions of years (Stewart 1951). Thus Native Americans discovered, but did not invent, wildland fires
(Pyne 1982).
Table 1 lists documented reasons that American Indians used fire. Still, evidence for the purposeful
setting of fires by American Indians is difficult to document precisely (Williams 2000). Our knowledge
of Native American firing practices prior to settlement is thus based on informed speculation relying on
fire history studies and knowledge of how aborigines used fire in their daily lives. Also, this knowledge
is evolutionary, in that we now generally believe that Indians burned far more areas than considered
previously (Williams 2000).
Table 1. Documented reasons for Native American fires on the landscape (after Williams 1994)
•
•
•
•
•
•
•
•
•
•
•
Hunting
Crop management
Improve growth/yield
Fire proof areas
Insect collection
Pest management
Warfare
Economic extortion
Clearing areas for travel
Felling trees
Clearing riparian areas
Native burning and natural backgrounds
One of the questions that you as a task force face relates to the extent that historic burning by natives
should “count” as natural background. I don’t know the answer to this complicated question other than to
say that in certain areas (e.g., lower elevation grasslands, and to a lesser extent, forests) aboriginal fires
added to what might be considered natural background levels. But I would add that numerous
methodological issues complicate your task. For example, if you intend to rely on the historical record of
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burning by Native Americans in a particular area or vegetation, you will need to rely on information
whose accuracy is not verifiable. One plausible approach might require you to partition the origins of
historic fires into natural and anthropogenic causes and develop fuel consumption and emission factors
for those respective fire sets. You will probably need to interpolate spatially and temporally, and possibly
develop probability distributions for the likelihood of indicators exceeding certain tolerances (e.g., days
exceeding visibility standards) in the past, present, and future. Even if you are modestly successful in
addressing these issues you will need to satisfy yourselves that the base era selected (e.g., 18th century)
provides the appropriate standard for comparison.
Conclusions and Recommendations
A growing knowledge base of fire history studies and anthropological evidence substantiates the assertion
that Native Americans contributed to historic fire regimes, often significantly. Further we generally
acknowledge that removal of natives to reservations removed a potent ignition source from many areas,
particularly some lower severity fire regimes. Moreover, the fires of 2000 suggest that areas traditionally
classified as lower severity fire regimes are now burning with greater vigor due to higher fuel loads
resulting from a century of fire exclusion, causing higher resource damage and raising economic costs.
Smoke regulators need to acknowledge that Indian burning added to the historic fires caused by lightning
and other natural sources, and somehow need to account for this added increment in setting acceptable
visibility standards for an area. This accounting must acknowledge that fuel loadings have increased
since pre-settlement times due to aggressive fire exclusion, including withdrawal of native firings.
However, we need to be honest with each other and the American public, recognizing that we will never
know enough to estimate the historical extent of native firing, including spatial and temporal variations.
Estimating the extent of native burning in the past is less important than SENSIBLE regulation (and
monitoring) of future emissions
Literature Cited
Barrett, Stephen W. 1980 "Indians and Fire." Western Wildlands, Vol. 6, #3 (Spring): 17-21.
Gruell, G.E.1985. Indian Fires in the Interior West: A Widespread Influence. Pp. 68-74 in James E.
Lotan, et al. (technical coordinators) Proceedings-- Symposium and Workshop on Wilderness Fire:
Missoula, Montana, November 15-18, 1983. General Technical Report INT-182. Ogden, UT: USDA
Forest Service, Intermountain Forest and Range Experiment Station.
Lewis, H.T. 1983. Why Indians Burned: Specific Versus General Reasons." Pp. 75-80 in James E. Lotan,
et al. (technical coordinators) Proceedings--Symposium and Workshop on Wilderness Fire: Missoula,
Montana, November, 15-18, 1983. General Technical Report INT-182. Ogden, UT: USDA Forest
Service, Intermountain Forest and Range Experiment Station.
Martinson, E.J. and P.N. Omi. In press. Pre-settlement fire regimes of North America: a geographic
model based on quantitative research synthesis. In: Proc. Fire Conference 2000: The first national
congress on fire ecology, prevention, and management, Nov. 27-Dec. 1, 2000. San Diego, CA.
Omi, P.N. 1990. History of wildland burning in America from an air quality perspective. Air and Waste
Management Association. 83rd Ann. Meeting, Pittsburgh, PA, June 24-29, 1990, Reprint 90-172.5, 7 p.
Phillips, C.B. 1985. The relevance of past Indian fires to current management programs. In: Proc. Symp.
and Workshop on Wilderness Fires. Gen. Tech. Rep. INT-182, USDA Forest Service, Ogden, pp 87-92.
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Pyne. S.J. 1982. Fire in America: A Cultural History of Wildland and Rural Fire. Princeton, NJ: Princeton
University Press.
Williams, G.W. 1994. References on the American Indian Use of Fire in Ecosystems. 1994.
http://wings.buffalo.edu/anthropology/Documents/firebib.txt
______ 2000. Introduction to aboriginal fire use in North America. USDA Forest Service. Fire
Management Today 60(3): 8-12.
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Fire and Agriculture: Historical Perspective to the Present
Dr. Robert R. Quinn
Professor of Geography, and Meteorologist
Eastern Washington University, Cheney, WA 99004
rquinn@ewu.edu
Invited presentation to NBTT Senior Staffers Workshop, January 24, 2001, Denver, CO
My primary area of expertise is that of a meteorologist that has worked in the operational area of
smoke management in the burning of blue grass in Eastern Washington for over a decade. I am
also a professor of Geography in the Geography-Anthropology Department and have a thirty
year professional perspective on climate and agriculture in the Pacific Northwest. For the last 4
years I have been a member of the Agricultural Air Quality Task Force for the USDA. Other
presenters have far more expertise in the historical perspective of fire practices and landscape
response in the west but I will attempt to focus on the agricultural perspective and the historical
problems of defining a "natural background" baseline.
The first myth that must be cast aside is that in pre-settlement, or pre-mechanized agricultural
times in the west there was some pristine level of minimal smoke and haze that was only
occasionally disturbed by lightning fires or other natural conflagrations a result of drought
periods. As Mr. Omi has indicated and a growing area of research has verified Native American
firing practices were widespread in all areas of the west. These practices in most cases were
purposeful and repeated on a regular basis to maximize a great number of resource amenities
which included game and crop management. These practices altered the species composition
and age structure of a variety of ecotones in almost every climate region of the west.
The use of fire in pre-settlement time also begs the question of what practices fall in to the
category of agricultural management. If agricultural land management practices are defined in
the modern context of tillage than most of the Native American firing practices would be a
simple land treatment practice to facilitate hunting and gathering. I prefer to take a more general
view of agriculture " the raising of crops and livestock" which does not necessitate tillage and
would include a variety of land management practices (including burning) which maximize the
growth and regeneration of native crops.
Robert Boyd in "Indians, Fire, and the Land in the Pacific Northwest" OSU Press 1999, 301 pgs,
has compiled a variety of sources of research on regional Native American firing practices and I
would briefly summarize several of the examples:
1. In the Willamette valley of Oregon the Kalapuya were the sole inhabitants in pre-contact
times and their population is estimated at 14,000 to 9000 individuals in the period of the late
1700's through the early 1800's until several episodes of malaria decimated the population to a
level of 600 by 1841 (Boyd, 1999). Many early accounts document the late summer fall burning
of the valley in an organized fashion by the Kalapuya. The burning was for a variety of
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resources utilization purposes including the management of camas, tarweed, wapato, berries,
hazel nuts, acorns and an amazingly centralized deer drive. The burning was systematic and
large enough that it established a fire induced prairie grassland over millions of acres of the
valley as well as an oak transition zone in foothills and valley margins that survives in patches to
this day. The valley averages between 40 and 50 inches of rain a year and if left to a
nonagricultural and non burning treatment would eventually establish a mixed coniferous forest
(Douglas fir) as is occurring in many patches today.
2. The Spokan occupied the eastern portion of the Columbia plateau and a portion of the
intermontane area of northeastern Washington and Northern Idaho. They practiced a seasonal
and regional burning strategy for a variety of resources that moved from the lower to higher
elevations across a variety of ecotones (Ross 1999) These included land treatment strategies for
forest clearing and access, productivity management for camas, cattail, balsam root, huckleberry,
and pine nuts. Even in the early 20th century when the surviving members were located on the
reservation selective burning by (women) elders continued into the modern era and often
seriptiously in an era of fire suppression.
As emigrant settlement progressed rapidly in the first half of the 19th century tilled agriculture
progressed rapidly across already suitable fire managed landscapes of the Willamette valley,
Puget Sound, and Walla Walla valley. Some traditional crops brought by emigrants such as corn
did not do well but wheat and barley thrived. During the California gold rush Willamette valley
wheat could be sold for six dollars a bushel (Schwantes 1996). By the late 1880's the dry land
soils of the Palouse of eastern Washington were under the plough and from 1890 to 1910
Spokane grew from 30,000 to 100,000 (Meinig 1968). Despite horse drawn tillage and
harvesting it is estimated that over 90% of the Palouse of eastern Washington came under the
plough from a period of 1875 to 1895. Mechanized agriculture appeared in the early 1900's and
by the 1920's had largely replaced mules and horses. Barbed wire, irrigation agriculture,
diversified cropping of fruits, berries, and commercial pasture crops all supported an ethic of fire
suppression but also developed a practical private ownership mind set of cooperative institutions
for fire suppression. While the drought era of the 1920's and thirties saw a number of great
forest conflagrations in the west it might be argued that fire as a land management tool was not
as commonly practiced on agricultural land until fire suppression technology had improved
significantly.
The modern era of agriculture based on sophisticated mechanized technology and petro-chemical
based fertilizers and herbicides and pesticides has dominated the western landscape since the late
1940's. A curious dichotomy has evolved in that fire again has emerged as an agricultural
management tool in dry land wheat stubble control, rice residue control, grass seed stimulation,
orchard waste disposal, and occasional frost sensitive citrus management. All of these practices
have increasing air pollution consequences and have been regulated and or eliminated on a
region by region basis. On the other hand forestry management as other presenters have
demonstrated has had a strong "smoky the bear" fire suppression ethic from the 1940's to the
early 1990's to the degree that has changed forest species composition and fuel loading
characteristics. Now a return to the prescribed burn to mimic nature (Native American?) fire
practices is a renewed part of institutional forest management policy to restore healthy stand and
species composition.
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Agricultural burning is valid management tool although undesired by many due to air quality
considerations. There are over 295 million acres of cropland harvested in the United States
today. Burning is used on approximately 3% (8.9 million acres). Of the 600 million acres of
grazing land in the continental United States about 18 million acres is burned annually. An
additional 2 million acres of CRP and 2.5 million acres of irrigation ditches and "edge" land is
burned each year (Odum report,1996). Even today some of these figures are estimates because
many states do not track agricultural burned acreage. Developing accurate emission factors for
various crops based on field measurements and empirical models is still an inexact science.
Quantifying PM 2.5 contributions from agricultural sources will reflect inherent errors in both
estimates of crop acreage's burned and model errors for non point source emission factors.
The problem of arriving at some baseline estimate of natural background PM2.5 as well has
other VOC contributions to haze is fraught with complex historical issues as well as current
measurement and model errors. One approach is to pick a period as representative of post
industrial resource management and try to estimate historic contributions based on current
knowledge of resource sources with all of the errors in current measurements and emission
factors. Another approach is simply to use the current developing Class 1 area PM2.5
measurements and selectively use a subset in each region that satisfies some agreed criterion to
mimic natural background. Another subset would be an area that is reasonably devoid of modern
agricultural, urban, and industrial sources such as an onshore flow from the Pacific in the
Olympic rain forest. Frankly I agree with Dr. Omi that sensible regulation of future emissions is
more important than estimating historical emissions.
Literature Cited
Barbour, Michael G. 2000 " North American Terrrestrial Vegetation. " 2nd ed Cambridge
University Press, 708 pgs
Boyd, Robert. 1999 "Indians, Fire, and the Land in The Pacific Northwest. " OSU Press, 314
pgs.
Boyd, Robert. 1999 "Strategies of Indian Burning in the Willamette Valley." in Indians, Fire, and
the Land in the Pacific Northwest, pgs 94-138, OSU Press.
Dryness, C. T. 1973 "Natural Vegetation of Oregon and Washington." USDA Forest Service
Technical Report PNW-8 , 406 pgs.
Meing, D.W. 1968 "The Great Columbia Plain." University of Washington Press. 576 pgs.
Ross, John. "Proto-historical and Historical Spokan Prescribed Burning and Stewardship of
Resource Areas." pgs 277-291 in Indians Fire and The land in The Pacific Northwest, OSU Press
314 pgs 1999.
Scwantes, Carlos Arnold, "The Pacific Northwest, an Interpretive History" 412 pgs.
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Fire’s Contribution to Natural Visibility - Senior Staff Workshop
January 24-25, 2001 – Denver, Colorado
Stakeholder Position Papers
Agricultural Burning
Agricultural Position Paper
Native American Cultural Burning
Natural Sources in Natural Background
A Case for Historical Fire Patterns as a Basis for “Natural Background” for
Implementing the Regional Haze Rule
A Conceptual Approach for Estimating Fire’s Contribution to Natural
Visibility
Role of Fire in Natural Background
Comments on Contributions of Fire to Natural Conditions
An Industry Perspective
Forest Industry Position on Natural Background
Fire’s Contribution to Natural Background
Natural Wildland Fire Emissions: A Historical Perspective
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Agricultural Burning
Mark Wagoner
Alfalfa Seed Farmer
January 2001
Fire has been a part of farming for thousands of years. In the United States, native Americans
used fire to clear vegetation and stimulate grass forage production for domesticated animals such as
horses and undomesticated animals such as buffalo.
Modern day farmers use fire to produce seed crops; fight weeds, diseases, and insects; manage
residues to aid in seeding and harvest and in the maintenance of irrigation canals.
Much of the land used to produce crops here in the Western United States experienced the natural
effects of fire long before it was put to the plow. For example, Whitman County, Washington, was once a
lush carpet of native grasses that burned roughly one out of every ten years due to lighting strikes in the
dry summer time. Today Whitman County is the largest wheat-producing county in the US with over one
million acres in production. In 1999, in this county, farmers burned 50,000 acres of stubble for disease or
weed control. This represented 5% of the total acreage in production, less than has been documented to
burn naturally prior to cultivation.
Agricultural burning is highly regulated by the Washington State government and requires prior
approval by a “Best Management Practice” guideline set by the Department of Ecology. These “BMPs”
state that a farmer has to document a valid reason to burn, pay a fee, and receive a permit. Once approved
by authorities, the burn can only take place on specific days that allow for good smoke dispersion. These
burn days are set by the Department of Ecology, after their review of MM5 weather data from the
University of Washington Department of Atmospheric Sciences. In Washington State, there has been a
conscious effort by farmers to move some agricultural burns from the summer to the spring in order to
have better ventilation and smoke dispersion.
Prescribed burning of agricultural land can have less impact on visibility than the natural smoke
levels present prior to the land being farmed. There are many historical accounts of grassland fires in the
West by early explorers and pioneers. In 1836, the naturalist John Kirk Townsend, who was camped
along the Columbia River fifteen miles downstream from the Umatilla River recorded the spectacular
sight of a huge fire on the north side of the Columbia. George McClellan, of Civil War fame, noted the
great wild fires when he was part of the Isaac Stevens survey party in 1854.
Precisely because we can pick the season, day and time of agricultural burns, using modern
meteorological data, our impacts can be very minor on Class I Parks and wilderness areas of the West. In
this era of economic doldrums and increasing regulations on agriculture more restrictions could spell
disaster for some farms. It would be much better to classify agricultural burning as a natural occurrence
and develop an enhanced smoke management program, over the entire West, to deal with the visibility
issue. This way we can not only protect our magnificent scenic vistas of the West, but also protect public
health, and maintain an economically healthy agricultural community.
Submitted by:
Mark Wagoner, alfalfa seed farmer, Touchet, WA 99360
Member: Fire Emissions Joint Forum; WA Department of Ecology Ag Burning Task Force
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Agricultural Position Paper
Manuel Cunha, Jr.
President of the Nisei Farmers League
December 21, 2000
As a member of the USDA Air Quality Task Force and President of the Nisei Farmers League, an
organization that represents approximately one thousand growers, packers, processors, dehydrators, farm
labor contractors and flower growers that are based throughout the San Joaquin Valley, I am writing to
suggest how your group should approach the issue of agricultural burning and its impact on visibility in
Class I areas.
When deciding how to classify fire emissions from agricultural land, keep in mind that the emissions
from these lands today are probably less in most areas than the fire emissions from these lands several
hundred years ago. The land that is now agricultural was usually more heavily vegetated and burned
naturally on a regular basis. Some of this land was also burned regularly by Native Americans.
Any recommendations made by the Fire Emissions Joint Forum to the Western Regional Air Partnership
should also be consistent with the proposed Air Quality Policy on Agricultural Burning. The United
States Department of Agriculture Air Quality Task Force developed these recommendations and I have
attached that document for reference. Below is a quote from Section II (Purpose) of that document:
The Agricultural Burning Policy recommendations have been prepared in response to
implementing provisions of the Clean Air Act (CAA) and the concerns of agricultural
producers to retain the valid use of fire as a management tool in support of agricultural
production. Fire has continued to be a management tool used by private and public land
owners/producers for agricultural production and land management and, therefore, has a
long-standing context in the planning and regulation requirements of Air Quality
Agencies or Agricultural Burning Managers.
This Agricultural Burn Policy addresses two public policy goals: (1) to allow the use of
fire as an accepted management practice, consistent with good science, to maintain
agricultural production on agricultural land; and, (2) to protect public health and welfare
by mitigating the impacts of air pollution emissions on air quality and visibility.
In closing, I would like to emphasize that the USDA Air Quality Task Force recommendation for the Air
Quality Policy on Agricultural Burning is intended to be a national policy on agricultural burning. It was
developed by EPA representatives, state regulatory representatives, researchers, and agricultural growers.
The proposed policy would assist farmers and agencies across the Nation in developing agricultural burn
programs that achieve the goals of the Clean Air Act.
If you have any questions, please contact my office at (559) 251-8468.
Submitted to Ms. Darla J. Potter, Fire Emissions Joint Forum - Natural Background Task Team Co-Chair
Nisei Farmers League, 1775 N. Fine, Fresno, CA 93727
Phone: (559) 251-8468 Fax: (559) 251-8430
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Natural Sources in Natural Background
Grand Canyon Trust
December 2000
The mission of the Grand Canyon Trust is to protect and restore the canyon country of the Colorado
Plateau—its spectacular landscapes, flowing rivers, clean air, diversity of plants and animals, and areas of
beauty and solitude. This includes restoring and maintaining the ecological integrity of the biological
communities that comprise this area. Ecological integrity includes a critical range of variability in
biodiversity, ecological processes and structures, regional and historical context, and sustainable cultural
practices.
Fire has been a keystone ecological process in most Western vegetation types for millennia. The
frequency, severity, and type of vegetation burned in natural fire regimes varies greatly between
vegetation types. Past land management practices including livestock grazing and fire suppression have
altered natural fire regimes and therefore also fuel accumulations and types. Restoration and maintenance
of ecological integrity—upon which native biological diversity and all human communities ultimately
depend—is of utmost importance and will require that emissions management facilitates restoration and
subsequent maintenance of natural fire regimes and fuel conditions in wildland and wildland/urban
interface ecosystems.
When restoring and maintaining natural fire regimes, every effort should be made to minimize emissions,
and new, low-emission methods for vegetation disposal should be explored and promoted. However,
because emissions from natural sources are critically important for restoring ecological integrity,
minimizing emissions from anthropogenic sources is also important. To assure that both natural and
anthropogenic needs are met, a ratio based on the two source categories should be established, based on
the following:
1. Emissions resulting from restoration and maintenance of natural fire regimes should be considered
"natural sources," and therefore play a central role in determining "natural background". Natural
background should include: the estimated emissions resulting from the re-establishment of natural fire
regimes (before current unnatural fuel loading); unplanned wildfires; and prescribed burning intended
to reduce fuel loads and/or mimic natural fire regimes.
2. Emissions management should prioritize natural sources and the restoration and maintenance of
natural fire regimes. To this end, total annual emissions resulting from all natural sources should not
exceed those projected to result from natural fire regime historical emissions.
3. Every effort should be made to minimize emissions exposures resulting from planned “Natural
Sources” such as prescribed fires. “Smoke Management Plans” should play an integral role in this
process, and alternative, and low-impact / low-emissions vegetation disposal methods should be
encouraged.
4. Besides those “Natural Sources” described above, all other sources (commodity, agricultural, etc.)
shall be considered “Anthropogenic Sources” in wildland and wildland/urban interface ecosystems.
5. All smoke should be managed, and reductions in anthropogenic sources (commodity, agriculture,
etc.) must be an integral part of any program attempting to manage natural sources.
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A Case for Historical Fire Patterns
as a Basis for “Natural Background”
for Implementing the Regional Haze Rule
Robert Wilkosz
Idaho Department of Environmental Quality
January 2001
For a concept to have lasting value, it needs to share a consistent logic within the processes for
which it is used or developed. Thus, “natural background” must be consistent with National
Wildland Fire Policy and Regional Haze protocols.
Wildland managers defend their management of public landscapes based on ecological (science
derived) principals; and, the use of fire in their management schemes is also thus defended. The
heart of is logic is that any portion of the landscape is specifically suited (or limited) toward
specific vegetal end points (or management options) according to its specific physical qualities
(soil types, climate conditions). Because of these specific qualities, fire can be predicted to
return to any given landscape on a predictable regime. Any such fire then would be “natural”
and its emissions would be “natural.” Such natural fire impacts would thus be considered nondetrimental and consistent with evolutionary forces under which all plant and animal life are
“naturally” adapted.
The Regional Haze Rule seeks to protect the visibility of our nation’s most prized natural areas,
national parks and wilderness areas, by returning the visible resource of those areas to a “natural”
state – a state where human produced detriments to visibility are reduced to “natural
background.”
To merge the two recognized programs of Wildland Fire Policy and Visibility Protection, two
main principals logically become prominent:
1. All natural landscapes have a natural fire regime or interval; and that regime produces
smoke emissions which are knowable and part of healthy, normal life conditions.
2. Even in protecting our most prized natural areas, we will allow smoke intrusions and
visibility impairment from that smoke as long as it is natural in intensity, duration, etc.
Because the above two principals are ecologically derived and thus evolutionarily based, the
logical basis for “natural background” must be historical rates of smoke emission.
The historical basis for “natural background” is consistent with the basis and methods with
which ecologists and wildland managers determine the natural plant community composition.
This is the basis under which wildland managers determine appropriate plant and animal species
management, the sustainability of those communities, etc. To back away from this basis when
we integrate air quality protection with land management, would make any such integration
suspect and illogical.
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Considerable public resources have been expended already across the past few decades to
elucidate critical, factual knowledge about natural ecosystems: species composition and
diversity, carrying capacity, weather patterns, fire return intervals, etc. necessary for science
based natural resource management. All these myriad scientific facts were derived based on the
study of historical data derived from plant tissue and geological formations. The valid
assumption was that historical data would contain the facts that allow us to elucidate natural
conditions. And, we strive to know proper natural conditions, as those conditions are most
appropriate to wild areas and provide the best probability for sustaining key evolutionarily
derived qualities.
Because we already have considerable knowledge about the historic landscape in the form of
plant species composition and fire return intervals, it should then be a straightforward process to
derive historic rates of smoke emissions from those landscapes. Coupled with best available
historic meteorological data it should also be straight forward to reasonably predict smoke
intrusion rates into Class I areas. This is the only scientifically defensible method for estimating
“natural background” smoke effects on visibility in these areas.
It is true that there is considerable variability in the number and location of fires across the broad
landscape on any given year and among years – all driven by natural variations in weather
patterns and vegetal ground cover. But science has always been comfortable with variation and
willing to concede the non-linearity of nature. We can still do a reasonable job of predicting
“natural background” and designing reasonable management goals considering that variability.
Historic “natural background” needs to be calculated from the total land area in question,
regardless of its current use or ownership. And yes, when basing “natural background” on
historical patterns it means that some of that historical smoke emission came from land that is
now under agricultural production. Those current land owners have as much right to bank the
historical smoke emissions from that ground for their own fire use as the Forest Service or BLM
for their portion of the current landscape. Any process that excludes agriculture ground from its
share of “natural background” will predictably precipitate a political dynamic which will make
all the “scientists” working on this endeavor look foolish.
There is also an inherent fairness in first determining a historic basis for “natural background,”
then managing from that basis. The historic background level once determined can then be
converted to a total acceptable carbon or PM metric (an acceptable smoke currency, if you will).
This acceptable level of smoke impact then becomes the emission budget or cap to work with.
The acceptable impact can then be back calculated spatially to provide allowable natural smoke
emissions for any region. Those regional emission must then divided objectively to all valid
users of fire management techniques, public and private, wildland and agricultural. The smoke
currency could even be traded (bought, sold, banked) to provide maximum flexibility and
opportunity for fire and smoke management.
Any non-objective methods such as linking the description, or metric, of “natural background” to
an implicit land management goal (like, we need more fire) inherently makes the process appear
biased toward those who favor that goal. The description or metric needs to be as objective as
we can make it. The historic basis provides such objectivity.
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A Conceptual Approach for Estimating Fire’s
Contribution to Natural Visibility
Brian Finneran
Oregon Department of Environmental Quality
January 3, 2001
The regional haze rule requires states to determine natural visibility conditions for each Federal Class I
area in the United States, as a means of setting the 2064 “goalpost” for the ultimate objective of the rule.
States must show “reasonable progress” in improving visibility on the most impaired days until natural
visibility conditions are achieved. This position paper proposes one approach for estimating the
contribution of fire to natural visibility.
The national visibility goal of the Clean Air Act is to prevent any future and remedy any existing
visibility impairment from “man-made” (anthropogenic) emission sources. Many forests in the United
States have forest health problems due to years of wildfire suppression, which have altered the natural
role of fire. EPA recognizes this role and the need for increased use of prescribed fire to “mimic” wildfire
in order to help restore forest ecosystems. In the Preamble to the Regional Haze Rule, EPA
acknowledges that states may consider some amount of intentionally ignited fire in the calculation of
natural visibility.
This opens the door for some amount of prescribed fire to be factored into the calculation of “natural
conditions” for each Class I area. There are two possible ways to approach this. One would be to focus
on whether certain types of prescribed fire impacts should be treated as “natural” if they mimic the role of
natural fire. One problem with this approach is being able to distinguish between different types of
prescribed fire impacts in ambient monitoring data. Another problem is the appropriateness of treating
any activity that is essentially manmade as natural. Therefore, a second approach would be to treat all
prescribed fire as man-made, and focus instead on the calculation of natural conditions - specifically the
“natural fire” component - so that it reflects the appropriate role fire should play in each Class I area.
This approach involves basically setting the 2064 “goalpost” for natural conditions at a level that would
allow for increases prescribed fire to occur (and the resulting visibility impacts) without jeopardizing
reasonable progress for improving visibility on the most impaired days.
This paper provides a conceptual look at the second approach, and is outlined in three graphs on the
following page. Graph 1 shows the basic objective of the regional haze rule – setting the baseline for
2000-2004 visibility conditions and the 2064 goalpost (20% worst days), and then making reasonable
progress in improving visibility during the interim. This graph indicates that due to expected increases in
the use of prescribed fire nationally, visibility impacts would likely increase, but that this would have
been accounted for when making the “natural fire” estimate. Graph 2 shows natural conditions to be a
combination of natural fire and natural dust, and that the natural fire component could be based on
historic natural fire cycles and some desired or acceptable level of natural fire. (Note: using strictly
historic natural fire cycles would likely not be appropriate, given the extent of manmade changes to the
landscape, and other reasons). Finally, Graph 3 indicates one example of how a desirable or
“acceptable” level of natural fire might be estimated, based on a hypothetical 15-year natural fire cycle
and average wildfire levels during the baseline period.
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Graph 1 - How to Meet the Regional Haze Rule
“Baseline”
20% Worst Days
“R
eas
on
industry
abl
e
Deciview
mobile
Pro
g
res
s”
“Natural
Conditions”
man-made
dust
Other Nat’l
nat’l dust
wildfire
increased h
aze impacts
Nat’l Fire
pres. fire
2000-2004
2064
Graph 2 - Estimating “Natural Fire” as a component of Natural Conditions
“Natural
Conditions”
•
“Other” Natural (mostly dust) likely
based on current data, NAPAP
report?
•
Natural Fire estimate based on
historic fire cycle, then adjusted to an
“acceptable” level - criteria still to be
determined (see example next slide)
Other Nat’l
Nat’l Fire
2064
Graph 3 - What might be “acceptable” level for Natural Fire
Current
WF
Average wildfire in
2000-2004 baseline
Historic
Fire
Cycle
EXAMPLE: 15-year
(high) fire return
interval
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÷
2
Natural
Fire
20%
worst days
Role of Fire in Natural Background
Greg Schaefer
Arch Coal Company
January 2001
Fire has a very important role is land management in the western United States. It is used
as a tool to improve wildlife habitat, reduce high fuel loads that could lead to catastrophic
wildfires and is a necessary tool for agricultural operations. Unfortunately, smoke from fires has
a very significant impact on visibility in the west. Anyone who has flown over the west during
the peak of wildfire season has seen this impact first hand. The critical question is then how to
handle smoke emissions in the overall context of a visibility management program.
From an equity standpoint, there has been significant progress by the regulated
community to reduce overall visibility impairing emissions over the past number of years. Coalfired power plants are highly regulated, and it is anticipated that further emission reductions will
continue to be achieved over time. Sulfur content of transportation fuels has been significantly
lowered, and operations such as mines have stringent regulatory requirements to manage fugitive
dust emissions. Each of these factors serve to protect and enhance visibility in Class I Areas.
The Regional Haze Rule, either Section 309 or Section 308, requires states to prevent
degradation of visibility on the 20% best days, and to significantly improve visibility on the 20%
worst days. The critical function in the determination of compliance with this goal is the
delineation of the source of the visibility impairing emissions. As an example, in some years fire
emissions, whether natural or prescribed, can significantly impact visibility. In the analysis of
the monitoring records, it could be wrongfully assumed that visibility is not improving and that
additional controls should be required of the regulated community. To provide anecdotal
evidence of this issue, the Powder River Basin of Wyoming probably has the highest density of
particulate matter monitors in the United States. On one monitoring day, particulate
concentrations were exceptionally high and the regulatory agency called to raise concern over
the value and to make sure that we were adhering to our permit requirements to control fugitive
dust emissions. In evaluating the cause, it was found that the monitor was running on the same
day as the Highway Department was conducting chip and seal operations within an 1/8 mile of
the monitor. In another instance, there was an extended period of high PM concentrations that
raised concern. In this case, the reason was the Yellowstone fires.
Fairness and equity demand that the success of one sector in meeting emission reduction
goals is not masked or eliminated by another sector. It is critical that fire, whether natural or
anthropogenic be accounted for separately from industrial/business sources.
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COMMENTS ON CONTRIBUTIONS OF FIRE TO
NATURAL CONDITIONS
C.V. Mathai
Pinnacle West / Arizona Public Service
December 21, 2000
As the recommendation of the Grand Canyon Visibility Transport Commission (Commission)
concluded, wildland “plays a significant role in visibility on the Plateau.”1 With respect to
prescribed burning, the Commission clearly recognized that regardless of the amount of money
spent to address visibility impairment in the other source sectors, visibility gains could be
overshadowed by prescribed burning.2 Therefore, if policymakers are truly concerned about
visibility impairment, it is important that the impact of fire, both natural and man-caused be clearly
understood and addressed with the same diligence that has been focused on other source sectors.
With respect to fires and their relationship to natural background, it is important to keep in mind
how the Commission defined these issues in its recommendations. Prescribed burning was
defined as follows, “Fires in wildland areas that are allowed to burn under prescribed conditions.
The "prescription" reflects ecosystem management goals, ability to control the fire, and air
quality concerns.” A prescribed natural fire is defined as “a fire started by natural processes
(usually lightning) and allowed to burn as long as it meets prescribed fire conditions.”3 In both
cases, there is an element of human action or inaction. Moreover, as was recently the case at Los
Alamos, there are examples where prescribed burns become wildfires. The case could also be
made that many naturally started wildfires are the result of human actions or inaction. As the
Commission pointed out, past management activities on the part of land managers has resulted in
a significant build-up of fuel loads. Consequently, the same as emissions from industrial
facilities, emissions from many wildland fires can be considered manmade and regulated as the
same as emissions from manmade facilities.
There are three major issues related to the contributions of wildfires and controlled burns to
natural background conditions: 1) What are “natural background conditions”? 2) Which fires are
natural? 3) How do we quantify their contributions to natural conditions?
For the first question, it has been suggested by some that “natural conditions” mean the
conditions that would occur today in the absence of man-made emissions. This avoids issues
such as the changes in land use that have occurred since the U.S. became significantly populated,
which have resulted in changes in the area of burnable vegetation. The highly forested
conditions that existed when Columbus arrived are no longer achievable, and thus do not
constitute sensible “natural conditions.” Since we can’t control global pollution and especially
transport of pollutants from Mexico and Canada, we have to accept an “elevated” natural
background.
1
The Grand Canyon Visibility Transport Commission, Recommendation for Improving Vistas, June 10, 1996, pp.
ii-iii.
2
Ibid.; 3 Ibid.
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Relating to natural component of fires, several questions need to be addressed, including:
•
Should a fire contribution be considered “natural” even though most of the fuel has
accumulated over the years because of a fire suppression policy? Or should part of the
emissions be considered as man-made?
•
Is a controlled burn man-made when it reduces the opportunity for a future natural fire? Or
should it be considered a natural fire that just got started sooner?
•
Should the wind-blown dust (ashes and soil) emissions that often appear after a fire has
occurred be considered as delayed emissions from the fire and be classified as natural or man
made in the same way as the original fire was classified?
Measurements in remote locations can quantify the global background, but give no insight into
the effects of fires on a more regional and local scale. Figuring out how to assign their
contributions to natural background will be challenging because fires are: a) limited to areas
where there is burnable vegetation, b) occur when the fuel is dry, c) are triggered somewhat
randomly, d) last for short periods, and e) currently available “emissions factors” are quite crude.
In order to account for some of these factors, at the very least, assignments of natural background
contributions due to fire will have to vary with location (perhaps on a grid, such as used for
modeling) and should vary with season (or, even, month). Single background values for the
entire West for a full year, as presented by NAPAP, are not appropriate. It will require a major
effort, combining measurements and modeling, to come up with estimates of fire contributions to
natural background at a sufficient level of detail required to deal with visibility in Class I areas.
I-126
An Industry Perspective
Kenneth E. Evans
Manager of Air Quality
Phelps Dodge Corporation
January 2001
It is generally acknowledged that air emissions from both natural and anthropogenic sources
contribute to visibility reduction and impairment in Federal Class I wilderness areas in the
United States. To some extent, industrial sources contribute to visibility reduction in these areas,
but, arguably, a large proportion of visibility degradation is due to emissions from wildland and
agricultural burning. With respect to industrial sources, the New Source Review (NSR) /
Prevention of Significant Deterioration (PSD) program was established, in part, by the USEPA
to limit the degradation of visibility in the Class I areas. Given that certain types of fire are a
part of the natural environment and some are not, it is fair and equitable that some types of fire
be subject to regulation in a manner similar to that experienced by most industrial sources. It is
neither fair nor equitable to assume that emissions from all fire—both natural and
anthropogenic—can be totally accounted as “background” in the Class I areas or that they do not
contribute at all to background conditions.
The views presented below represent a generic industry viewpoint on the objectives, goals, and
proposed methodologies of the Natural Background Task Team (NBTT). This paper does not
purport to represent the view of any specific industry or company, including the author’s
employer, and it is anticipated that industry, in general, might have varying positions. These
views are offered to provide diversity in perspective as the goals and methodologies of the
NBTT are being considered.
•
The objectives and process of the NBTT should be supported. The stated objectives of
the NBTT are 1) to develop a method to classify fires and their subsequent emissions into
two visibility classifications, natural or anthropogenic, 2) to define fire’s contribution to
natural visibility conditions for Federal Class I areas in the West, and 3) to develop source
apportionment criteria which lead directly to the methods and process needed for tracking
those emissions. The classification process includes a means for classifying wildland and
agricultural land burns as either “natural” or “anthropogenic.” It is imperative that such a
classification system be developed in order to distinguish between those burns that should be
subject to smoke management and those with emissions that should be considered
background. The ramifications are great with respect to responsibility for improving
visibility within Class I areas, and the responsibility must be both fair and equitable.
•
There should be a technical and justifiable means for quantifying the occurrence and
extent of fire in the natural environment minus anthropogenic influence. Emissions
from any fire that can credibly be accounted as offsetting what would be expected to occur
naturally should be considered as background. Emissions from any other fire should not be
considered background and should be subject to smoke management. This should include
I-127
even those fires that are allowed by law or treaty if they are not offsetting the natural role of
fire; the law or treaty may allow the burn but should not preclude smoke management.
•
Every fire should be classified according to what portion of the fire is offsetting what
would be expected to occur naturally, and what is not, in order to determine the extent
to which smoke management should be applied. For example, a prescribed wildland fire
may be used to reduce fuel accumulation due to fire suppression practices, leading to the
conclusion that emission are considered background. However, if slash pile combustion is
included in the prescribed burn, an appropriate proportion of emissions attributed to the
burning of the piles should not be considered background and should be subject to smoke
management.
•
It is appropriate to identify selective burn types and to establish de minimis emission
thresholds, below which emissions would not be considered in the classification system.
The permitting of industrial sources includes such de minimis values to avoid the permitting
of relatively insignificant sources and activities, and such practices are reasonable for
wildland and agricultural land burns.
I-128
Forest Industry Position on Natural Background
Note: This is not a formal position, but some concerns that have been raised.
Scott Kuehn
Plum Creek Timber
January 3, 2001
•
There needs to be a fixed and achievable Visibility Goal. Yes, historically Natural Background
varied from year to year, or even decade to decade, but an average for a given period needs to be set.
There must be a defined and fixed target; other wise there will always be this “fuzzy” moving goal in
the future.
•
With 70 years of fire suppression in the west, fuels have built up to a historic level, which are not
natural. How can treating these fuels be called “Natural” and included in the Natural Background?
Only those fuels that have built up during a historic fire interval rate should be called Natural.
•
Federal Land Managers talk about an accelerated fire program to bring these out of balance lands
back into a more natural balance. There will be 20-30 years (probably 20-60 years, if not more)
where emissions will exceed the glide path toward the visibility goal in order to get these lands back
into balance. There will be increased emissions in the near term to get these lands back into balance
in the long term. In the real world of Industry, environmental and health organizations and their
lawyers watching out for their constituents as well as the general public, will any amount of public
relations and public education make a difference when we are creating health impacts? Not until
every one in the fire community has taken a call from a mom or dad at 3:00 in the morning who had
to take their child into the emergency room because of the smoke will they understand that it is not
just public education and awareness. It’s also health effects and their impacts. There needs to be a
parallel increase in the use of alternatives to fire, and improved smoke and emission reduction
techniques along with the accelerated fire program.
INCREASE IN ECOSYSTEM BURNING
FLM EMISSIONS
EMISSIONS
GLID
E PA
TH
VISIBILITY GOAL
NATURAL BACKGROUND
MUST HAVE A CORRESPONDING
DECREASE IN EMISSIONS
TODAY
2030
YEAR
FEDERAL LAND MANAGERS EMISSIONS
I-129
2064
•
In order to meet the visibility goal, all emissions exceeding the glide path must be offset by
corresponding reductions in emissions below the glide path. That is, every ton of emission over the
glide path must be offset by a reduction of at least one ton of emission below the glide path. If the
glide path was close to a horizontal line, it would be a 1:1 ratio, i.e. one ton of increased emissions
offset by one ton of reduction. Since these emission reductions aren’t until 2030 and beyond,
emissions will have to be reduced exponentially. One ton of emission increase in 2015, will have to
be offset by up to two tons in 2050. As FLM increase emissions, other sources will have to reduce
their emissions. Prescribed burning is only one piece of the Regional Haze pie. Stationary, mobile
and other prescribed burning sources will have to reduce their emissions to offset the FLM increased
emissions of the visibility goal is to be met.
Is this realistic in the next 60 years? Will the public, Forest Industry, Non-industrial private tree
farms, etc be willing to let FLM increase emissions while they have to reduce theirs? Will the public
be willing to tolerate 20-30 years of increased health impacts so that their great-great grandchildren
can have better visibility? There are 15 potential presidential administration changes until the
visibility goal is to be met. Will all these administrations stay on course for the next 60 years?
•
If Federal Land Managers (FLM) treat these acres with fire and try to bring them back into a more
historic balance, How and When will these additional acres be treated?
Let’s first discuss How: In Western Montana, FLM will quickly run out of areas to treat with fire
that need little, if any type of pre-treatment, i.e. areas that can be treated with little or no fuel
reduction. Once these easy areas are treated, then FLM will have to start treating areas with higher
fuel loading. These can be treated as is, but with heavy mortality rates. These areas will need to have
fuel reduction treatments before fire can be re-introduced, unless a scorched earth is the prescription.
With current environmental laws, it takes 1-2 years of paper work to even think about doing any
mechanical treatments. Using mechanical treatments to reduce fuels means loggers using chain saws,
harvesters, skidders, and killing trees. Once chain saws and loggers are involved, appeals are filed at
even a greater rate, which extends the time line even more. You can not do the amount of fuel
reduction that is needed by hand, heavy equipment and chain saws will be needed.
50% of the employees in the Forest Service are eligible for retirement in 5 years. An estimated 3,500
new employees are scheduled to be hired in the fire management program. There will be a point in
the not too distant future, where we have a well-trained work force with little or no experience. The
public does not remember all of the good things you have done, they only remember your last
mistake.
Now lets discuss When: During the past fifteen years in Montana, an average of 79,000 acres have
been treated per year. This includes all of the major open burners. From a low of 54,000 acres in
1994 to a high of 108,000 acres in 1989. In 1999, during the fall burning season (9/1- through 11/30)
there was a total of 91 possible burn days. In western Montana 60 of those days had some type of
burning restriction. During the winter months in Montana (12/1 through 2/28) burning is limited to
Essential Winter Burning, i.e. you can’t burn any unit in the winter that you could burn at other times
of the year. This leaves spring and summer. Last spring was the first year we implemented our new
spring burning program which is identical to our very successful fall program. This turned out to be a
slow period and not a good test due to the federal moratorium on prescribed burning.
I-130
Talking with our meteorologist and others in Montana’s prescribed fire field, we all feel we could
double our treated acres in Montana and still maintain a viable program, i.e. meeting all local, state
and federal laws and not turning the public against prescribed burning. By doubling the acreage, the
increase in burning would have to be accomplished in the spring and summer. The winter is basically
out and the fall can only handle a small increase.
The goal of FLM in Montana is to perpetually treat 175,000 acres per year starting in 2005. Since
1991, the Forest Service has steadily increased their burning, from 18,040 acres in 1991 to 41,388
acres in 1999. If by 2005 FLM do accomplish 175,000 acres per year, this is in addition to the other
major open burners for a total of 224,000 acres per year. Almost a three fold increase in what all the
major open burners are currently treating each year. This does not include the small private wood lot
owners or the agriculture burners. This will not be accomplished without corresponding reduction in
emissions.
I can only speak for Montana and Northern Idaho, but there is only a small window open that is not
being utilized that prescribed burning can accomplished. Inversions in the valley bottoms start in
September and last well into April and May. If prescribed burning is pushed too far and targets and
treated acres become more important than smoke management, the program is doomed.
•
Montana has in its constitution that all Montanans “Have the right to a clean and healthy
environment.” This has yet to be tested in the courts as it relates to air quality and no one knows what
the legal definition of a clean and healthy environment will end up being. My guess is though, it will
be tested in the courts as a result of a prescribed burn.
•
Re-introducing fire into the ecosystem and
reducing the risk of wild fire through
hazard reduction are two completely
separate processes. You can treat the
forest and reduce the fire hazard using
various methods, one of which is fire. The
re-introduction of fire in the ecosystem is
a management tool to meet a specific
management goal. These tools can be
used in conjunction with each other, or
they can also be used independently to
reduce the risk of wild fire. Reintroduction of fire and hazard reduction
are two separate management goals and do
not necessarily need to be used together.
•
Is this what the public will think about
when we talk to them about prescribed
burning?
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I-132
FIRE’S CONTRIBUTION TO NATURAL BACKGROUND
USDA Forest Service
January 2001
BACKGROUND
Fire suppression activities and some past management practices over the past 100 years have excluded
fire from many short interval fire-adapted ecosystems. In the absence of fire, many of these lands have
become subject to an over-accumulation of shrubs and small trees, diminishing ecosystem diversity,
health, and resiliency and fueling conditions for unnaturally intense fires that threaten communities, air,
soil, water quality, and plant and animal species.
CURRENT SITUATION
In September, the Secretaries of Agriculture and Interior recommended to the President in “Managing the
Impact of Wildfires on Communities and the Environment” the steps necessary to respond to the 2000
wildfire season, reduce the impacts on wildland fire on rural communities, and ensure sufficient
firefighting resources in the future. This document, along with its funding request and the budget
allocation from Congress, initiated the National Fire Plan. The National Fire Plan has five key points:
•
•
•
•
•
Firefighting readiness
Restoring/rehabilitating burned areas
Reducing the risk of fire
Community assistance
Accountability
The National Fire Plan directs over 2 million acres be treated through a combination of prescribed fire
and mechanical treatments. 1.8 million of these acres are federal lands; nearly 400,000 acres are nonfederal lands.
A guiding document to implement the National Fire Plan for the USDA Forest Service, is “Protecting
People and Sustaining Resources in Fire-Adapted Ecosystems: A Cohesive Strategy” (i.e. Strategy). This
Strategy is based on the premise that sustainable resources are predicated on healthy, resilient ecosystems.
In fire-adapted ecosystems, some measure of fire use – at appropriate intensity, frequency, and time of
year – should be included in management strategies intended to protect and sustain watersheds, species,
and other natural resources over the long term. The Strategy is also based on the premise that, within fireadapted ecosystems, fire-maintained forests and grasslands are inherently safer for firefighters and the
public than ecosystems in which fire is excluded.
The focus of the Strategy is on restoring ecosystems that evolved with frequently occurring, low intensity
fires. These fires typically occurred at intervals between 1 to 35 years and served to reduce growth of
brush and other understory vegetation while generally leaving larger, older trees intact.
The Forest Service estimates that total smoke emissions from recent wildfire, wildland fire use
(prescribed natural fire), and prescribed fire are substantially less than the historical amounts of “natural”
fires, but that smoke emissions from wildfires have steadily increased from the 1980’s to the present. We
anticipate that implementing the Cohesive Strategy will reduce wildfire smoke emissions in
approximately 15 years. Even though there will be some increase in smoke from wildland fire use and
prescribed fire, total smoke emissions are predicted to be less than if we did not implement the Cohesive
Strategy.
I-133
COMMITTMENT
Successfully implementing The National Fire Plan through the Cohesive Strategy depends on
collaborating with the Environmental Protection Agency, National Marine Fisheries Service, and the U.S.
Fish and Wildlife Service in addressing long-term impacts, tradeoffs, and issues to air quality, watershed
resilience, species conservation, ecosystem integrity, and public safety as a result of each agency’s
respective policy in the context of fire-adapted ecosystems. Further, successful implementation requires
identifying opportunities for improved coordination between regulatory and land management agencies in
achieving restoration and maintenance objectives to protect people and sustain resources in fire-adapted
ecosystems.
Regional planning, including stakeholders in identifying and assessing values at risk, is an important
component of the Strategy. The Sierra Nevada Ecosystem Management Project and the Interior Columbia
River Basin Management Project are examples of regional-scale planning that address resources at risk
and establish priorities for broad geographic areas. Additionally, the Forest Service has been an active
participant in air partnerships such as the Southern Appalachian Mountains Initiative, the Grand Canyon
Visibility Transport Commission and its implementing body the Western Regional Air Partnership. We
are also actively involved in the “Interagency Monitoring of Protected Visual Environments”
(IMPROVE) program. At some of our IMPROVE sites, we have been monitoring visibility for 20 years.
We have taken seriously our responsibility to prevent any future, and remedy existing, impairment of
visibility resulting from man-made sources of air pollution.
Recommendations from the regional projects listed above are important in our more localized planning
processes, including Land and Resource Management Plan (forest plan) revisions and amendments.
These forest plans will integrate specific concerns and priorities at a watershed or landscape scale within
the context of regional plans and the Forest Service GPRA Strategic Plan. Because of fire’s contribution
to natural background across a variety of geographic scales, it is an issue that must be addressed at all
planning levels.
POSITION
The costs of implementing the restoration and maintenance approaches outlined under the Cohesive
Strategy are high. Yet, fire suppression costs, public resource losses, private property losses, and
environmental damages (including air quality) accruing without treatment are expected to be greater over
time. There are short-term and long-term trade-offs associated in each of these areas. Our position is to
use the best research in fire ecology and fire effects to articulate and demonstrate to society those tradeoffs as well as we can. And our challenge is to then implement, through our planning process, the
treatments (including smoke management) society feels are most acceptable.
Hirami, P.; Hann, W. 2000. Protecting People and Sustaining Resources: Assessment of Natural Levels
of Smoke Emissions in the Western U.S. Presented at California Association for Fire Ecology
(CAFÉ) Conference. San Diego, CA.
Laverty, L.; Williams, J. 2000. Protecting People and Sustaining Resources in Fire-Adapted Ecosystems;
A Cohesive Strategy. The Forest Service Management Response to the General Accounting
Office Report GAO/RCED-99-65. 85 p.
I-134
Stakeholder Position Paper - Fire’s Contribution to Natural Visibility
Natural Wildland Fire Emissions: A Historical Perspective
Bill Leenhouts
U.S. Fish and Wildlife Service
January 2001
Wildland Fire Acreage Burned
160
140
120
100
80
60
40
20
0
Historically, fire was a frequent and major
conterminous U. S. ecological disturbance. In the
preindustrial era (200 - 500 years BP) between 84 206 (0 = 145) million acres burned annually .
Today between 1 - 5 (0 = 3) million acres are burn
annually by wildland fire. Human caused land use
changes (agriculture and urbanization) are
responsible for 50 percent of this10 fold decrease
from the preindustrial era to today. Human land
management decisions (land fragmentation - roads,
irrigation ditches, etc., suppression actions, etc.) are
responsible for the remaining 50 percent decrease
(Leenhouts 1998).
This significant decrease in wildland fire was an ecologically destabilizing influence in many fire adapted
ecosystems: ponderosa pine, lodgepole pine, pinyon/juniper woodlands, and southern pinelands (Ferry et
al. 1995), whitebark pine (Kendall 1995), oak savanna (Henderson and Epstein 1995), pitch pine (Heusser
1979), aspen (Bartos et al. 1991), tallgrass prairie (Collins and Wallace 1990), etc. Hessl and Spackman
(1995) also found that, of the146 threatened, endangered, and rare plant species found in the
conterminous U. S. for which there is conclusive information on fire effects, 135 species benefit from
wildland fire or are found in fire adapted ecosystems.
This significant decrease in wildland fire also significantly decreased natural air pollutants from the
preindustrial era which had the potential to significantly improve human health and welfare. But because
industrial, transportation, and agricultural anthropogenic emissions were increasing during much of the
period when natural air pollutants were decreasing, the effects of this reduction only partially mitigated the
human health and welfare impacts caused by anthropogenic emissions from modern society (Leenhouts
2000).
In 1985 the EPA began including agricultural and fugitive dust in PM-10 emission
inventories, and in 1990 the EPA changed the emission factors for fugitive dust.
Page 1 of 3
Probably no other natural emission source has been reduced more by direct human involvement than
wildland fire.
Any inventory or assessment of natural background wildland fire emissions that does not account for or
include the amount of emissions that would have been produced from natural ignitions (lightning) if human
involvement and intervention (land use changes, land fragmentation, wildland fire suppressing decisions,
etc.) had not occurred is incomplete and flawed.
Two methods for accounting for these “missing” natural emissions are:
•
•
Defining a portion of anthropogenic emissions (e.g., the prescribed fire and managed wildland fire
emissions necessary to restore and sustain desired ecosystem characteristics [Peterson et al. 1998])
as natural .
Determining natural wildland fire emissions by calculating gross nature wildland fire emissions 1 and
subtracting the emissions from anthropogenic wildland fire ignitions sources.
1
Gross natural wildland fire emissions can be modeled for any naturally (lighting) caused
wildland fire by using FARSITE and appropriate data (fuels, weather, topography, etc.) to determine fire
growth through a natural landscape without human intervention or control (i.e., let a lightning caused fire
burn until it is controlled by the weather or natural fuel barriers) .
Page 2 of 3
Stakeholder Position Paper - Fire’s Contribution to Natural Visibility
Literature Cited
Bartos, D. L., W. F. Mueggler, and R. B. Campbell, Jr. 1991. Regeneration of aspen by suckering on
burned sites in western Wyoming. U.S. Department of Agriculture, Forest Service Research
Paper INT-448.
Collins, S. L., and L. L. Wallace, editors. 1990. Fire in North American tallgrass prairies.
University of Oklahoma Press, Norman, Oklahoma, USA.
Ferry, G. W., R. G. Clark, R. E. Montgomery, R. W. Mutch, W. P. Leenhouts, and G. Thomas
Zimmerman. 1995. Altered fire regimes within fire-adapted ecosystems. Pages 222-224 in E.T.
LaRoe, G. S. Farris, C. E. Puckett, P. D. Doran, and M. J. Mac, editors. Our living resources.
U.S. Department of the Interior, National Biological Service, Washington, D.C., USA.
Kendall, K. C. 1995. Whitebark pine: an ecosystem in peril. Pages 228-230 in E.T. LaRoe, G. S.
Farris, C. E. Puckett, P. D. Doran, and M. J. Mac, editors. Our living resources. U.S.
Department of the Interior, National Biological Service, Washington, D.C., USA.
Hessl, A., and S. Spackman. 1995. Effects of fire on threatened and endangered plants: an
annotated bibliography. U.S. Department of Interior, National Biological Service, Information
and Technology Report 2.
Henderson, R. A., and E. J. Epstein. 1995. Oak savannas in Wisconsin. Pages 230-232 in E.T.
LaRoe, G. S. Farris, C. E. Puckett, P. D. Doran, and M. J. Mac, editors. Our living resources.
U.S. Department of the Interior, National Biological Service, Washington, D.C., USA.
Heusser, C. 1979. Vegetational history of the pine barrens. Pages 215-312 in R.T. Forman, editor.
Pine Barrens: ecosystem and landscape. Academic, New York, New York, USA.
Leenhouts, B. 1998. Assessment of biomass burning in the conterminous United States. Conservation
Ecology [online] 2(1): 1. Available from the Internet. URL:
http://www.consecol.org/vol2/iss1/art1.
Leenhouts, B. 2000. A comparison of historic and contemporary wildland fire and anthropogenic
emissions. Fire Conference 2000. November 27 - December 1, 2000. San Diego, Ca. Available
from the Internet. URL: http://fire.r9.fws.gov/ifcc/smoke/fire2000/index.html.
Peterson, J., D. Sandberg, and B. Leenhouts. 1998. Estimating natural emissions from wildland
and prescribed fire. A White Paper for the development of the Interim Air Quality Policy on
Wildland and Prescribed Fires. Environmental Protection Agency, Research Triangle Park, NC.
Page 3 of 3
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I-138
Fire’s Contribution to Natural Visibility - Senior Staff Workshop
January 24-25, 2001 – Denver, Colorado
Participant Information
I-139
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I-140
Participant List
Fire’s Contribution to Natural Visibility - Senior Staff Workshop
Denver, Colorado
January 24-25, 2001
Ann Acheson
USDA Forest Service - Reg. 1
P.O. Box 7669
Missoula, MT 59807
ph 406-329-3493
fax 406-329-3132
aacheson@fs.fed.us
John Beyer
CA Air Quality Coordinator
USDA- NRCS
4974 E. Clinton Way Suite 114
Fresno, CA 93727
ph 559-252-2191
fax 559-252 5483
john.beyer@ca.usda.gov
Steve Arnold
Colorado Dept. of Public Health & Environment
4300 Cherry Creek Drive South
APCD-ADM B1
Denver, CO 80246
ph 303-692-3220
fax 303-782-5493
steve.arnold@state.co.us
Doug Blewitt
AQRM
(Colorado Air Commissioner)
5401 S. Geneva St
Englewood, CO 80111
ph 303-741-8647
doug_n_blewitt@hotmail.com
Lara Autry
USEPA, OAQPS
Emissions, Monitoring & Analysis Division
(MD-14)
Research Triangle Park, NC 27711
ph 919-541-5544
autry.lara@epa.gov
Lyle Carlile
Bureau of Indian Affairs, NIFC
3833 South Development Ave.
Boise, ID 83705
ph 208-387-5640
fax 208-387-5937
Lyle_Carlile@nifc.gov
Mark Beighley
USDA Forest Service
P.O. Box 06090
Washington, DC 20090-6090
ph 202-205-0888
fax 202-205-1272
mbeighley@fs.fed.us
Colleen Cripps
Nevada Division of Environ. Protection
333 W. Nye Lane
Carson City, NV 89701
ph 775-687-4670, x3065
fax 775-687-6396
ccripps@ndep.carson-city.nv.us
Frances Bernards
Division of Air Quality
150 North 1950 West
Salt Lake City, UT 84116
ph 801-536-4056
fax 801-536-0085
fbernard@deq.state.ut.us
Patrick Cummins
Western Governors= Association
1515 Cleveland Place, Suite 200
Denver, CO 80202
ph 303-623-9378
fax 303-534-7309
pcummins@westgov.org
I-141
Manuel Cunha, Jr.
Nisei Farmers League
1775 N. Fine
Fresno, CA 93727
ph 559-251-8468
fax 559-251-8430
nisei@lightspeed.net
Brian Finneran
Oregon Dept. of Environ. Quality
811 SW 6th Ave.
Portland, OR 97204
ph 503-229-6278
finneran.brian@deq.state.or.us
Rich Fisher
USDA Forest Service - Washington Office
2150A Centre Ave.
Ft. Collins, CO 80525
ph 970-295-5981
fax 970-295-5988
rfisher@lamar.colostate.edu
Bernie Dailey
Wyoming DEQ- Air Division
122 W. 25th Street
Cheyenne, WY 82002
ph 307-777-7391
fax 307-777-5616
bdaile@state.wy.us
Doug Fox, Ph.D.
Colorado State University
CIRA
Fort Collins, CO 80523
ph 970-491-3983
fax 970-491-8241
fox@cira.colostate.edu
Rich Damberg
Office of Air Quality, Planning & Standards
EPA
Mail Drop 15
Research Triangle Park, NC 27711
ph 919-541-5592
damberg.rich@epa.gov
Jody A. Gale
Utah State University Extension Services
250 N. Main
Richfield, UT 84701
ph 435-896-9262 ext 8
fax 435-896-8888
jodyg@ext.usu.edu
Mike Dykzeul
OR Forest Industries Council (OFIC)
1201 Court Street, N.E. Suite 300
Salem, OR 97301
ph 503-371-2942
fax 503-371-6223
mike@ofic.com
Mike George
Arizona DEQ
3033 N. Central
Phoenix, AZ 85012
ph 602-207-2274
fax 602-207-2366
george.mike@ev.state.az.us
Craig R. Derickson
USDA - NRCS
U.S. Federal Bldg., Room 152
100 Centennial Mall North
Lincoln NE 68508
ph 402-437-4068
fax 402-437-5165
craig.derickson@np.nrcs.usda.gov
Mark Gray
Washington State Department of Natural
Resources
Resource Protection Division
P.O. Box 47037
Olympia, WA 98504-7037
ph 360-902-1754
fax 360-901-1781
mark.gray@wadnr.gov
Alan Dominicci
U.S. General Accounting Office
1244 Speer Blvd #800
Denver, CO 80204
ph 303-572-758
fax 303-572-7433
dominiccia@gao.gov
I-142
Sandy Gregory
BLM
P.O. Box 12000
Reno, NV 89520-0006
ph 775-861-6514
fax 775-861-6668
s50grego@nv.blm.gov
Mark Janssen
LADCO
2250 E. Devon #216
Des Plaines, IL 60018
ph 847-296-2181
janssen@ladco.org
Lee Gribovicz
Wyoming DEQ - Air Division
250 Lincoln Street
Lander, WY 82520
ph 307-332-6755
fax 307-332-7726
lgribo@state.wy.us
David Jones
San Joaquin Valley Air Pollution
Control District
1990 E. Gettysburg Avenue
Fresno, CA 93726-0244
ph 559-230-5812
fax 559-230-6064
dave.jones@valleyair.org
Gerry Guay
Dept. of Environmental Conservation
555 Cordova Street
Anchorage, AK 99501
ph 907-269-3070
fax 907-269-7508
gguay@envircon.state.ak.us
Vicky Komie
New Mexico Air Quality Bureau
2048 Galisteo
Santa Fe, NM 87505
ph 505-955-8009
fax 505-827-1523
vicky_komie@nmenv.state.nm.us
Robert Habeck
Montana DEQ
1520 East Sixth Ave.
P.O. Box 200901
Helena, MT 59620-0901
ph 406-444-7305
bhabeck@state.mt.us
Ursula Kramer
Pima County Department of
Environmental Quality
130 W. Congress Street
Tucson, AZ 85701-1317
ph 520-740-3352
fax 520-882-7709
ukramer@deq.co.pima.az.us
Wendel Hann
USDA Forest Service
2015 N. Poplar
Leadville, CO 80461
ph 719-486-3214
fax 719-486-0928
whann@amigo.net
Scott Kuehn
Plum Creek Timber
140 N. Russell
Missoula, MT 59801
ph 406-542-3273
fax 406-549-1885
skuehn@plumcreek.com
Patti Hirami
U.S. Forest Service/Fire & Aviation
P.O. Box 96090
Washington, D.C. 20090
ph 202-205-1498
fax 202-205-1272
phirami@fs.fed.us
Donna V. Lamb
USDA Forest Service
14th & Independence S.W.
Washington, DC 20250
ph 202-205-0800
dlamb@fs.fed.us
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Tom Larsen
Department of Forestry and Fire Protection
P.O. Box 944246
Sacramento, CA 94244
ph 916-653-9446
fax 916-653-8957
tom_larsen@fire.ca.gov
Paige Lewis
Colorado State Forest Service
1313 Sherman Street, Room 219
Denver, CO 80203
ph 303-866-5896
fax 303-866-2115
plewis@lamar.colostate.edu
Art Latterell
Zion National Park
Fire Management Office
Springdale, UT 84767-1099
ph 435-772-0188
arthur_latterell@nps.gov
William Malm, Ph.D.
National Park Service
Atmospheric Science, CIRA
Fort Collins, CO 80523
malm@cira.colostate.edu
William C. Malone
White Mountain Apache Tribe
P.O. Box 700
White River, AZ 85941
ph 520-338-4346 ext 315
fax 520-338-5195
mrtomstorm@yahoo.com
Lyle Laverty
USDA Forest Service
P.O. Box 25127
Lakewood, CO 80225-0127
ph 303-275-5450
fax 303-275-5754
llaverty@fs.fed.us
C.V. Mathai
Principal Scientist
Environmental Department
Pinnacle West/Arizona Public Service
P.O. Box 53999, M/S 8931
Phoenix, AZ 85072
ph 602-250-3569
fax 602-250-3813
c.mathai@pinnaclewest.com
Jim Lawrence
Western State Foresters
2850 Youngfield Street
Lakewood, CO 80215-7093
ph 303-239-3943
james.lawrence@colostate.edu
Rose Lee
Yakama Nation Environmental Program
P.O. Box 151
Toppenish, WA 98948
ph 509-865-4565
fax 509-865-5522
rose@yakama.com
Kevin McKernan
Yurok Tribe
Environmental Program Director
P.O. Box 355
Orick, CA 95555
ph 707-834-2536
fax 707-488-2106
kevinmck@reninet.com
Bill Leenhouts
U.S. Fish & Wildlife Service
3833 S. Development Ave.
Boise, ID 83702
ph 208-387-5584
bill_leenhouts@fws.gov
Brian Mitchell
National Park Service - Air Resources Div.
P.O. Box 25287
Academy Place, Room 450
Denver, CO 80225
ph 303-969-2819
fax 303-969-2822
brian_mitchell@nps.gov
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Don Motanic
Intertribal Timber Council
1112 NE 21st Avenue
Portland, OR 97232
ph 503-282-4296
fax 503-282-1274
donmo@itcnet.org
Tim Rogers
SD DENR, Air Quality Program
Natural Resources Senior Scientist
523 E. Capitol Avenue, Joe Foss Bldg
Pierre, SD 57501
ph 605-773-3151
tim.rogers@state.sd.us
Garry Oye
Acting National Program Leader
for Wilderness, Rivers and Special Areas
USDA Forest Service, Washington Office
RWHR Staff, P.O. Box 96090
Washington, D.C. 20090-6090
ph 202-205-0925
fax 202-205-1145
goye@fs.fed.us
Kirk Rowdabaugh
Director, Fire Management Division
Arizona State Land Department
2901 W. Pinnacle Peak Road
Phoenix, AZ 85027
ph 602-255-4059
fax 602-255-1781
krowdabaughaz@cybertrails.com
Marcus Schmidt
Bureau of Land Management
2850 Youngfield Street
Lakewood, CO 80215
ph 303-239-3607
fax 303-239-3811
marcus_schmidt@co.blm.gov
John Parada
La Posta Band of Mission Indians
P.O. Box 1048
Boulevard, CA 91905
lapostaepa@earthlink.net
Robert Quinn, Ph.D.
Professor of Geography, Meteorologist
Eastern Washington University
PO Box 343
Cheney, WA 99004
ph 509-359-7050
rquinn@ewu.edu
David Simon
National Parks Conservation Association
823 Gold Avenue SW
Albuquerque, NM 87102
ph 505-247-1221
fax 505-247-1222
dsimon@npca.org
Dave Randall
Air Sciences Inc. - Small Business
12596 West Bayaud Ave.
Lakewood, CO 80228
ph 303-988-2960 ext 221
fax 303-988-2968
drandall@airsci.com
Jim Smitherman
Nevada DEP, Bureau of Air Quality
333 W. Nye Land
Carson City, NV 89706
ph 775-687-4670 ext. 3312
fax 775-687-6396
jsmither@ndep.carson-city.nv.us
Art Reese
Director
Wyoming Office of Federal Land Policy
122 West 25th Street
Herschler Building, 1 West
Cheyenne, WY 82002
ph 307-777-3697
areese@state.wy.us
Charlene Spells
EPA, OAQPS
Mail Drop 15
Research Triangle Park, NC 27711
ph 919-541-5255
fax 919-541-5489
spells.charlene@epa.gov
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Mark Wagoner
371 Bald Road
Touchet, WA 99360
ph 509-394-2970
fax 509-394-0479
wagoner@hscis.net
Greg Zschaechner
Utah Interagency Smoke Program
Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114
ph 801-539-4151
fax 801-536-0031
gzschaechner@worldnet.att.net
Ken Woodard
EPA, OAQPS
Mail Drop 15
Research Triangle Park, NC 27711
ph 919-541-5697
fax 919-541-5489
woodard.ken@epa.gov
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Presenter List
Fire’s Contribution to Natural Visibility - Senior Staff Workshop
Denver, Colorado
January 24-25, 2001
James K. Agee, Ph.D.
Professor of Forest Ecology
Division of Ecosystem Sciences, College of
Forest Resources
Box 352100, University of Washington
Seattle, WA 98195
ph 206-543-2688
fax 206-543-3254
jagee@u.washington.edu
Philip N. Omi, Ph.D.
Professor and Director
Western Forest Fire Research Center
Colorado State University
Fort Collins, CO 80523
ph 970-491-5819
fax 970-491-6754
phil@cnr.colostate.edu
Richard M. Hayslip
Manager, Environmental, Land & Risk
Management
Salt River Project
1521 Project Drive
Tempe, AZ 85072
ph 602-236-6699
fax 602-236-3407
rmhaysli@srp.gov
Patrick Cummins
Western Governors= Association
1515 Cleveland Place, Suite 200
Denver, CO 80202
ph 303-623-9378
fax 303-534-7309
pcummins@westgov.org
Dennis Haddow
USDA - Forest Service
Air Program Manager, Rocky Mountain and
Intermountain Regions
PO Box 25127
Lakewood, CO 80225
ph 303-275-5759
fax 303-275-5754
dhaddow@fs.fed.us
William Malm, Ph.D.
National Park Service
Atmospheric Science, CIRA
Fort Collins, CO 80523
malm@cira.colostate.edu
Robert Quinn, Ph.D.
Professor of Geography, Meteorologist
Eastern Washington University
PO Box 343
Cheney, WA 99004
ph 509-359-7050
rquinn@ewu.edu
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NBTT Resource Team List
Fire’s Contribution to Natural Visibility - Senior Staff Workshop
Denver, Colorado
January 24-25, 2001
Coleen Campbell
Colorado Air Pollution Control Division
APCD-TS-B1
4300 Cherry Creek Drive South
Denver, CO 80246
ph 303-692-3224
coleen.campbell@state.co.us
Dennis Haddow
USDA - Forest Service
Air Program Manager, Rocky Mountain and
Intermountain Regions
PO Box 25127
Lakewood, CO 80225
ph 303-275-5759
fax 303-275-5754
dhaddow@fs.fed.us
Mark Fitch
Arizona DEQ; Air Quality Division
3003 N. Central Avenue
Phoenix, AZ 85012
ph 602-207-2374
fax 602-207-2366
fitch.mark@ev.state.az.us
Peter Lahm, FEJF Co-Chair
Air Resource Program Manager
USDA, Forest Service
c/o ADEQ-AQD
3033 N. Central Avenue
Phoenix, AZ 85014
ph 602-207-2356
fax 602-207-2366
pete_lahm@compuserve.com
Carl Gossard, NBTT Co-Chair
Bureau of Land Management
National Interagency Fire Ctr
3833 South Development Ave
Boise, ID 83704-5354
ph 208-387-5419
fax 208-387-5179
cgossard@nifc.blm.gov
Shelley Nolde
U.S. Forest Service
P. O. Box 25127
Lakewood, CO 80225
ph 303-275-5065
fax 303-275-5075
snolde@fs.fed.us
John Graves
Assistant Smoke Management Program
Manager
BIA c/o ADEQ-AQD
3033 N. Central Avenue
Phoenix, AZ 85014
ph 602-207-2277
fax 602-207-2366
graves.john@ev.state.az.us
Darla Potter, NBTT Co-Chair
Wyoming Air Quality Division
122 West 25th Street
Herschler Building, 4 West
Cheyenne, WY 82002
ph 307-777-7346
fax 307-777-5616
dpotte@state.wy.us
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Jim Russell
USDA/FS R6/USDI BLM
Air Resources/Smoke Mgmt. Program Manager
Pacific Northwest Region/OR/WA State Office
FS and BLM
333 S.W. First Avenue
P.O. Box 3623
Portland, OR 97208-3624
ph 503-808-2956
jrussell01@fs.fed.us
David (Sam) Sandberg, Ph.D.
Team Leader, Fire and Environmental Research
Applications
Pacific Northwest Research Station, USDA
Forest Service
3200 SW Jefferson Way
Corvallis, OR 97331
ph 541-750-7265
dsandberg@fs.fed.us
Mike Ziolko
Meteorology Manager
Oregon Department of Forestry
2600 State Street, Building 2
Salem, OR 97310
ph 503-945-7452
mziolko@odf.state.or.us
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Coordination/Facilitation List
Fire’s Contribution to Natural Visibility - Senior Staff Workshop
Denver, Colorado
January 24-25, 2001
Rebecca Reynolds, Lead Facilitator
Rebecca Reynolds Consulting, Inc.
10841 East 155th Place
Brighton, CO 80602
ph 303-655-3773
fax 303-655-3776
rbr@thunderworks.com
Tammie Dauson, Assistant
Rebecca Reynolds Consulting, Inc.
10841 East 155th Place
Brighton, CO 80601
ph 303-655-3773
fax 303-655-3776
Volunteer Facilitators
Tamara Blett
Air Resources Division
National Park Service
P.O. Box 25287
Denver, CO 80225
ph 303-969-2011
tamara_blett@nps.gov
Marion Malinowski,
BLM-Colorado State Office
2850 Youngfield Street
Lakewood, CO 80215
ph 303-239-3749
marion_malinowski@co.blm.gov
Susan Ford
USDA Forest Service
P.O. Box 25127
Lakewood, CO 80225
ph 303-275-5742
sbford@fs.fed.us
Ellenjean Morris
Colorado Dept. of Public Health & Environment
Director of Training & Development
4300 Cherry Cr Dr S, Building A1
Denver, CO 80246
ph 303-692-2066
ellenjean.morris@state.co.us
Karen Hamilton
US EPA Region VIII
999 18th Street, Suite 300
Denver, CO 80202
ph 303-312-6236
hamilton.karen@epa.gov
Doris Sanders
US EPA Reg VIII
999 18th Street, Suite 300
Denver, CO 80202
ph 303-312-6361
sanders.doris@epa.gov
Jane Leche
USDA Forest Service
P.O. Box 25127
Lakewood, CO 80225
ph 303-275-5349
jleche@fs.fed.us
Lisa Silva
CO Department of Health
Attn: Lisa Silva in Administration
4300 Cherry Creek Drive South
Denver, CO 80236
ph 303-692-3119
lisa.silva@state.co.us
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Dave Steinke
USDA Forest Service
P.O. Box 25127
Lakewood, CO 80225
ph 303-275-5365
dsteinke@fs.fed.us
Dana Stotsky
US EPA Reg VIII
999 18th Street, Suite 500
Denver, CO 80202
ph 303-312-6905
stotsky.dana@epa.gov
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APPENDIX II.
POLICY MAKER/OPINON LEADER WORKSHOP
SUMMARY
Executive Summary
Discussion Notes & Evaluation Forms - Q6 Response Compilation
Agenda
Draft Policy for Categorizing Fire Emissions
Tree Change Guide
Participant Information
[Ed note: This document has been formatted
for 2-sided printing (i.e., duplex printing).]
Executive Summary
June 18, 2001
Policy Maker/Opinion Leader Workshop – Fire’s Contribution to Natural Visibility
May 2, 2001 – Tempe, Arizona
Introduction
The Fire’s Contribution to Natural Visibility -- Policy Maker/Opinion Leader Workshop (Policy
Maker Workshop) was designed as a follow-up workshop to the Senior Staff Workshop on Fire’s
Contribution to Natural Visibility. The Policy Maker Workshop was held in Tempe, Arizona on May
2, 2001.
The objective of the Policy Maker Workshop was to build upon the outcomes and information
gained at the Senior Staff Workshop, toward the development of a Draft Policy for Categorizing Fire
Emissions that ultimately will be recommended through the Fire Emissions Joint Forum (FEJF) to
the Western Regional Air Partnership (WRAP). It was the expectation of the Natural Background
Task Team (NBTT) that the Policy Maker participants would discuss their stakeholder viewpoint
of the Draft Policy developed by the NBTT from the Senior Staff Workshop and move toward
consensus, making modifications that would result in a Recommended Policy for Categorizing Fire
Emissions.
Structure and Content
The Policy Maker Workshop was a one-day facilitated and moderated meeting. Invitees to the
Workshop were chosen to participate as either a Policy Maker or as a Concerned Stakeholder. The
purpose of designating two groups of participants was to focus the Workshop around a balanced
Policy Maker core group of 23 participants for the main discussion. This core group was enhanced
by the input of 31 Concerned Stakeholder participants. Of the 54 participants, 8 were WRAP
Members and/or their designated alternates. The participants formed a large and diverse stakeholder
base, ranging from governmental and land management agencies to the agricultural community.
The NBTT utilized the Draft Policy for Categorizing Fire Emissions to facilitate and focus the
discussion of the Policy Maker Workshop. During the Workshop, valuable discussion took place
among the participants regarding the components of the Draft Policy, stakeholder viewpoints, and
Draft Policy implications, resulting in specific feedback for Draft Policy revisions.
Workshop Results
From the discussion, the Policy Maker Workshop participants arrived at general assent on some
changes to the Draft Policy and convergence on certain key issues that will change the format of
what was originally developed by the NBTT. The majority of suggested changes to the Draft Policy
concern the supporting and explanatory language in the annotated sections of the Draft Policy. The
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Workshop participants also came to resolution on some Draft Policy Statements endorsing removal
and/or modification, while several Draft Policy Statements were approved as originally written.
Due to time constraints, not all of the topics addressed in the Draft Policy were covered by the Policy
Maker Workshop participant discussion. To address this, Workshop participants were asked to
submit written comments by the close of the Workshop.
Conclusion
It is apparent that the Policy Maker Workshop has substantially augmented the outcomes and
information gained at the Senior Staff Workshop, and the dialogue and decisions reached by the
participants captured in the discussion notes and evaluations are both insightful and illustrative.
The NBTT is now in the process of analyzing the Policy Maker Workshop discussion notes to
identify suggested changes to the Draft Policy Statements and annotated sections. An analysis of
similar rationale for recommendations, and whenever possible, convergence on key issues will
change the work to date. The results of this analysis will be the basis for the Recommended Policy
for Categorizing Fire Emissions.
The Recommended Policy for Categorizing Fire Emissions will be finalized and presented by the
NBTT to the FEJF for approval. The FEJF will then submit the Recommended Policy to the WRAP
for consideration and utilization by WRAP states and tribes. The FEJF would then submit the
Recommended Policy to the Ambient Monitoring and Reporting Forum, for inclusion into the
overall natural background condition determination guidance needed to meet the requirements of the
Regional Haze Rule.
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Fire’s Contribution to Natural Visibility
Policy Maker/Opinion Leader Workshop
May 2, 2001 – Tempe, Arizona
Discussion Notes
and
Evaluation Forms – Question 6 Response Compilation
June 18, 2001
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May 2, 2001 - Discussion Notes
Opening Comments & Questions
[Ed. Note: Following the NBTT presentation on the Draft Policy and Workshop Outcomes, the
Policy Maker and Concerned Stakeholder participants were given 45 minutes to pose opening
comments and questions. The intent of this portion of the Workshop was to ensure that persons
arriving at the Workshop with comments and questions would be able to pose those toward the
beginning of the day. The comments and questions were recorded on flip charts for consideration
during the applicable Policy Discussion later in the day. Each paragraph represents a new
comment; some clarifying responses were provided and are noted.]
First two Draft Policy Statements: expand to more closely reflect GCVTC and RHR language, e.g.,
manage for visibility impacts as well as public health and nuisance impacts.
Recognition of increased fire emissions controlled from increased fire.
Annual emissions goals established cooperatively.
There is an interest out there in quick fixes to perceived barriers to the National Fire Plan and
repairing ecosystem health. This initiative may prevent the National Fire Plan from happening and
is a significant problem.
Biomass utilization is crucial to managing emissions. It should be endorsed and recognized as a
concept.
Reference to USDA-FS and USDOI Cohesive Strategies: There is a huge unnatural condition on the
land out there – this needs to be confirmed in the NBTT Draft Policy.
What other connection/relationship does this have to the National Fire Plan? Specifically in re: the
Condition Class Table on page 32 of the Draft Policy.
All burning is not equal, but all policies should work to be equitable. For instance, the National Fire
Plan recognizes and has established a priority for burning in the wildland/urban interface. Like this,
the Draft Policy also needs a mechanism for recognizing priorities vis-à-vis visibility impacts to
Class I areas.
How does NBTT interface with the Agricultural Air Quality FACA re: prescribed burning?
(NBTT Response: The Senior Staff Workshop included FACA members for agricultural
representation {Manuel Cunha and Robert Quinn}. NBTT also reviewed the AAQTF
Recommendations on agricultural burning in development of the Draft Policy.)
Managing visibility impacts vs. reducing emissions – what is the difference?
Condition Class Table on page 32 of the Draft Policy: the picture it portrays is that 144 million acres
need treatment. This is not a complete long-term picture – need to include the Comprehensive Plan
that discusses state and private lands, and incorporate the new information now available from the
National Fire Plan.
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Condition Class numbers: need to keep perspective – there is significant burning planned but not all
treatment is prescribed fire. Annually and over the next 10 years, we’ll only be burning 8 million
of the 144 million acres and the focus will be on the priority acres (wildland/urban interface).
The Cohesive Strategies framework is a gross estimate and will not work on the ground to
distinguish maintenance from restoration.
Prevention-Suppression: an aggressive prevention program should be emphasized in the Draft
Policy.
The impact of classification is difficult to evaluate without understanding the setting of the 2064
goal.
A cost-benefit analysis would be helpful in this process, e.g., the obvious benefits to suppression
such as protection of property versus the costs of the new tracking and monitoring
equipment/personnel that will be needed to deal with what is currently unmonitored fire.
There needs to be a better understanding of the effect of adopting the Draft Policy on SIPs/TIPs,
(e.g., basis for 309 SIP – effect on 308 states). Can there be variation from state to state?
Also, the Draft Policy discusses Smoke Management Plans (SMPs) – how will states’ various SMPs
address the Draft Policy?
Is some variability anticipated with what will be contained in SMPs?
(NBTT Response: Yes, state by state. WRAP recognizes state/tribal sovereignty – WRAP
wants everyone to accept the Draft Policy, but understands it will be modified depending on
the state/tribe.)
Clarification on Draft Policy Statement #7: second sentence -- how will this be done? What will
happen with the flagged data?
What we are dealing with today is a framework for addressing fire.
Many questions presented here today cannot be answered today nor by NBTT, but can be put
forward for further subsequent discussion.
I want to underscore that this (the classification) is not about “good” or “bad”, “right” or “wrong.”
Are we looking at reducing fire as a beneficial tool through this Draft Policy?
(NBTT Response: No.)
What impact, if any will the Draft Policy have on other EPA policies: Natural Events Policy and
Wildland Fire Policy?
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What percent of regional haze impact is generated by smoke from a fire?
(NBTT Response: It is significant on an episodic basis.)
(Concerned Stakeholder Response: In the West, organics make up about a third; dust about
a third and sulfate about a third.)
Clarify: Is all agricultural burning “anthropogenic” or will some be considered “natural”?
(NBTT Response: Lands in CRP could be “natural”.)
Will there be flexibility to address specific situations, e.g., will crops adversely affected by disease
or insects be classified “natural”?
(NBTT Response: No, still “anthropogenic.” The Senior Staff Workshop considered
insects/disease as a criterion as well as others, but the plurality declined to use these as
criteria for a “natural” classification.)
Citation of Brian Finneran’s, OR DEQ, Policy Implications Paper. Comment: A means to help us
get to 2064 needs to be developed.
[Ed. Note: The cited paper was distributed by Annette Liebe to some, but not all, of the
Policy Maker/Opinion Leader Workshop participants and NBTT Resource Team. The paper
was entitled: “The Policy Implications Related to Classifying Prescribed Fire as “Natural”
under the Regional Haze Rule”, prepared by the Oregon Department of Environmental
Quality for the May 2, 2001 NBTT Policy Workshop.]
There will be a tremendous amount of smoke out there to come. What will response to the public
be vis-à-vis visibility?
(NBTT Response: Other Forum task teams are working on all of these items including public
health and nuisance impacts.)
Draft Policy seems to support prescribed fire for maintenance, which will cause a lot of smoke. Is
this going to satisfy the public?
(NBTT Response: All smoke will be managed. “Natural” is not a “get out of jail free” card.
Recognition that there will be smoke in the air, and we’re all connected in the visibility challenge
-- even globally. We’re here about regulations, which means tradeoffs.
In re: Draft Policy Statements #4 and #5: There is an assumption that if someone is making money
off burning then it is “anthropogenic”, but rather, we should be considering fuel type and amount.
Clarify definitions of natural, unnatural fuels, etc.
Draft Policy Statement #7 – Natural events like exemption: Clarify intent/calculations. Is the
flagging of extreme events only for the calculation of natural conditions or for the tracking of
progress toward the natural visibility goal over time? Assumption that “natural” prescribed fire
would be flagged. Need additional clarification in the Draft Policy.
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Follow-up on comments re: public – especially concerning agricultural burning. It will be difficult
to get farmers to accept their fire as “anthropogenic” if FLMs are burning their acreage.
Policy Maker Questions (index card)
Is carbon the sole source of regional haze?
Is the NBTT determining natural range of variability for haze?
“Apportioning”? -- Who, how, when?
How to integrate emissions foregone from prescribed fire.
Concerned Stakeholder Comments (index card)
Is there a mechanism to account for emission controls already implemented by the states? Regional
Haze Rule would appear to, but Draft Policy is silent on this specific issue.
The language throughout the Draft Policy should be revisited for consistency with 2001 Federal Fire
Policy, signed by FS, DOI Bureaus, DOD, DOE, EPA, FEMA, DOC, and NASF. (i.e., it’s very
broadly supported…)
II-8
Policy Discussion
Native American Cultural Burning (Policy Statement #9)
Clarifying Questions
Question on Draft Policy Statement #9 and #10: How is Native American cultural burning defined?
(NBTT Response: Does the definition in the Draft Policy need more clarification?)
(Concerned Stakeholder Response: NBTT left it somewhat broad because of each tribe’s
different uses of fire. Tribal Council will need to define specifically what makes up cultural
burning.)
Could Tribal Council deem all tribal burning as cultural?
Policy Makers Discussion
Recommend that “intra-tribal” be deleted. (agreed) It is not relevant criteria in regards to commerce
as there historically has been commerce within a tribe and between tribes.
Also, re: magnitude: recommend that the last sentence re: de minimus be deleted. (agreed) This may
not be the case in the future if tribes’ cultural burning increases, and suggest it will increase as tribes
reclaim their heritage. Need to recognize that tribal burning may increase through the next decades.
(agreed)
In re: “regardless of land ownership” -- suggest this language be added to Draft Policy Statement
#9 since many tribes do not own all of their tribal Lands. (agreed)
Draft Policy Statement #10: Do not see the point to it. Draft Policy Statements #4 and #5 suffice.
Suggest deleting Draft Policy Statement #10. (agreed)
Native American Cultural Burning stems from Native American Culture.
1. Culture derives from the past, but is not necessarily the same. We have modified it but not totally.
Question logic behind separating some practices from Native American Culture.
2. “Inter/intra-tribal commerce” – restricts tribes to reservation lands. In fact, they have a much
broader zone of influence that needs to be recognized. They have a right to exercise certain activities
on “usual and custom places” of ancestral homelands as well as around tribal Lands. Also, want to
understand more about risks, costs and how this relates to indigenous cultures.
Does Draft Policy Statement #9 cover all religious burning or just Native American?
(NBTT Response: Right now, it covers Native American only.)
II-9
At what level will Native American cultural burning be significant enough to track? e.g., 1000 acres.
(NBTT Response: Yes, 1000 acres is significant, and will be tracked, especially where there
are Class I impacts, while giving leeway for tribal cultural burning practices.)
(NBTT Response: What the tracking threshold will be still needs to be determined. There
are many different possible criteria: acreage, proximity to Class I, purpose, etc.)
Let tribes decide what cultural burning is. Do we agree that this type of burning is “natural”?
What is the rationale behind the Native American cultural burning classification? Is it based on de
minimus levels or based on the fact that it is “natural”?
(NBTT Response: All will be tracked; implementation of tracking may be based on a de
minimus level.)
Suggested Modifications to Draft Policy Statement #9 & Annotation
1.
a) Maintain as “natural,” but clarify reference to magnitude as “currently” in the Annotation.
(agreed)
b) Include in the beginning as part of what is not under this Draft Policy. (not agreed)
2. Define “cultural burning.” Let tribes or Tribal Council do it. In Draft Policy Statement &
Annotation. (agreed)
3. Recognize current magnitude and anticipated future increases in Annotation. (agreed)
4. Add “Inter and Intra-Tribal.” (not agreed)
5. Add “regardless of land ownership” in Annotation. (agreed)
6. Delete Inter and Intra-Tribal in Draft Policy Statement & Annotation. (agreed)
Suggested Language for Draft Policy Statement #9:
Native American cultural burning for traditional, religious, and ceremonial practices, as determined
by each tribe (or by Tribal Council) is considered to be a “natural” source.
Policy Maker Comment (index card)
I disagree that this Draft Policy should give tribes the ability to define Native American cultural
burning on state land as “natural”. That must be up to each individual state.
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Policy Discussion
Prescribed Fire -- Policy Statements #4, #5, #6 and #10
Modifications Draft Policy Statement #10 & Annotation
Draft Policy Statement #10: Do not see the point to it. Draft Policy Statements #4 and #5 suffice.
Delete Policy Statement #10 and the Annotation. (agreed)
Should we make specific reference to Native American burning in Draft Policy Statements #4 and
#5? Policy Maker Response: No, we don’t single out other types of lands in those Draft Policy
Statements. (agreed)
Clarifying Questions (#4 & #5)
Distinction between ecosystem restoration and maintenance. In the implementation – how will this
distinction be made?
USDOI and FS already have made the distinction, but how is private land figured in?
Difficult to define “sustainable ecosystem.” This has been defined and redefined without success.
How can we tighten this up?
There needs to be a provision to allow for local or programmatic level assessment and adjustment
of the gross scale analysis and strategy that differentiates between maintenance and restoration. This
would need to take place across all land ownership.
Need to recognize increase in burning on state and private land as well as federal land.
Policy Makers Discussion
Opportunity to encourage moving toward a more sustainable natural system. We don’t want to
inhibit efforts in this area.
Consider alternatives to burning.
Need to better define maintenance vs. restoration. The distinction does not exist on the ground.
There are some operational issues with the distinction between maintenance vs. restoration that will
need to be addressed over time.
I can live with Draft Policy Statement #4 with the stated understanding of the unnatural fuel levels.
Consideration needs to be given to the awarding of credits for emission reduction practices.
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Providing incentives to move systems toward maintenance may take the form of credits for the
balance between wildfire and prescribed fire.
Modification to Draft Policy Statement #4
Provision to allow for adjustments to the Cohesive Strategies – to happen at local or programmatic
level. Suggest the definition of sustainable ecosystem be locally derived. (agreed)
Modifications to Draft Policy Statement #5
Suggest that the Draft Policy include language on fuel buildup and increased use of mechanical
treatments.
Suggested language: Unnatural fuel build-ups across the West threaten communities, critical
watersheds, habitats and air quality. It is recognized that there needs to be an increase use of
prescribed fire and other treatments to promote better fire control, predictable fire effects and
management of air pollution emissions. (agreed to this language, but in Annotation of #1)
Also, suggestion to add language that recognizes suppression, prevention and that prescribed fires
can lessen emissions. And, to track this will be important.
Suggested language: While recognizing that many human actions, including fuel reduction by
prescribed fire or mechanical means, fire suppression and fire prevention all ultimately reduce
potential emissions and impacts on visibility. (agreed, but add to Annotation #1)
Also, reference it in the Draft Policy Statement #5. (not agreed)
Additional Suggested Language for #5
The technical feasibility and economic soundness of alternatives should be evaluated on a case-bycase basis in an objective manner in accordance with a pre-established “alternatives clearinghouse.”
(Similar to “top-down” BACT)
Draft Policy Statements #4 and #5 stay the same – add: Increase in fire and alternatives to fire
language to Draft Policy Statement #1, Annotation. (agreed)
Concerned Stakeholder Comments
It is difficult to accept the distinction between maintenance and restoration, especially re: agricultural
equity.
Suggested Language to Draft Policy Statement #4:
Prescribed fires to maintain natural conditions in a currently healthy ecosystem are classified as
natural, provided that these fires are the absolute minimum necessary and all non-burning emission
reduction practices are evaluated and utilized.
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There needs to be a greater emphasis on clearing up fire hazard.
Suggest on Draft Policy Statement #4: add a cap on the amount of ecosystem maintenance that can
be done in a given time period.
Not comfortable with the distinction between maintenance and restoration. The biggest issue is
equity across all sources. Supports the suggested CS modification above.
The use of alternatives needs to be made clear in the Draft Policy Statement not just in the
Annotation.
The Draft Policy needs to be integrated with all other considerations (e.g., public health, nuisance,
etc.).
There is no real understanding in the Draft Policy documents vis-à-vis what ecosystem health is and,
no one has it. So therefore, it is not a good criterion. A better criterion is the condition class
categories. Also, CRP land burning is in fact burning of unhealthy lands. It is not to maintain
healthy ecosystems as is stated in the Draft Policy, and therefore it is a bad example in this section.
Policy Maker Discussion
The key to this (i.e., healthy ecosystems) is Condition Classes. What techniques will be used on
what lands will be decided at a local level (e.g., land use planning, fire management planning, NEPA
documents). (agreed)
Using fire as a natural agent is the epitome of maintenance for ecosystem burning.
Modification on #4 Annotation
Look at example of CRP as written – not a good one – insert “in order to maintain” instead of “that
are in.” (page 13)
Suggested language:
“…Conservation Reserve Program (CRP) in order to maintain a healthy and sustainable condition.”
(Section 4, Discussion paragraph 2, page 13 of 32) (agreed)
Insert “ecosystem components” instead of “ecosystem health” (Section 4, Discussion paragraph 2,
page 13 of 32, and also in the Draft Policy Statement #4) (agreed)
NBTT needs to add a definition of “ecosystem components” (see USDA-Forest Service and USDOI
Cohesive Strategies for a definition). (agreed)
Policy Maker Discussion
Prescribed fire can be managed and is therefore “anthropogenic” (as is Native American fire). Seems
like making this anything else is avoiding regulation and is indefensible.
II-13
There is a concern that if this approach (i.e., all human ignited fire is “anthropogenic”) is taken, it
removes choices from the air regulator (especially concerning agriculture) rather than adding them.
Some amount of agricultural burning should be allowed to be considered natural. I see Agriculture
as being at a disadvantage in this Draft Policy.
Concerned Stakeholder Comments
Long-term impact of classification is important.
Sees the classification as totally driving regulation and therefore is pejorative (“natural” is “good”,
“anthropogenic” is “bad”.)
Look at other terms for “natural” and “anthropogenic.” They are too confusing.
Natural is defined by “historical” situation.
Equity issue: non-economical value vs. economical value (agriculture/federal).
What are the incentives?
What is the goal here: Reduce fire? Provide equitable scheme for use of fire? What is basis for
discussion?
Policy Maker Discussion
1995 Federal Fire Policy and 2001 National Fire Plan encourage use of fire.
Profit should not be a guiding principle or criterion between Draft Policy Statement #4 and #5.
(agreed)
Policy Maker Comment (index card)
Guiding principle: Goal of ecosystem restoration activities vs. remove as much material as possible.
Every effort will be made to maximize utilization and removal of biomass material. Prescribed fire
cannot be last alternative.
Concerned Stakeholder Comment (index card)
Draft Policy mixes sustainability with natural range of variability. Some ecosystems outside of the
natural range of variability are sustainable, and some that are within the natural range of variability
are not sustainable (i.e., require active management). Suggest a fire ecologist work with final
wording (Leenhouts, Sexton or Teensma).
II-14
Section 5 – “Anthropogenic Fire” (page 5 of 32). “The needs of an individual flora or fauna species
or human use, that is not vital to the overall ecosystem management, may be met through the use of
prescribed fire.” The FLMs would not undertake a prescribed fire for a single species that is not also
“vital” to the ecosystem management. The sentence seems out of place in Section 5.
The specific figures from the DOI Cohesive Strategy need to be slightly adjusted to reflect the
numbers in the Draft Final Version of the Strategy.
Policy Statement #6
[Ed. Note: Draft Policy Statement #6 was skipped due to lack of time, and therefore not specifically
addressed by the group. The following comments were submitted.]
Policy Maker: Any escaped prescribed fire will take on the category (“natural” vs. “anthropogenic”)
based upon where it is burning.
Concerned Stakeholder: Any escape demonstrates a lack of control capability and is outside the plan
of emissions. All escapes should be “anthropogenic.”
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Policy Discussion
Overarching -- Policy Statements #1, #2 and #3
Policy Maker Discussion Draft Policy Statements #1 & #2
Add alternatives to fire language in Annotation for Draft Policy Statement #1. (See above discussion
in Prescribed Fire and suggested language under #5.) (agreed)
Is there really a distinction between Draft Policy Statements #1 and #2? Can we combine Draft
Policy Statements #1 and #2? Would then read: “All fires will…” (agreed)
(Citation of Brian Finneran’s memo) This means that “all fire would be managed to reduce emissions
and visibility impacts.”
[Ed. Note: See cite on page 7.]
“Control” means something specific to the fire community, use “reduce” instead. (agreed)
Combine Draft Policy Statements #1 and #2: “All fires managed to minimize visibility impacts and
to reduce emissions to the maximum extent feasible, subject to…” (NBTT refine language) (agreed)
Suggestion to add: “…subject to economic, safety, technical and environmental considerations.”
(Add above to combined Draft Policy Statement #1 and #2) (agreed)
In the Draft Policy: separate overarching statements (were Draft Policy Statements #1, #2, & #3)
from classification statements (were Draft Policy Statements #4 - #10). (agreed)
NBTT needs to re-visit SMPs vis-à-vis distinction between BSMP and ESMP (that now no longer
exists as written with the combination of Draft Policy Statements #1 & #2). (agreed)
Policy Maker Comment (index card)
Draft Policy Statements #1 and #2: Should remain separate because they embrace the difference
outlined in the Regional Haze Rule that “emissions” from “natural” sources will not be factored into
the 2064 target.
Concerned Stakeholder Comment (index card)
Need to have some measure of impacts versus emissions generated. Oregon has an element of its
smoke management plan to account for burning under meteorological impairment. Additionally,
burning of piles during optimum mixing may limit impacts to visibility as well as NAAQS. Thus,
restoration burning may not have any impact on visibility – why shall emissions count?
II-16
Policy Maker Discussion Draft Policy Statement #3
Add emissions averted to tracking program and crediting those in the context of annual emissions
goals.
Should the tracking system be complex enough to track cross-source emissions trading? (e.g.,
trading fire emissions for stationary source emissions)
Details of tracking will need to be figured out at a later date by the FEJF/Emissions Task Team.
The details of the tracking may be key to overcoming the final implementation of this Draft Policy
in some states.
Averted emissions banked to offset overages on an annual basis? Is this do-able? Suggest mechanism
to track this, but wait on deciding whether or not to credit.
Suggested Modification: In Annotation, recognize the suggestions for the tracking system (e.g.,
credits, use of alternatives, emissions avoided) to be considered and evaluated by the FEJF or one
of its task teams as the tracking system is developed. (agreed)
There may be barriers to implementation re: agricultural fire in Nevada, Colorado, and South Dakota.
What is realistic, feasible, and affordable?
I am not comfortable with the addition of credits to the tracking.
Seems to be delving into other tasks and does not add to classification – delete it?
I think we do need it.
Leave Draft Policy Statement #3 as is. (agreed)
Concerned Stakeholder Comments
Getting credits for averting emissions seems ludicrous if we are trying to reduce regional haze. We
need to aim for the goal.
The Sierra Club is against emission credits.
Concerned Stakeholder Comment (index card)
Page 11 of 32. While there are no systems in place for tracking emissions and emission reductions
on a regional or larger basis, the ICBEMP Final EIS and Record of Decision document do have some
agreed upon mechanisms for doing some of this tracking, as well as other coordination issues.
Recommend borrowing from it as much as possible.
II-17
Policy Discussion
Wildfire -- Policy Statements #7 and #8
Policy Maker Discussion
Need to clarify in the Annotation that if there is a lack of resources to suppress the fire it would fall
into Draft Policy Statement #7. (agreed)
Draft Policy Statement #7 is good except for the 2nd sentence – take it out? Put it in the Annotation?
The NBTT should re-consider the 2nd sentence. The 2nd sentence might be appropriate, but there
is concern on the technical aspect. (agreed)
Regarding the 2nd sentence: Would the flagged data be removed from the natural background
calculation but not the data as a whole?
It is likely that all wildfire will not be able to be prevented by the increased use of prescribed fire.
If it were just a few wildfire hits in the data per year then maybe this proposal (i.e., 2nd sentence)
would work. However, if there were more wildfire hits than a few this would only mask the reality
of what is going on and then the slope of the line toward the natural visibility goal would not make
sense.
Draft Policy Statement #8: replace “wildfires not suppressed” with “wildland fire managed for
resource objectives.” (agreed)
Otherwise #8 is good.
Concerned Stakeholder Comment
What is the relationship with other EPA guidance on prescribed burning? (e.g., Natural Events
Policy and Wildland Fire Policy)
II-18
Evaluation Forms - Question 6 Response Compilation
At the conclusion of the Policy Maker/Opinion Leader Workshop on Fire’s Contribution to Natural
Visibility, the Workshop participants were asked to complete an Evaluation. Of the 54 participants,
21 participants completed the Evaluation. Verbatim responses to Question #6 have been included
here as an indicator of the group’s priorities. Question #6 reads:
“The top three (3) Policy issues from this Workshop that are important to me are:”
Prescribed Fire Classification for Ecosystem Maintenance & All Other Purposes
(Policy Statements #4 & #5) - 26% of issues identified for Question 6
“Prescribed fire.”
“Issue of restoration vs. maintenance.”
“Restoration vs. ‘Natural.’”
“Policy Statement #4.”
“Policy statements #4 and #5.”
“Restoration.”
“Policy Statement #5.”
“Avoiding constraints to the use of prescribed fire.”
“Native American prescribed burning dropped. The Senior Staff did not include this issue?”
“Maintenance/restoration distinction.”
“Re-look at the philosophy that commodity/profit is a deciding factor in categorizing fire type/control
requirements.”
“How this will affect overall health – ecosystem.”
Management of Visibility Impacts from Fire Sources & Control of Anthropogenic Sources
(Policy Statements #1 & #2) – 21% of issues identified for Question 6
“Policy Statements #1 and #2 combined.”
“Acknowledging role of actions that reduce and prevent emission.”
“Visibility protection.”
“Management for both visibility and emissions reductions.”
“Distinction between management of fires and tracking haze.”
“Equity regarding reduction of visibility impacts and control of emissions.”
“Fire/smoke management.”
“How prescribed fire relates to NAAQS violations/Fire Policy verses regional haze.”
“Management vs. Natural background.”
“That the land managers are accountable for managing (reducing) fire emissions.”
Natural & Anthropogenic Source Classifications
13% of issues identified for Question 6
“Natural vs. human caused fires – sort it out. For me, the most logical construct is that if man caused the
fire, it’s man caused.”
“‘natural’ vs. ‘anthropogenic.’”
“’Anthropogenic’ vs. ‘natural.’”
II-19
Question 6 Response Compilation, continued
Natural & Anthropogenic Source Classifications, continued
“Clear distinction between ‘natural’ and ‘anthropogenic’ fire.”
“Need a clear definition for wildfire, natural background, ‘anthropogenic’ and ‘natural.’”
“Categorization ‘natural’ vs. ‘anthropogenic.’”
Develop approaches for estimating the contribution of fire emissions to natural background
visibility conditions.
(Task 2) - 9% of issues identified for Question 6
“Affect on Reasonable Progress goals.”
“Determining the source of natural background haze.”
“What is the natural background level.”
“Focus on natural background for ‘glide path.’”
The Draft Policy applies to both wildland and agricultural lands regardless of ownership,
cause of ignition, or purpose of the fire.
6% of issues identified for Question 6
“Equity.”
“Get rid of all the sacred cows. Manage all fires.”
“How this will affect logging.”
Alternatives to Burning
6% of issues identified for Question 6
“Additional emphasis on alternative treatments.”
“Consideration of economic, environmental and technical feasibility.”
“Plan to regain public acceptance to alternative treatments.”
Native American Cultural Burning Classification
(Policy Statement #9) - 6% of issues identified for Question 6
“Native American (Tribal Government: Government vs. Native American is key) cultural burning.”
“Tribal cultural burning.”
“Many policy makers referenced tribal sovereignty even though they’re not tribal reps, which was
meaningful.”
Other Policy Issues Identified for Question 6
13% of issues identified for Question 6
“Workable policy.”
“Tracking.”
“Understand cost/benefit.”
“Development of a policy that is understandable to internal and external audiences.”
“Policy Statement #6.”
“Flexibility of implementing the policy in different states.”
II-20
WORKSHOP OBJECTIVE
To build upon the outcomes and information gained at the Senior Staff Workshop on Fire’s
Contribution to Natural Visibility, toward the development of a Draft Policy for Categorizing Fire
Emissions that ultimately will be recommended to the WRAP.
Participants will come prepared to discuss their stakeholder viewpoint of the Draft Policy to achieve
a joint understanding of the Draft Policy elements and their implications. From this, participants will
move toward consensus, making modifications that result in a recommended Policy for Categorizing
Fire Emissions.
REGISTRATION & SOCIAL
Tuesday, May 1, 2001
7:00 p.m. – 10:00 p.m. MST
Poolside, Fiesta Inn
Sponsored by Pinnacle West Capital Corporation
AGENDA
Wednesday, May 2, 2001
8:00 a.m. – 4:00 p.m. MST
Encantada
I. Opening Remarks
II. Welcome
III. Keynote Address
IV. Introductions & Agenda Review
V. NBTT Overview & Context
VI. NBTT Policy Presentation
And Workshop Outcomes
VII. Break
VIII. Opening Comments/Questions
8:00 – 8:05
Darla Potter, WY DEQ
NBTT Co-Chair
8:05 – 8:10
Richard Tobin, AZ DEQ
8:10 – 8:15
Dianne Nielson, UT DEQ
8:15 – 8:30
Rebecca Reynolds, RRC
Facilitator
8:30 – 8:50
Carl Gossard, BLM
NBTT Co-Chair
8:50 – 9:15
Darla Potter, WY DEQ
NBTT Co-Chair
9:15 – 9:30
9:30 – 10:15
II-21
Pete Lahm, USDA FS
FEJF Co-Chair
Moderator
AGENDA, continued
IX. Break
10:15 – 10:45
X. Policy Discussion:
10:45 – 11:15
Native American Cultural Burning (Policy Statement 9)
Pete Lahm, Moderator
XI. Policy Discussion:
11:15 – Noon
Prescribed Fire, Part 1 (Policy Statements 4, 5, 6 & 10)
Pete Lahm, Moderator
XII. Lunch
Noon – 1:00
XIII. Policy Discussion:
1:00 – 1:45
Prescribed Fire, Part 2 (Policy Statements 4, 5, 6 & 10)
XIV. Policy Discussion:
Wildfire (Policy Statements 7 & 8)
(provided)
Pete Lahm, Moderator
1:45 – 3:00
Pete Lahm, Moderator
[includes one 15-minute break]
XV. Policy Discussion:
Overarching (Policy Statements 1, 2 & 3)
3:00 – 3:45
Pete Lahm, Moderator
[includes one 15-minute break]
XVI. Close
3:45 – 4:00
Carl Gossard, BLM
NBTT Co-Chair
Policy Discussion Format:
I. Questions/Understanding Policy -- All
II. Policy Maker Discussion
a. Implications
b. Barriers
III. Concerned Stakeholder Input
a. Implications
b. Barriers
c. Suggested Modifications
IV. Policy Maker Modification/Finalization
a. Suggested Modifications
b. Finalize Policy Statements
Please Note:
There will be a break in most Policy Discussions prior to the
Modification/Finalization segment.
II-22
DRAFT POLICY FOR
CATEGORIZING FIRE EMISSIONS
PREPARED BY:
NATURAL BACKGROUND TASK TEAM OF THE FIRE EMISSIONS JOINT FORUM
APRIL 5, 2001
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II-24
TABLE OF CONTENTS
I. PURPOSE
II. SCOPE AND APPLICABILITY
III. BACKGROUND
IV. POLICY
V. ANNOTATED POLICY
Section 1. Management of Visibility Impacts from Fire Sources
Section 2. Control of Anthropogenic Sources
Section 3. Tracking of Fire Emissions
Section 4. Prescribed Fire for Ecosystem Maintenance
Section 5. Prescribed Fire for All Other Purposes
Section 6. Escaped Prescribed Fire
Section 7. Wildfire Suppressed by Management Action
Section 8. Wildfire Not Suppressed by Management Action
Section 9. Native American Cultural Burning
Section 10. Native American Prescribed Burning
VI. APPENDICES
Appendix A. Definitions
Appendix B. Wildfire Variability – Acres Burned per Year
Appendix C. Wildfire Variability – Ignition Source
Appendix D. DOI and DOA, Cohesive Strategies Information
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I. PURPOSE
This Draft Policy was developed for the Western Regional Air Partnership (WRAP) to aid in
determining natural background conditions for Federal Class I areas in the region. Fire emissions
are acknowledged by EPA in the Regional Haze Rule (Rule) to be a significant contributor of
regional haze and that there is a complex relationship between what may be considered natural
versus human-caused sources of fire. In the Preamble to the Rule, EPA states that “in determining
natural background for a Class I area, EPA believes states [and tribes] should be permitted to
consider some amount of fire in the calculation to reflect the fact that some prescribed fire effects
serve merely to offset what would be expected to occur naturally” 1.
The Natural Background Task Team (NBTT) of the Fire Emissions Joint Forum (FEJF) created this
Draft Policy through a stakeholder-based senior staff level workshop. This Draft Policy has been
drafted to help determine which fire emissions will be considered as part of the natural background
conditions in Federal Class I areas and which of the remaining fire emissions are considered
“anthropogenic” and subject to reasonable progress requirements of the Rule. This Draft Policy
clarifies the relationship between what would be defined as a “natural” fire source and what would
be defined as an “anthropogenic” fire source, thereby addressing the complex relationship EPA
acknowledges in the Preamble to the Rule. By clarifying the categorization of fire types, the Draft
Policy will provide a clear pathway to the quantification of the fire emissions contribution to natural
background.
Upon collection of further input on this Draft Policy through another stakeholder-based workshop
at the policy-maker level, the NBTT will submit a recommended Policy to the FEJF. The
recommended Policy will then be finalized and submitted by the FEJF to the Ambient Monitoring
and Reporting Forum (AMRF) for inclusion into the overall natural background condition
determination guidance needed to meet the requirements of the Rule. The natural background
condition determination guidance will be submitted to the WRAP for consideration as the
recommended Policy, to be utilized by WRAP states and tribes in development of their respective
state or tribal implementation plan (SIP/TIP) addressing the Regional Haze Rule.
II. SCOPE AND APPLICABILITY
Natural Conditions as defined in the Regional Haze Rule include “naturally occurring phenomena
that reduce visibility as measured in terms of light extinction, visual range, contrast, or coloration”2.
Natural Conditions are also described in the Regional Haze Rule Preamble as “the visibility
conditions that would be experienced in the absence of human-caused impairment”3. This Draft
Policy does not address potential natural sources of visibility impairing pollutants such as natural
vegetative hydrocarbon emissions (e.g., terpines from trees), oceanic sulfates, natural wind1 64 FR 35735-35736 (July 1, 1999)
2 64 FR 35764 (July 1, 1999)
3 64 FR 35728 (July 1, 1999)
4/5/01 Draft
Page 3 of 32
suspended dust, and sulfate and nitrate from volcanoes. This Draft Policy only addresses the effects
of fire emissions in terms of natural background visibility and the requirements of the Rule. Air
pollutant emissions from fires may also impact public health and cause nuisance smoke intrusions;
those issues have been left for other task teams of the FEJF to address.
All kinds of fire (e.g., wildfire, prescribed fire, agricultural burns, Native American cultural burns)
contribute to regional haze. This Draft Policy applies to both wildland and agricultural lands
regardless of ownership (e.g., federal, state, tribal, public, private), cause of ignition (e.g., lightning,
arson, accidental human, land management decision) or purpose of the fire (e.g., commodity benefit,
hazard reduction, maintain ecosystem health). This Draft Policy does not apply to other open
burning activities, regardless of the purpose of the burn, on residential property or tribal lands (e.g.,
backyard burning, garbage incineration, cremation, sweat lodge fires, residential wood combustion).
This Draft Policy would apply to impacts on Federal Class I areas in the WRAP region. States and
tribes in the WRAP region are anticipated to incorporate the overall natural background condition
determination guidance developed by the WRAP into the technical support documentation for a
SIP/TIP submitted to EPA in order to meet the requirements of the Rule. The overall natural
background condition determination guidance will allow states and tribes to establish natural
background conditions for the most and least impaired days for each Federal Class I area within their
jurisdiction. The natural background condition values will then be incorporated into the sections of
the SIP/TIP that address the requirements in Section 308 or Section 309 of the Rule, for the
calculation of natural visibility conditions. As the SIPs/TIPs will be revisited and revised, per the
schedule specified in the Rule, there will be opportunities to refine the recommended Policy to
reflect scientific advances and policy changes.
The WRAP is a voluntary organization of western states, tribes and federal agencies formed in 1997
as the successor to the Grand Canyon Visibility Transport Commission (GCVTC), which made more
than 70 recommendations in June 1996 for improving visibility in 16 national parks and wilderness
areas on the Colorado Plateau. The WRAP promotes, supports, and monitors the implementation of
those Recommendations throughout the west. The WRAP is also recognized by EPA as a regional
planning organization implementing processes to improve visibility in all western Class I areas by
developing the necessary technical and policy tools needed by states and tribes to implement the
Regional Haze Rule. The WRAP includes the states of Washington, Oregon, Idaho, Montana,
Wyoming, North Dakota, South Dakota, California, Utah, Colorado, Arizona and New Mexico.
Tribal nations selected 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, Jicarilla Apache Tribe, Northern Cheyenne Tribe, Salish and Kootenai
Confederated Tribes, Pueblo of San Felipe, and Shoshone-Bannock Tribes of Fort Hall.
Representatives of other tribes participate on WRAP forums and committees. Federal WRAP
members are the Department of the Interior, the Department of Agriculture, and the Environmental
Protection Agency.
4/5/01 Draft
Page 4 of 32
III. BACKGROUND
The Regional Haze Rule was issued by the Environmental Protection Agency (EPA) in July 1999
and outlines the requirements for addressing regional haze in Federal Class I areas. A critical
element of the Rule is the establishment of the natural background condition values for each Federal
Class I area, against which improvements of the 20 percent worst visibility days and maintenance
of the 20 percent cleanest visibility days will be compared. This comparison will allow for a state
or tribe to demonstrate that their emissions management program will meet the required reasonable
progress goals established in the SIP/TIP for the Regional Haze Rule.
There are a number of sources that EPA has suggested as contributors to natural background
conditions, including fire. The Regional Haze Rule Preamble also stipulates that fire contributes to
regional haze and that fire can have both natural and anthropogenic sources. The Preamble to the
Rule further states that some fire that is set by human ignition may be included in a state’s or tribe’s
determination of natural background conditions. Fire had been identified by the GCVTC as a source
that can potentially overwhelm the visibility effects of all other sources on an episodic basis. The
GCVTC also established a series of Recommendations to address this potential, which were later
adopted into Section 309 of the Rule. The participating Western State Governors, Tribal Government
leaders, and Federal Departments and Agencies signed the GCVTC Recommendations. The
Annotated Policy section herein integrates some of the Recommendations as the means to implement
this Draft Policy.
The WRAP is composed of several committees and forums that are addressing specific sections of
the Rule. The FEJF is responsible for addressing fire and smoke management issues that could
impact Class I areas. The AMRF is responsible for establishing guidance on the determination of
natural background to the WRAP. The AMRF will also analyze the Interagency Monitoring of
Protected Visual Environments (IMPROVE) visibility monitoring data to demonstrate reasonable
progress toward the National Visibility Goal. This categorization of fire is necessary due to the
scientific inability to identify the source of organic carbon aerosol monitored at Federal Class I areas.
Therefore, the AMRF requested the FEJF determine which smoke emissions should be classified as
either “natural” or “anthropogenic” to facilitate the tracking of reasonable progress as well as the
establishment of natural background condition values.
The FEJF formed the NBTT to determine the classification of smoke source emissions as a
deliverable to the AMRF. The AMRF will then combine smoke source emissions with other natural
source emissions to make a final determination on natural background conditions.
The NBTT determined that three processes must be developed for the states and tribes to meet the
requirements of the Regional Haze Rule as it applies to fire emissions. Further, the NBTT
determined that these processes would need to be addressed in the following sequential order to most
effectively accomplish the Task Team’s objective.
4/5/01 Draft
Page 5 of 32
1.
Develop a methodology to categorize fire into “anthropogenic” and “natural”
source classifications.
2.
Develop approaches for estimating the contribution of fire emissions to natural
background visibility conditions.
3.
Establish methods for tracking and apportioning fire emissions into the
classifications above.
In planning the approach to categorize fire emissions, the NBTT decided a two-workshop format
would best enable the Task Team to gain the necessary input surrounding both the technical and
policy implications involved. The Senior Staff Workshop on Fire’s Contribution to Natural Visibility
was held in Denver, Colorado in January 2001, and utilized a proposed decision tree methodology
to categorize potential source emissions into either “natural” or “anthropogenic” classifications. The
following key definitions were used in the Senior Staff Workshop and are maintained in this Draft
Policy:
Natural Source Classification (“natural”) - A categorization that designates which fire
emissions result in a natural reduction of visibility for each Federal Class I area in the WRAP
region. This classification may include natural and human-caused ignitions.
Anthropogenic Source Classification (“anthropogenic”) - A categorization that designates
which fire emissions contribute to visibility impairment and must be managed to achieve
progress toward the 2064 natural visibility goal for each Federal Class I area in the WRAP
region. This classification may include natural and human-caused ignitions.
The Senior Staff Workshop utilized a decision tree approach with a series of assumptions provided
by the NBTT. The Workshop participants were split into small workgroups assigned to review the
decision tree and assumptions. There were few issues that represented a complete consensus of all
Workshop participants. However, a number of workgroups converged on similar approaches and
decision-making criteria. The Policy herein represents this convergence of thought and will be the
basis of the discussion at the Policy Maker/Opinion Leader Workshop on Fire’s Contribution to
Natural Visibility to be held in May 2001 in Tempe, Arizona.
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IV. POLICY
1. All fires classified as either “natural” or “anthropogenic” sources must be managed to minimize
visibility impacts.
2. All fires classified as “anthropogenic” sources will be controlled to reduce emissions to the
maximum extent feasible.
3. Emissions from all fires, classified as “natural” or “anthropogenic”, will be tracked.
4. Prescribed fires to maintain ecosystem health in a sustainable ecosystem are classified as a
“natural” source.
5. All other applications of prescribed fire are to be classified as an “anthropogenic” source.
6. Any escaped prescribed fire retains its pre-escape classification.
7. Wildfires, regardless of cause (accidental human ignitions, natural ignitions, or arson), that are
suppressed by management action are classified as a “natural” source. Visibility impacts from
wildfires under suppression, as determined by the monitoring data from the IMPROVE network
that have a statistically significant (e.g., =>1 deciview) effect on the natural background
condition values, will be flagged and removed from that natural background condition
calculation.
8. Wildfires that are not suppressed by management action are classified the same as prescribed
fires.
9. Native American cultural burning for religious, ceremonial or for intra-tribal commerce is
considered to be a “natural” source.
10. Native American prescribed burns will be classified the same as prescribed fires.
The following Fire Emissions Source Categorization Decision Tree is a diagrammatic representation
of the Policy.
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Figure IV-1. Fire Emissions Source Categorization Decision Tree
Native
American
Cultural
Burn
Religious,
Ceremonial,
Intra-Tribal
Commerce
N
Agricultural
Land &
Wildland
N
Escaped
Prescribed
Fire
N
Other
Prescribed
Fire
A
Escaped
Prescribed
Fire
A
Prescribed
Fire
Wildfire
Not
Suppressed
Wildfire
(arson, natural,
accidental)
Wildfire
Suppressed
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Maintain
Ecosystem
Health
N
N - Natural Source
Classification
A - Anthropogenic Source
Classification
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V. ANNOTATED POLICY
The following sections provide additional detail regarding each of the ten Draft Policy Statements
from Section IV above. The annotation for each Draft Policy Statement is separated into four
sections: Discussion, Senior Staff Workshop Results, Magnitude, and Linkage. The Discussion
section will contain pertinent definitions, rationale, and interactions with other important policies.
The Senior Staff Workshop Results section summarizes the Senior Staff Workshop conclusions and
how those were used by the NBTT in the development of this Draft Policy. The Magnitude section
highlights some of the potential effects and barriers to implementation of the respective Draft Policy
Statement and also attempts to show the scale of the fire source type. The Linkage section discusses
how the activities of the FEJF and other groups can support the implementation of the Draft Policy
Statement.
SECTION 1. MANAGEMENT OF VISIBILITY IMPACTS FROM FIRE SOURCES
Policy Statement: All fires classified as either “natural” or “anthropogenic” sources must
be managed to minimize visibility impacts.
Discussion
It was acknowledged in the GCVTC Recommendations that fire sources can overwhelm the visibility
effects of all natural and anthropogenic sources at a Federal Class I area on an episodic basis. The
recent severe wildland fire season of 2000 underscores this effect on visibility. This Policy
Statement addresses the pressing need that all fires, regardless of subsequent classification as
“natural” or “anthropogenic,” must be managed to minimize their impacts on visibility, in addition
to public health and nuisance concerns. The GCVTC recommended programmatic smoke
management as the means to address these impacts. The FEJF concept of a Basic Smoke
Management Program (BSMP) addresses all three concerns.
Senior Staff Workshop Results
The NBTT provided to the Senior Staff Workshop participants, the assumption that all fires,
regardless of classification, must be managed to minimize visibility impacts. The vast majority of
Workshop participants accepted the premise.
Magnitude
Currently in the WRAP region, most smoke management programs address only public health and
nuisance concerns. Generally they do not address all the potential visibility-impacting fire sources
nor do they have procedures to address minimization of visibility impacts. This Draft Policy
requirement will necessitate a number of changes to existing smoke management programs and the
establishment of new programs where none exist. There may be state legislative or tribal
governmental barriers to the implementation of such a policy. Almost all fire management plans do
not include visibility impact minimization elements nor are fire practitioners trained to consider
visibility impacts beyond localized safety concerns.
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Linkage
The FEJF is developing recommendations for the elements that should comprise a BSMP, which will
manage fire sources with the goal of minimizing visibility impacts. Such management may include
use of atmospheric dispersion conditions, timing of ignition and burn size, or other techniques to
minimize visibility impacts. Emissions reduction practices, although a potential element of a BSMP,
may not be a required element, and for some sources such as wildfires under suppression, may not
be feasible to employ. The recommendations for the elements of the BSMP and subsequent
management principles are currently under development by the FEJF and the BSMP Task Team.
SECTION 2. CONTROL OF ANTHROPOGENIC SOURCES
Policy Statement: All fires classified as “anthropogenic” sources will be controlled to
reduce emissions to the maximum extent feasible.
Discussion
The Anthropogenic Source Classification is a categorization that designates which fire emissions
contribute to visibility impairment and must demonstrate reasonable progress toward the 2064
natural visibility goal for each Federal Class I area in the WRAP Region. This classification may
include natural and human-caused ignitions. The GCVTC Recommendations acknowledged the role
of fire across the region and noted that the use of fire would increase in the future. Several of their
Recommendations addressed the need for minimizing the visibility impacts from such increases in
order to achieve reasonable progress. The Recommendations cited the establishment of Enhanced
Smoke Management Programs (ESMP) and an annual emissions goal to ensure visibility goals are
attained.
Elements of the ESMP are the application of emissions reduction techniques and use of alternatives
to burning, where possible, subject to economic, environmental and technical feasibility criteria. The
application of emissions reduction techniques and use of alternatives are further established in the
Regional Haze Rule. The control of “anthropogenic” fire emissions will occur through the
application of the ESMP and an annual emissions goal, in addition to the management of all fires
that will take place under the BSMP, as cited in Policy Statement 1.
Senior Staff Workshop Results
The distinction between management of all fire sources versus the control requirement of
“anthropogenic” fire sources was discussed at the Senior Staff Workshop. The direct emissions
reduction approach and use of the ESMP to achieve the requirement of reasonable progress was also
included in the assumptions provided to the Senior Staff Workshop participants. This assumption
was discussed by the various workgroups with endorsement by most participants. There were
concerns raised that the control requirement for “anthropogenic” sources may have potential
conflicts with the Agricultural Air Quality Task Force (AAQTF) recommendations4. However, the
reference to the specific ESMP criteria seemed to partially allay the concerns about how these
4 Agricultural Air Quality Task Force, Air Quality Policy on Agricultural Burning, November 10, 1999.
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“anthropogenic” fires would be controlled.
Magnitude
At this time there are no smoke management programs at the ESMP level that capture these
emissions reduction requirements or establish an annual emissions goal. The current policies and
guidance on smoke management from the EPA, i.e., the AAQTF Air Quality Policy on Agricultural
Burning and the Interim Air Quality Policy on Wildland and Prescribed Fires5, do not provide a
mechanism for this type of program. The current fire and land management plans used by land
owners/managers do not include this approach either. An underlying assumption of the GCVTC
Recommendations is that there will be significant interaction between land owners/managers with
air quality regulatory entities to establish the ESMP and set annual emissions goals. This interaction
would be required for all fires classified as “anthropogenic” and is a significant departure in some
areas from current programs. There may also exist legislative barriers to the implementation of this
Draft Policy. There are currently no systems in place to track the use of emissions reduction
practices or alternatives on a region-wide basis, which is an inherent element of this Policy Statement
and would be a key part of the annual emissions goal accounting process.
Linkage
The acknowledgment of increasing fire emissions by the GCVTC pre-dates the similar direction of
the current National Fire Policy that the federal and state land managers are striving to implement.
As the increased fire use was envisioned under the previous GCVTC Recommendations, it is
believed that the increased use of fire under the National Fire Policy can be accommodated with the
control requirement in Policy Statement 2 and the subsequent implementation of the ESMP and
annual emissions goals. The FEJF is currently developing recommendations for the ESMP and how
an annual emissions goal may be created, which will be passed on to the WRAP for approval.
The availability and feasibility of alternatives for both wildlands and agricultural lands is being
addressed by the FEJF through current contract work for the Non-Burning Alternatives on Wildlands
and Agricultural Lands Task Teams. This work will support the use of alternatives in the
development of the annual emissions goal methodology and the consideration of alternatives use in
land management and fire management plans. The Prescribed Fire Program Assessment Task Team
is creating guidance on how alternatives and emissions control may be considered in these land and
fire management plans.
5 U.S. EPA, Interim Air Quality Policy on Wildland and Prescribed Fires, April 23, 1998.
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SECTION 3. TRACKING OF FIRE EMISISONS
Policy Statement: Emissions from all fires, classified as “natural” or “anthropogenic”,
will be tracked.
Discussion
In order to determine fire’s contribution to natural background visibility conditions or anthropogenic
visibility impairment, all fire sources, regardless of ownership or land use type, need to be accounted
for in a region-wide system. Emissions from all fires will be tracked for two purposes, in order to
classify the fire as “natural” or “anthropogenic”, and if “anthropogenic”, to ensure established annual
emissions goals are being met as well as demonstrating reasonable progress. The GCVTC
Recommendations, and the subsequent Regional Haze Rule, both establish the need for a regionwide emissions tracking system for fire sources. Information about fires will include enough data,
as necessary for states and tribes to classify a fire as “natural” or “anthropogenic”, to then allow
emissions to be calculated and to provide for source attribution to occur for Federal Class I areas.
Senior Staff Workshop Results
The need to track all information required to classify a fire into its respective category was presented
to the Senior Staff Workshop participants. This information led directly to a concerted effort by
most workgroups to simplify the different fire types that result in “natural” or “anthropogenic”
classifications. There was little discussion within the groups of the implications of tracking, except
for the desire to keep the tracking as simple as possible.
Magnitude
Currently there is no region-wide system that would provide the needed information for either a fire
to be classified or for the visibility impairing pollutants to be calculated from that fire. Some states
have information that supports an emissions inventory that is focused on public health and nuisance
concerns. Current tracking systems and emissions inventories have generally not been developed
to support regional haze needs or the need to classify a fire for natural background/reasonable
progress purposes. As the number and magnitude of fire events across the region is massive,
consideration of the establishment of a de minimus level below which a fire would not be tracked
will be considered by the FEJF. An example of the sheer magnitude of the tracking task can be
found in 1996 when 35,756 wildfires on wildlands occurred across the region of which 95 percent
were of a size generally thought to be significant in terms of potential visibility effects.
There are some systems in place that allow tracking of wildfire and ignition cause (arson, natural,
etc.), but they have not been developed to allow emissions calculations at this time. The current
EPA Interim Air Quality Policy on Wildland and Prescribed Fires, and the AAQTF Air Quality
Policy on Agricultural Burning do not provide support for an emissions tracking system. There are
also potential legislative barriers to the implementation of such a tracking system in some states
where agencies are directed not to track specific types of fire.
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As technology and science develops, with regard to the ability to differentiate fire impacts on Federal
Class I areas as compared to other sources, the needs and methods of tracking are anticipated to
change.
Linkage
Both the BSMPs and ESMPs are envisioned to have emissions tracking and inventory requirements.
As established above, the two programs will differ, as will the extent of the emissions tracking
information needed. The FEJF is developing the recommendations for both types of programs for
the WRAP. The Emissions Task Team of the FEJF, in coordination with other WRAP Forums, is
addressing the actual elements and methods for tracking.
As tracking is critical to success of the overall Draft Policy, and the information will be used to
apportion the IMPROVE data and used in modeling exercises to show that reasonable progress is
being made, specific tracking needs will also be coordinated with the AMRF. Other national policies
support increased information on fire and respective emissions for national emissions inventory
requirements, as well as for land management agency goals.
SECTION 4. PRESCRIBED FIRE FOR ECOSYSTEM MAINTENANCE
Policy Statement: Prescribed fire to maintain ecosystem health in a sustainable ecosystem
is classified as a “natural” source.
Discussion
A prescribed fire is any fire ignited by management actions to meet specific objectives (i.e., managed
to achieve resource benefits) on agricultural land or wildland. Prescribed fires may have various
purposes including vegetative residue disposal, commodity production, ecosystem restoration,
ecosystem maintenance, hazard reduction, and single-purpose benefit. This portion of the Draft
Policy only addresses prescribed fires conducted for the purpose of ecosystem maintenance.
Prescribed fires conducted for any other purpose are addressed in Policy Statement 5.
Ecosystem maintenance fires occur primarily on wildlands in ecosystems that are in a healthy and
sustainable condition. Ecosystem maintenance fires may also occur on agricultural lands in the
Conservation Reserve Program (CRP) that are in a healthy and sustainable condition. An ecosystem
is considered to be sustainable at the point at which ecosystem health is not destroyed but is
enhanced by fire, and the planned application of fire is needed to keep the system in a fully
functional and resilient condition.
Sustainable ecosystems are functioning within their range of natural variability, and have either not
been affected by the forces of man (e.g., livestock grazing, past fire suppression efforts, cultivation,
invasion of exotic species), or have undergone successful restoration efforts. The natural range of
variability is the range of conditions within which a vegetative community can perpetuate itself over
time and may be expressed through consideration of a variety of factors that could include: presence
of natural vegetation, natural fire cycle, fuel loading, and absence of invasive species.
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The underlying principle for the classification of prescribed fires for ecosystem maintenance as
“natural” is the fact that these ecosystems are in, as closely as can be determined, their natural range
of variability.
This portion of the Draft Policy also applies to wildfires that are not suppressed by management
action, as addressed by Policy Statement 8, but are managed for the resource objective of ecosystem
maintenance.
Senior Staff Workshop Results
There was majority sentiment at the Senior Staff Workshop that all prescribed fire conducted for
ecosystem maintenance should be considered “natural”. The rationale for that classification is that
prescribed fires for ecosystem maintenance are beneficial to the natural ecosystem process and are
applied to keep the ecosystem within its range of natural variability. The participants also expressed
that prescribed fires of this type would produce emissions comparable to natural emissions.
Magnitude
In order to estimate the potential amount of emissions from ecosystem maintenance fire sources in
the WRAP region, the NBTT has reviewed the Cohesive Strategy6 for restoring ecosystem health
in fire-adapted ecosystems by the Forest Service and a similar Cohesive Strategy7 being developed
by the Department of Interior (USDI). Of the 1.9 billion acres of land in the contiguous United
States, the USDI manages about 228 million acres and Forest Service manages approximately 196
million acres. These Cohesive Strategies identify that 144 million acres of lands they manage are
considered healthy and sustainable, with fire regimes within historical ranges. Nationally over the
next 15 years, the USDI intends to perform ecosystem maintenance on approximately 60 million
acres of land8 and the Forest Service plans to treat 18.5 million acres. Furthermore, the Forest
Service plans to treat approximately 6.8 million acres over the next 15 years within the WRAP
region. Ecosystem maintenance treatment will be achieved through a variety of methods including,
but not limited to, prescribed fire and mechanical manipulation of vegetation. Further detail on the
USDI and Forest Service Cohesive Strategies may be found in Appendix D.
Linkage
Prescribed fire for maintenance of ecosystem health will be managed to minimize visibility impacts
under the BSMP being developed by the FEJF. The potential visibility effects of such fires on
Federal Class I areas would also be required to be analyzed prior to ignition per the GCVTC
Recommendations. Development of the methods of such an analysis and how they would be
addressed in a fire plan or land management plan is a primary activity of the Prescribed Fire Program
Assessment Task Team of the FEJF.
6 USDA – Forest Service, Protecting People and Sustaining Resources in Fire-Adapted Ecosystems; A Cohesive
Strategy, October 13, 2000.
7 USDI, Integrating Fire and Natural Resource Management; A Cohesive Strategy for Protecting People by
Restoring Land Health, March 2001, Draft.
8 Personal Communication, Timothy Sexton, National Fire Ecologist, National Park Service
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SECTION 5. PRESCRIBED FIRE FOR ALL OTHER PURPOSES
Policy Statement: All other applications of prescribed fire are to be classified as an
“anthropogenic” source.
Discussion
A prescribed fire is any fire ignited by management actions to meet specific objectives (i.e., managed
to achieve resource benefits) on agricultural land or wildland. Prescribed fires conducted for any
purpose, except ecosystem maintenance, are addressed in this Policy Statement.
Prescribed fire may be conducted for the purpose of vegetative residue disposal where land
management related fuel or vegetation is burned to dispose of the fuel accumulation. Prescribed fire
may be used in support of economic activities related to increasing or maintaining agricultural and
silvicultural output or increasing forage values. Fires to support economic activities often have the
purpose of removing crop residue, controlling weeds, pests, and disease, and improving yield.
Burning may also be conducted in areas of accumulated wildland fuels to reduce the risk of wildfire,
particularly in the wildland/urban interface or areas of especially combustible fuels. The needs of
an individual flora or fauna species or human use, that is not vital to the overall ecosystem
management, may be met through the use of prescribed fire.
While prescribed fires conducted for ecosystem maintenance were addressed in Policy Statement 4;
prescribed fires conducted for ecosystem restoration are addressed in this portion of the Draft Policy.
Prescribed fires and mechanical treatments may be necessary to restore an ecosystem to a state
consistent with its range of natural variability. Ecosystem restoration is the re-establishment of
natural vegetation and may be accomplished through the reduction of unwanted and/or unnatural
levels of biomass, which may have accumulated due to management action (e.g., wildland fire
suppression). Ecosystem restoration may also be used to control undesirable plant species.
Ecosystem restoration prescribed fires may be conducted on wildland or agricultural lands in the
Conservation Reserve Program.
This portion of the Draft Policy also applies to wildfires that are not suppressed by management
action, as addressed by Policy Statement 8, but are managed for a resource objective other than
ecosystem maintenance.
One of the primary Recommendations of the GCVTC states “the Commission recognizes that fire
plays a significant role in visibility on the Plateau. In fact, land managers propose aggressive
prescribed fire programs aimed at correcting the buildup of biomass due to decades of fire
suppression. Therefore, prescribed fire and wildfire levels are projected to increase significantly
during the studied period [i.e., 1995-2040, --ed.]. The Commission recommends the implementation
of programs to minimize emissions and visibility impacts from prescribed fire, as well as to educate
the public”.9
9 Report of the Grand Canyon Visibility Transport Commission to the United States Environmental Protection
Agency, Recommendations for Improving Western Vistas, June 1996, Page ii.
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Senior Staff Workshop Results
The possibility of individually categorizing all of the potential prescribed fire types was considered
by the Senior Staff Workshop participants. However, they agreed that prescribed fires that were not
conducted for ecosystem maintenance should be categorized the same, regardless of the purpose for
the burn. This included prescribed fires for vegetative residue disposal, commodity production,
hazard reduction, and single-purpose benefit, as well as for ecosystem restoration.
While the Senior Staff Workshop participants recognized that prescribed fires will be necessary to
restore or attain a sustainable ecosystem, most rejected classifying these fires the same as ecosystem
maintenance fires. One of the key facts behind that rationale is that past land management decisions
and practices, including nearly a century of aggressive fire suppression, have resulted in an
“unnatural” fuels buildup in the wildlands. As a result, the participants stated that the present and
future land management decisions and practices to correct the “unnatural” fuels buildup should be
classified “anthropogenic”, in order to assure the control of these fires.
Although there was agreement to differentiate between prescribed fire for maintenance purposes
versus all other prescribed fire, there was incomplete agreement at the Senior Staff Workshop on
what other criteria, if any, should be used to categorize prescribed fire. Workshop participants
explored the following three possible criteria, with the shared underlying premise that opportunities
should be utilized to reduce visibility impacts if there is a chance to do so. This Draft Policy does
not recommend any one of the following as criteria for further differentiating prescribed fire
classification due to the participants’ lack of agreement on one criterion. However, the NBTT
anticipates that states and tribes may utilize the following criteria in an ESMP, which includes
elements such as the application of emission reduction techniques and use of alternatives to burning,
toward visibility impact reduction.
Alternatives to Burning
Several of the workgroups suggested using the criteria of “alternatives to burning” to determine
a fire’s classification. It was carried forward that a prescribed fire might be classified as a
“natural” source if there were no legal, technically feasible, environmentally sound, and
economically reasonable alternatives to fire available. However, if alternatives to fire are
available (legal, technically feasible, environmentally sound, and economically reasonable) and
fire was used anyway, the classification would be “anthropogenic”.
Less Emissions than Natural Vegetation
One of the workgroups used the premise of “less emissions than natural vegetation” as the basis
for their categorization methodology. This resulted in a prescribed fire being classified as a
“natural” source if the prescribed fire produced less emissions than would exist from the burning
of natural vegetation. This could be accomplished through the use of verifiable emissions
reduction practices that would minimize emissions increases to the maximum extent feasible.
Key points to consider when using this criterion would be the determination of the natural
vegetation, natural fire cycle, fuel loading, invasive species, and a method to determine potential
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emissions from natural vegetation.
Natural Fire Season
There was some discussion of utilizing the criterion of “prescribed fires conducted in or out of
the natural fire season” to determine a fire’s classification. Under this method prescribed fires
conducted in the natural fire season were classified as a “natural” source. The rationale for using
this criterion is to take into consideration that burning in different seasons may have different
emissions and associated impacts, and burning within the natural fire season is mimicking the
natural impacts during that season.
Magnitude
Prescribed fires that are classified as “anthropogenic”, whether set intentionally or wildfires that are
not being suppressed, would be controlled and subject to demonstration of reasonable progress. The
level of emissions control beyond current management levels employed in contemporary smoke
management programs is a dramatic shift for fire practitioners and air quality regulators. This shift
will require implementation of appropriate programs to ensure that the emissions are controlled.
In order to estimate the potential amount of emissions from prescribed fire sources conducted for any
purpose except ecosystem maintenance, the NBTT has reviewed the AAQTF Air Quality Policy on
Agricultural Burning10. According to the AAQTF, there are over 295 million acres of cropland
harvested annually in the United States and burning is used on approximately 8.9 million acres each
year. An additional 2.5 million acres of non-crop land adjacent to agricultural operations is burned
annually to control weeds and pests in ditches and adjacent, non-crop land areas, to control wildfire,
and to clear land. As of October 2000, more than 33 million acres were enrolled in the Conservation
Reserve Program11 and it is estimated that approximately 2 million acres of CRP land is burned
annually. Rangeland and pasture land account for about 725 million acres of land in the contiguous
United States. Of this, about 18 million acres is estimated to be burned annually. The NBTT did not
have sufficient information to present data regarding the magnitude of commercial woodlot acreage
and burning.
For a refined estimate of the potential amount of emissions from ecosystem restoration fire sources
in the WRAP region, the NBTT once again reviewed the Cohesive Strategy12 for restoring ecosystem
health in fire-adapted ecosystems by the Forest Service and a similar Cohesive Strategy13 being
developed by the USDI. The USDI and Forest Service Cohesive Strategies identify that fire regimes
on 176 million acres of lands they manage are considered moderately altered from their historical
range. These Cohesive Strategies identify that, nationally over the next 15 years, ecosystem
restoration treatments need to be applied to 25.5 million acres of Forest Service lands and 13 million
10 Agricultural Air Quality Task Force, Air Quality Policy on Agricultural Burning, November 10, 1999, Pages 6-7.
11 USDA Economic Research Service
http://www.ers.usda.gov/briefing/ConservationAndEnvironment/Questions/consenvcrp1.htm
12 USDA – Forest Service, Protecting People and Sustaining Resources in Fire-Adapted Ecosystems; A Cohesive
Strategy, October 13, 2000.
13 USDI, Integrating Fire and Natural Resource Management – A Cohesive Strategy for Protecting People by
Restoring Land Health, March 2001, Draft.
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acres of USDI land. Of the ecosystem restoration treatments to be applied nationally by the Forest
Service, 20 million acres of land will be treated in the WRAP region. Treatments for ecosystem
restoration on moderately altered lands may include prescribed fire as well as mechanical or
chemical restoration treatment, and the reintroduction of native species. Further detail on the
Department of Interior and Agriculture Cohesive Strategies can be found in Appendix D.
Linkage
The FEJF is developing recommendations for the WRAP for an ESMP along with methods for
establishing an annual emissions goal, which is envisioned to be the means for implementing control
strategies for these sources.
SECTION 6. ESCAPED PRESCRIBED FIRE
Policy Statement: Any escaped prescribed fire retains its pre-escape classification.
Discussion
An escaped prescribed fire is any fire ignited by management actions on wildland or agricultural land
to meet specific objectives that goes out of prescription (e.g., fire intensity greater than specified in
a pre-set fire plan, pre-set wind speeds exceeded, fire jumps pre-established boundaries, etc.) in a
predefined geographic area.
The underlying principle for the classification of escaped prescribed fires remaining under their preescape designation is that these were controllable events at one time that have now become
uncontrollable. Prescribed fires have a means of controllability at the ignition stage of the burn.
Escaped prescribed fires cannot occur if there was not initially a prescribed fire.
Senior Staff Workshop Results
The NBTT initially presented to the Senior Staff Workshop the concept of classifying an escaped
prescribed fire using the same rationale as the classification of an accidental human ignition
becoming a wildfire, i.e., based on the inability to control smoke from these fires. While some of
the participants retained that reasoning, the workgroups that addressed this issue in more detail came
to the general agreement that the fire’s classification should not be revised just because it has gone
out of prescription and may now be uncontrollable.
Magnitude
Most prescribed fires in the WRAP region are accomplished with few or no control problems. In
the last five years only one percent of prescribed fires on National Forest System land escaped and
became wildfires (230 fires out of 23,022 escaped).14 Estimates of the escape rate are approximately
less than one percent for the National Park Service as well.15 Prescribed fires that escape become
wildfires, and are suppressed by management action once declared an escaped prescribed fire.
14 Personal Communication, David Bunnell, National Fuels Specialist, USDA - Forest Service
15 Personal Communication, Timothy Sexton, National Fire Ecologist, National Park Service
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The prescribed fire, originally classified as “anthropogenic”, will retain the “anthropogenic”
classification if it escapes control and therefore, will fall under the ESMP and count towards the
demonstration of reasonable progress. This implies that there will be incentives for using
suppression strategies for these events that result in the least amount of emissions feasible, which
is a departure from current smoke management program practice.
Linkage
Regardless of the classification of the prescribed fire (“anthropogenic” -- which will fall under an
ESMP control approach, or “natural” -- which will fall under a BSMP management paradigm), the
different levels of smoke management strategies are being developed under the auspices of the FEJF.
The FEJF recommendations for a BSMP and an ESMP will be submitted to the WRAP for review
and approval.
SECTION 7. WILDFIRE SUPPRESSED BY MANAGEMENT ACTION
Policy Statement: Wildfires, regardless of cause (accidental human ignitions, natural
ignitions, or arson), that are suppressed by management action are classified as a
“natural” source. Visibility impacts from wildfires under suppression, as determined by
the monitoring data from the IMPROVE network that have a statistically significant (e.g.,
=>1 deciview) effect on the natural background condition values, will be flagged and
removed from that natural background condition calculation.
Discussion
Wildfires that are under suppression are unwanted, non-structural fires that are being actively
suppressed due to threats to public health and safety, firefighter safety, or damage to property and/or
natural resources. They can be caused by both natural causes, such as lightning, or human causes
such as accidental human ignitions or intentional ignitions (i.e., arson). Examples of accidental
human ignitions include fireworks, cigarettes, escaped campfires, vehicle fires, and fires from other
types of equipment. Arson is defined as the intentional start of a fire with the intent to either
maliciously or fraudulently damage property of one’s own or that of another party.
The term “management action” refers to a combination of strategies defined in a fire management
plan and/or during the fire itself. In the analysis of a wildfire, several strategies are detailed and
describe a set of possible firefighting tactics and their potential for success, trade-offs, and potential
consequences. Potential consequences are things such as suppression cost, resource damage,
property damage, acres burned and smoke impacts to the public and firefighters.
The underlying principle for classifying wildfires suppressed by management action as “natural” is
the general inability to control smoke from these fires. The inability to control these emissions,
along with the fact that, in most instances, all that can be done is being done, was a key reason for
the inclusion of this category as a “natural” source. Smoke and air quality are currently
considerations in the suppression strategies and tactics used by some land managers. These events
4/5/01 Draft
Page 19 of 32
still fit under the rubric of the BSMP through which smoke management principles would be
applied, when they are possible. It is recognized that increased effectiveness of fire prevention
efforts aimed at human ignitions could potentially reduce this source.
The potential for significant visibility impacts from episodic wildfires under suppression is high, as
demonstrated by recent wildfire seasons. The severity of impacts from these individual wildfire
events and all wildfire events averaged across the landscape as well as over significant time periods,
could result in dramatic effects on the establishment of natural background conditions for the most
and least impaired days for each Federal Class I area in the WRAP region.
Using a parallel concept of the Natural Events Policy16 for flagging and exempting monitored data
exceeding the particulate matter health standard caused by a natural event, the monitored data for
visibility would be flagged and potentially exempted from the determination of most and least
impaired days. This would occur when the data monitored by the IMPROVE network appears to
have a statistically significant effect (e.g., => 1 deciview) from wildfires under suppression. In this
way, the visibility improvements resulting from emissions reduction programs for industrial, mobile,
and other anthropogenic sources would not be masked by visibility impacts from wildfires under
suppression. Concomitantly, the demonstration of reasonable progress would not be dominated by
the visibility impacts to the natural background condition of these uncontrollable wildfires.
Senior Staff Workshop Results
The Senior Staff Workshop participants considered the possibility of individually categorizing
wildfire ignition sources. However, there was substantial agreement that all wildfires, with the
exception of arson ignitions, that are actively suppressed should be categorized as a “natural” source.
This included wildfires from accidental human or natural ignitions. Workshop participants
recognized that wildfires that are suppressed by management action, whether by accidental human
or natural ignition, are unplanned events over which land owners/managers can exert little or no
control. The participants also acknowledged that smoke from wildfires that are suppressed by
management action can not be controlled to reduce emissions.
The NBTT’s addition of arson to wildfires, and their subsequent classification as “natural”, is the
only significant deviation from the majority opinion expressed by the participants of the Senior Staff
Workshop. The consensus of the Workshop participants was to classify arson as an “anthropogenic”
source because it is human-caused and unlawful. However, when the NBTT reviewed the Workshop
rationale that resulted in a “natural” categorization for wildfires that are being suppressed by
management action from accidental human or natural ignitions, they recognized a parallel to arson
fires; the inability to control the fire and subsequent emissions. Applying this same seminal rationale
to wildfires being suppressed by management action caused by arson ignitions, they were likewise
included in the “natural” classification.
Magnitude
The emissions and subsequent visibility effects of wildfire are highly variable both spatially and
16 U.S. EPA, Natural Events Policy for Particulate Matter, June 6, 1996.
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Page 20 of 32
temporally. Wildfire activity can range dramatically from year to year in the same state, as
demonstrated in Wyoming where approximately 1.5 million acres were burned by wildfire in 198817
and less than 9 thousand acres were burned in 1993.18 Further support of this variability, which will
dramatically affect visibility, can be found in Appendix B where the high, low, and median values
of acres burned in wildfire for the respective year can be found. This variability and the magnitude
of emissions supports the establishment of the Natural Events Policy type of approach for wildfires
being suppressed by management action within the natural background condition estimation process.
The percentage of wildfire activity and emissions that are associated with natural ignitions versus
accidental human or arson varies greatly both temporally and spatially. This variability is captured
in Appendix C. During certain years, the percentage of arson wildfires can dominate all other
ignition types, including natural, which if the wildfire is being suppressed by management action,
could have significant ramifications and compromise the ability to demonstrate reasonable progress
toward the natural visibility goal.
Currently, few smoke management programs track or address wildfires suppressed by management
action. The current smoke management programs do not manage wildfires, which they would have
to do under a BSMP type system.
Linkage
The FEJF is developing recommendations for the BSMP that will include concepts on how to best
manage wildfires for visibility purposes. The Emissions Task Team of the FEJF will be developing
the methods and criteria (i.e., de minimus size) for the tracking of these fires, which will be of
significant importance to the natural events type flagging of data that may be necessary.
SECTION 8. WILDFIRE NOT SUPPRESSED BY MANAGEMENT ACTION
Policy Statement: Wildfires that are not suppressed by management action are classified
the same as prescribed fires.
Discussion
Wildfire Managed for Resource Benefits and Prescribed Natural Fire are both terms that have current
use in regulations and policies, and are considered to be synonymous. These terms refer to the
management of fires to accomplish specific, pre-stated resource management objectives in
predefined geographic areas, under pre-determined conditions (e.g., weather, firefighting resources
available, etc.) as outlined in a fire management plan or as applied in the field without a plan.
The key distinction between Policy Statement 7 and Policy Statement 8 is the potential to achieve
resource benefits from managing a wildfire ignition. The intent of this classification is to address
those wildfires that have approved plans in place by the respective land manager, which allow for
these incidents to be managed for resource benefits. It is not intended to interject air quality control
17 USDA - Forest Service, Fire and Aviation Management, 1984 – 1990 Wildland Fire Statistics, September 1998.
18 USDA - Forest Service, Fire and Aviation Management, 1991 – 1997 Wildland Fire Statistics, September 1998.
4/5/01 Draft
Page 21 of 32
principles into the strategic decisions associated with firefighter health and safety or resource
availability on wildfires.
At present, these types of fires will occur primarily on federally managed lands. The 2001 Federal
Wildland Fire Policy provides direction and guidance that allows this appropriate management
response. It is possible that in the near future state, tribal, public, or private landowners may choose
to utilize the same appropriate management response in order to achieve resource benefits from
managing a wildfire ignition, but without a plan in place.
As there is an application of management choice and control in the decision-making process for
these fires, the underlying principle guiding the classification of these fires is the potential for
emissions control similar to prescribed fires. There is a conscious management decision to allow
these incidents to grow because of the resource benefits that may be accrued. If the resource
objective of the wildfire were ecosystem maintenance, it would fall into the “natural” classification
(see Policy Statement 4); all other resource objectives fall into the “anthropogenic” classification (see
Policy Statement 5).
Senior Staff Workshop Results
The Senior Staff Workshop participants supported a different classification for wildfires based on
the management aspect (i.e., managed for resource benefit vs. suppression) selected for the wildfire.
There was substantial agreement among the Workshop participants that wildfires managed for
resource benefits are the result of a calculated management decision and thus, should be treated as
a prescribed fire and classified according to the same criteria.
Magnitude
The scope and scale of this type of wildfire will be increasing. Per assessments conducted by the
GCVTC’s Fire Emissions Project, the use of this type of fire is seen as an economic and appropriate
means to allow fire to play a more natural role in the ecosystems in the WRAP region. Initially, the
use of this type of approach has been centered in National Parks and Wilderness areas. However, the
current wildland fire policies support expanding the use of this approach to all areas where it may
be safely applied. The use of this approach is highly dependent on climatological and meteorological
factors that have high variability both spatially and temporally. Using Arizona as an example,
around five percent of the acreage burned in prescribed fires in 1998 was under this type of approach,
while other years have seen less than one percent. As approaches and plans are developed to support
the new 2001 Federal Wildland Fire Policy, there is expected to be a significant increase in the use
of wildland fire managed for resource benefit.
Linkage
This type of fire and how it should be addressed in smoke management plans as well as fire and land
management plans is being addressed by the FEJF in several different task teams. This type of fire
is also being considered in the Emissions Task Team’s development of a WRAP region-wide
approach to emissions tracking.
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SECTION 9. NATIVE AMERICAN CULTURAL BURNING
Policy Statement: Native American cultural burning for religious, ceremonial or for intratribal commerce is considered to be a “natural” source.
Discussion
This Draft Policy applies to vegetative burning conducted by Native Americans for religious and
ceremonial purposes, as well as commerce burning for intra-tribal utilization. These burning
practices may include, but are not limited to, sustainable plant vegetation land burning to increase
the yield for tribal use (e.g., huckleberries), and tule burning for intra-tribal basket making and use.
The NBTT has identified the need to distinguish between religious and ceremonial burning practices,
and smaller scale burns, (e.g., sweat lodge fires).
This Draft Policy does not apply to Native American cultural non-vegetative burning for religious
or ceremonial purposes, e.g., cremation, sweat lodge fires, etc. Individual tribes may identify these
burning practices by resolution, rule or ordinance as established by the tribal council for ceremonial
or religious use. These practices and burns will not be tracked or considered in the establishment
of either natural background conditions nor toward the reasonable progress requirements of the
Regional Haze Rule. The sovereign status of the tribes and rights afforded them by the Religious
Freedom Act further support the limitation to the scope of this Draft Policy. The amount of
emissions from these practices and their potential for significant visibility impact is estimated to be
very small when compared to the other source categories addressed by this Draft Policy.
Senior Staff Workshop Results
Although many Senior Staff Workshop participants indicated that they did not have adequate
information and/or expertise with regard to this issue, most participants categorized Native American
cultural burning as a “natural” source classification. Some participants classified these emissions as
“anthropogenic”, but suggested they should not be tracked. A common rationale for both of these
classifications was that the emissions from these types of fires were not significant enough to track.
In light of this, this Draft Policy reflects Native American cultural burning as a “natural” source
classification.
The distinction made in this Draft Policy between intra-tribal utilization and off-tribal-land
commerce, see the annotation for Policy Statement 10, reflects the difference recognized by the
Workshop participants between Native American cultural burning for traditional practices versus
prescribed burning in support of a modern economy, regardless of land ownership.
Magnitude
The NBTT did not have sufficient information to present data regarding the magnitude of these types
of burning practices. However, it is estimated that these types of burning practices will potentially
fall below the de minimus levels established in a BSMP (see Policy Statement 3) and by the FEJF
Emissions Task Team.
4/5/01 Draft
Page 23 of 32
Linkage
The FEJF BSMP Task Team is working with the Institute for Tribal Environmental Professionals
to collect information on Tribal Smoke Management Programs. This information will be used as
the FEJF develops its recommendation for a BSMP and ESMP.
SECTION 10. NATIVE AMERICAN PRESCRIBED BURNING
Policy Statement: Native American prescribed burns will be classified the same as
prescribed fires.
Discussion
This Policy Statement addresses burning activities on tribal lands not classified as religious or
ceremonial burning. Thus, the emissions from all prescribed fires that fall into this category need
to be tracked and classified equitably according to this Draft Policy (see Policy Statements 4 and 5).
Included in this category are Native American prescribed burns for the purpose of off-tribal-land
commerce. These are burning activities occurring on tribal lands used to support commodity
production (e.g., yield improvement or vegetative residue disposal) for goods that are produced for
and used off tribal lands. Some examples of these types of fires include burning the slash from
logging activity where the timber is exported off tribal lands, or burning agricultural croplands to
increase yield production for off-tribal-land commerce of the crop.
Senior Staff Workshop Results
Although many Senior Staff Workshop participants indicated that they did not have adequate
information and/or expertise with regard to this issue, most participants categorized Native American
prescribed burning the same as prescribed fires, regardless of land ownership. Some participants
recognized that the emissions from these types of fires could have a significant impact on visibility
due to the proximity of some tribal lands to Federal Class I areas.
The distinction made in this Draft Policy between intra-tribal utilization and off-tribal-land
commerce reflects the difference recognized by the Workshop participants between Native American
cultural burning for traditional practices versus prescribed burning in support of a modern economy,
regardless of land ownership.
4/5/01 Draft
Page 24 of 32
Magnitude
An assessment of how many acres are burned by prescribed fire on Tribal lands is not readily
available. At the request of the FEJF BSMP Task Team, the Institute for Tribal Environmental
Professionals is currently conducting a survey of tribal burning programs, and the results from that
survey may provide information on the burning occurring on tribal lands in the WRAP region. The
same condition classes used by federal land management agencies (see Appendix D) also exist on
tribal lands. Tribal lands are also the focus of increased use of fire to address the ecological health
of the lands and concerns for human health and safety.
Linkage
The FEJF BSMP Task Team is working with the Institute for Tribal Environmental Professionals
to collect information on Tribal Smoke Management Programs. This information will be used as
the FEJF develops its recommendation for a BSMP and ESMP, as well as any recommendations on
land and fire management plans with alternatives use or emissions control measures.
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Page 25 of 32
VI. APPENDICES
APPENDIX A. DEFINITIONS
This appendix is not intended to be a complete glossary of all terms. This appendix is intended to
provide readers with several operating definitions to facilitate a consistent review of the Draft Policy.
Agricultural Land* - Agricultural land includes croplands, pasture, and other lands on which crops
or livestock are produced (PL 104-127, Section 1240A). Rangeland will be included with wildland
for the purposes of the FEJF work.
Anthropogenic Source Classification (“anthropogenic”) - A categorization that designates which fire
emissions contribute to visibility impairment and must be managed to achieve progress toward the
2064 natural visibility goal for each Federal Class I area in the WRAP region. This classification
may include natural and human-caused ignitions.
Fire* - When this term appears, it refers inclusively to wildfire, prescribed natural fire/wildland fire
managed for resource benefits, prescribed fire, rangeland fire, and agricultural fire.
Natural Source Classification (“natural”) - A categorization that designates which fire emissions
result in a natural reduction of visibility for each Federal Class I area in the WRAP region. This
classification may include natural and human-caused ignitions.
Pasture Land - Grazing lands comprised of introduced or domesticated native forage species that are
used primarily for the production of livestock. They receive periodic renovation and/or cultural
treatments such as tillage, fertilization, mowing, weed control, and may be irrigated. They are not
in rotation with crops (Natural Resources Conservation Service National Range and Pasture
Handbook, 1997.)
Rangeland - Land on which the historic climax plant community is predominantly grasses, grasslike
plants, forbs, or shrubs. Includes lands revegetated naturally or artificially when routine management
of that vegetation is accomplished mainly through manipulation of ecological principles. Rangeland
includes natural grasslands, savannas, shrublands, most deserts, tundra, alpine communities, coastal
marshes and wet meadows (Natural Resources Conservation Service National Range and Pasture
Handbook, 1997.)
Silviculture - The theory and practice of controlling forest establishment, composition, and growth.
The art of producing and tending a forest.
* Operating Definitions from Section 1.1 of the WRAP FEJF Workplan dated February 25, 1999.
4/5/01 Draft
Page 26 of 32
Wildland* - An area where development is generally limited to roads, railroads, power lines, and
widely scattered structures. The land is not cultivated (i.e., the soil is disturbed less frequently than
once in 10 years), is not fallow, and is not in the USDA Conservation Reserve Program (CRP). The
land may be neglected altogether or managed for such purposes as wood or forage production,
wildlife, recreation, wetlands, or protective plant cover (EPA Interim Air Quality Policy on
Wildlands and Prescribed Fires). The land is not “agricultural land” as operationally defined above.
Silvicultural land and rangelands (per the FEJF charge), woodlots, and private timberlands will be
included with wildlands for the purposes of the FEJF work.
* Operating Definitions from Section 1.1 of the WRAP FEJF Workplan dated February 25, 1999.
4/5/01 Draft
Page 27 of 32
APPENDIX B. WILDFIRE VARIABILITY – ACRES BURNED PER YEAR19
Variance in Wildland Acres Burned for Western States
(1984 - 1997)
1,600,000
1,537,302
(1988)
Median
1,400,000
1,200,000
Acres
1,000,000
840,399
(1987)
800,000
740,161
(1996)
600,000
820,400
(1985)
658,714
(1988)
553,110
(1996)
390,431
(1994)
400,000
200,000
0
307,675
(1994)
251,555
(1995)
104,966
(1996)
15,203
(1997)
AZ
42,354
(1991)
CA
7,275
(1992)
CO
184,477
(1985)
137,758
(1988)
4,958
(1993)
ID
8,701
(1987)
MT
4,480
(1995)
ND
37,307
(1984)
NM
32,280
(1997)
NV
12,688
(1993)
OR
19 USDA - Forest Service, Fire and Aviation Management, 1984 – 1990 Wildland Fire Statistics, September 1998.
USDA - Forest Service, Fire and Aviation Management, 1991 – 1997 Wildland Fire Statistics, September 1998.
4/5/01 Draft
Page 28 of 32
4,979
(1986)
SD
6,271
(1995)
WA
8,911
(1993)
WY
APPENDIX C. WILDFIRE VARIABIILITY – IGNITION SOURCE
Table C-1. Annual Range of Acres Burned by Wildfire in the WRAP Region by Ignition Source20
Lightning (acres)
Year
high
low
Arson (acres)
median
high
low
Debris Burning (acres)
median
high
low
Accidental Human Ignition (acres)
median
high
low
median
1984
MT
226,325
WA
2,649
16,231
NV
24,146
CO
38
987
CA
35,742
NM
872
2,968
CA
79,112
WA
8,136
17,198
1985
NV
792,703
ND
4,494
32,910
CA
178,121
CO
21
2,199
SD
54,401
UT
682
3,411
CA
138,787
MT
2,292
21,704
1986
ID
377,688
ND
225
16,423
CA
21,278
WY
41
2,358
CA
8,809
MT
224
2,055
CA
63,600
WA
1,836
17,718
1987
CA
734,304
ND
90
35,739
CA
22,180
MT
40
2,241
SD
23,380
NV
1,296
5,386
CA
65,114
ND
2,901
22,149
1988
WY
982,193
UT
24,909
36,951
CA
87,608
WY
869
5,693
CA
40,134
UT
1,632
3,768
WY
550,543
CO
24,311
61,661
1989
ID
192,000
ND
515
18,004
CA
50,419
MT
16
1,083
NM
23,346
NV
428
3,446
NM
156,857
ND
6,117
10,750
1990
CA
142,101
ND
2,039
29,850
ID
74,754
SD
2
1,367
MT
29,531
NV
671
2,433
CA
146,307
NV
2,871
11,452
1991
MT
224,483
CO
1,334
9,685
SD
14,763
WY
106
619
MT
24,360
UT
221
3,301
WA
44,606
UT
1,823
22,654
1992
ID
602,436
ND
733
22,290
CA
89,031
SD
26
1,904
WA
8,526
NV
116
4,827
CA
164,534
CO
2,748
19,309
1993
NM
205,368
ND
17
4,425
CA
24,233
ID
16
1,188
AZ
12,248
WY
601
3,096
CA
177,587
SD
2,617
5,274
1994
ID
593,679
ND
2,996
161,603
CA
133,474
SD
87
4,560
NM
11,068
OR
621
4,947
CA
114,769
SD
5,662
31,252
1995
ID
170,463
ND
116
29,500
CA
23,788
SD
19
737
ID
20,443
NV
126
2,777
CA
156,961
ND
2,037
12,069
1996
ID
599,588
ND
928
145,752
CA
162,150
SD
262
2,631
ID
13,370
AZ
1,388
5,343
CA
353,566
ND
4,745
52,278
1997
UT
21,910
SD
209
12,051
CA
27,640
NV
1
614
CA
20,851
NV
318
2,306
CA
120,992
MT
3,408
5,503
20 USDA - Forest Service, Fire and Aviation Management, 1984 – 1990 Wildland Fire Statistics, September 1998.
USDA - Forest Service, Fire and Aviation Management, 1991 – 1997 Wildland Fire Statistics, September 1998.
4/5/01 Draft
Page 29 of 32
Table C-2. Annual Range of Ignition Source Contribution to Wildfire in the WRAP Region by Ignition Source21
Lightning (%)
Year
high
low
Arson (%)
median
high
low
Debris Burning (%)
median
high
low
Accidental Human Ignition (%)
median
high
low
median
1984
OR
89.0
SD
14.9
32.3
WA
10.6
CO
0.2
4.7
SD
36.9
MT
0.6
3.4
AZ
69.3
OR
7.5
43.5
1985
NV
96.6
SD
14.4
55.9
CA
38.5
CO
0.1
3.3
SD
29.5
NV
0.2
4.0
ND
59.1
NV
2.6
30.0
1986
ID
92.9
ND
3.5
61.3
CA
20.2
WY
0.2
3.0
SD
38.0
ID
0.3
4.2
NM
61.9
ID
6.0
22.6
1987
CA
87.4
ND
0.8
41.0
ND
13.3
MT
0.5
2.6
ND
60.2
OR
1.3
9.7
CO
68.0
CA
7.7
25.7
1988
ID
74.4
CA
15.4
40.7
CA
29.8
WY
0.1
5.6
SD
28.3
WY
0.2
4.1
WA
66.7
ID
19.5
41.2
1989
ID
94.0
ND
3.0
49.2
CA
32.2
ID
0.0
2.3
ND
52.3
NV
1.2
4.2
SD
62.6
ID
3.7
35.6
1990
OR
90.1
ND
13.1
47.4
ID
58.2
SD
0.0
1.7
MT
27.8
ID
0.7
5.8
SD
78.9
NV
7.5
34.3
1991
UT
80.3
WA
5.2
21.4
SD
18.9
WY
0.1
2.2
ND
37.9
NV
1.2
6.9
WA
87.7
MT
8.8
53.4
1992
ID
93.6
SD
3.5
43.5
CA
31.1
SD
0.0
3.7
WA
21.1
NV
0.1
9.3
SD
87.2
ID
3.5
43.2
43.1
1993
NM
59.9
ND
0.1
15.8
SD
48.0
ID
0.3
6.2
ND
65.8
NV
1.3
15.3
CA
80.7
UT
18.1
1994
MT
89.5
ND
12.6
79.2
CA
33.5
MT
0.2
2.4
SD
29.5
OR
0.3
2.0
ND
61.5
ID
7.5
14.7
1995
NV
90.0
ND
2.6
59.4
CA
12.0
SD
0.0
1.4
ND
45.2
NV
0.1
8.3
CA
78.9
NV
4.5
28.9
1996
UT
91.5
ND
6.0
58.3
CA
24.0
WY
0.2
1.6
ND
48.4
OR
0.3
1.3
WA
72.9
NV
4.5
30.5
1997
UT
73.0
SD
3.8
41.9
CA
15.0
NV
0.0
2.7
WA
34.0
NV
1.0
12.0
NM
82.8
UT
17.4
39.1
21 USDA - Forest Service, Fire and Aviation Management, 1984 – 1990 Wildland Fire Statistics, September 1998.
USDA - Forest Service, Fire and Aviation Management, 1991 – 1997 Wildland Fire Statistics, September 1998.
4/5/01 Draft
Page 30 of 32
APPENDIX D. DEPARTMENT OF INTERIOR AND FOREST SERVICE,
COHESIVE STRATEGIES INFORMATION
Of the 1.9 billion acres of land in the contiguous United States, the Department of Interior (USDI)
(Bureau of Land Management, Bureau of Indian Affairs, Fish and Wildlife Service, National Park
Service) manages about 228 million acres and Department of Agriculture - Forest Service manages
approximately 196 million acres. The Forest Service has recently completed a Cohesive Strategy22
for restoring ecosystem health in fire-adapted ecosystems and the Department of Interior is currently
developing a similar Cohesive Strategy23. The Cohesive Strategies identify lands in two types of fire
regimes and three fire condition classes that are planned to be managed over the next 15 years.
The two types of fire regimes are:
Frequent -- These are fire regimes with a fire return interval between 0 and 35 years.
Infrequent -- These are fire regimes with a fire return interval greater than 35 years.
The three-fire condition classes22 are:
Condition Class 1
For the most part, fire regimes in this condition class are within historical
ranges. Thus, the risk of losing key ecosystem components from the
occurrence of fire in these lands is relatively low. Maintenance management
such as prescribed fire, mechanical treatments, or preventing the invasion of
non-native weeds, is needed to prevent these lands from becoming degraded.
Condition Class 2
Fire regimes on these lands have been moderately altered from their historical
range, either increased or decreased fire frequency. A moderate risk of losing
key ecosystem components has been identified in these lands. To restore
their historical fire regimes, these lands may require some level of restoration
through prescribed fire, mechanical or chemical treatments, and the
subsequent reintroduction of native plants.
Condition Class 3
These lands have been significantly altered from their historical range.
Because fire regimes have been extensively altered, risk of losing key
ecosystem components from fire is high. Consequently, these lands verge on
the greatest risk of ecological collapse. To restore their historical fire
regimes, before prescribed fire can be utilized to manage fuels or obtain other
desired benefits, these lands may require multiple mechanical or chemical
restoration treatments. In addition, the need for reintroduction of native
species on these lands is considered to be high.
22 USDA – Forest Service, Protecting People and Sustaining Resources in Fire-Adapted Ecosystems; A Cohesive
Strategy, October 13, 2000.
23 USDI, Integrating Fire and Natural Resource Management – A Cohesive Strategy for Protecting People by
Restoring Land Health, March 2001, Draft.
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Page 31 of 32
Table D-1. Current Condition Class and Fire Regime Acres (Millions)24 25 26
AGENCY
FIRE
REGIME
CONDITION
CLASS 1
CONDITION
CLASS 2
CONDITION
CLASS 3
TOTAL
All USDI Lands*
Infrequent
43
40
35
118
All USDI Lands*
Frequent
23
66
21
110
All USDI Lands*
TOTAL
66
106
56
228
USDA - Forest
Service Lands*
Infrequent
51
29
19
99
USDA - Forest
Service Lands*
Frequent
27
41
29
97
USDA - Forest
Service Lands*
TOTAL
78
70
48
196
USDI & Forest
Service Lands*
TOTAL
144
176
104
424
* On conterminous United States land
24 USDI, Integrating Fire and Natural Resource Management – A Cohesive Strategy for Protecting People by
Restoring Land Health, March 2001, Draft.
25 Personal Communication, Timothy Sexton, National Fire Ecologist, National Park Service
26 USDA Forest Service, Rocky Mountain Research Station, Fire Sciences Laboratory , Historical Fire Regimes by
Current Condition Classes Data Summary Tables, February 15, 2000, Fire Modeling Institute, Missoula, Montana.
4/5/01 Draft
Page 32 of 32
FIRE EMISSION SOURCE CATEGORIZATION DECISION TREE
CHANGE GUIDE
Fire Emissions Joint Forum – Natural Background Task Team
6/21/01
The Natural Background Task Team (NBTT) of the Fire Emissions Joint Forum hosted a Fire’s
Contribution to Natural Visibility – Senior Staff Workshop in Denver, Colorado on January 2425, 2001. In order to facilitate and focus the discussion of the Workshop participants, the
Natural Background Task Team developed a Fire Emissions Source Categorization Decision
Tree (Decision Tree). The Decision Tree diagramed all of the potential emissions sources and
their differences based on stakeholder position and Regional Haze Rule assumptions that could
then be classified as “natural” or “anthropogenic”. At the Workshop, eight workgroups were
tasked with simplifying or modifying the Decision Tree to reflect concurrence or rejection with
these distinctions, or to introduce new distinctions.
The NBTT used the compilation of workgroup results to identify comparable recommendations,
similar rationale for changes and recommendations, and consensus between Senior Staff
Workshop workgroups. The results of that review formed the basis for the Draft Policy for
Categorizing Fire Emissions1 and Fire Emissions Source Categorization Decision Tree contained
therein. The Draft Policy applies to wildland and agricultural lands, regardless of ownership,
cause of ignition, or purpose of the fire. The Draft Policy does not apply to other open burning
activities, regardless of the purpose of the burn, on residential property or tribal lands.
This paper is a guide to the changes made from the original Decision Tree branches, utilized at
the Senior Staff Workshop, to the Fire Emissions Source Categorization Decision Tree that is a
diagrammatic representation of the Draft Policy for Categorizing Fire Emissions. The numbers
for the descriptions below (1 – 14) correspond to the numbers on the original Decision Tree
branches and the Fire Emissions Source Categorization Decision Tree from the Draft Policy
found on pages 4 – 6 of this Change Guide.
1. The Fire Emissions Source Categorization Decision Tree applies regardless of land use and
ownership. This reduced the wildland and agricultural branches down to one tree branch.
2. Intentional Ignition, Agricultural Burn, and Prescribed Fire did not prove to be separate
distinctions in the classification of the resultant emissions, to the Senior Staff Workshop
participants, and were combined in the Decision Tree as Prescribed Fire.
1 Natural Background Task Team of the Fire Emissions Joint Forum, Draft Policy for Categorizing Fire Emissions,
April 5, 2001.
II-57
3. The cause of the wildfire (i.e., natural, accidental, or arson ignition) is not as important as
the subsequent management action taken to suppress the wildfire. Wildfires suppressed by
management action are classified as “natural” due to the general inability to control smoke
from these fires. Wildfires that are not suppressed by management action are discussed in
number 8 below.
4. There is an inability to control an arson fire, a human-caused and unlawful fire, and
subsequent emission. This seminal rationale applies to wildfires that are being suppressed
by management action from accidental human and natural ignitions. Therefore, wildfires
suppressed by management action caused by arson ignitions are included in the “natural
classification” as described in number 3 above.
5. The Fire Emissions Source Categorization Decision Tree does not apply to other open
burning activities on tribal lands, e.g., cremation, sweat lodge fires, etc. The vegetative
burning conducted by Native Americans for religious and ceremonial purposes, as well as
commerce burning for intra-tribal utilization is classified as “natural”. Native American
prescribed burning activities, that are not classified as religious or ceremonial burning, are
classified the same as prescribed fires, regardless of land ownership.
6. Senior Staff Workshop participants indicated that a fire’s classification should not be revised
just because it has gone out of prescription and may not be controllable. Any escaped
prescribed fire retains its pre-escape classification, as it was previously a controllable event
that has become uncontrollable. Estimates of the prescribed fire escape rate are
approximately less than one percent.
7. Whether vegetation was “natural” or “intensively managed” did not prove to be an important
distinction in the classification of the resultant emissions, to the Senior Staff Workshop
participants, and was removed from the Decision Tree.
8. Wildfires that are not suppressed by management action are routed to the prescribed fire
portion of the Decision Tree and can then be classified the same as prescribed fires. This
distinction addresses those wildfires that have approved plans in place by the respective land
manager, which allow for those incidents to be managed for resource benefits. As there is an
application of management choice and control in the decision-making process for those fires,
the underlying principle guiding the classification of those fires is the potential for emission
control similar to prescribed fires.
9. These distinctions were removed from the Decision Tree but are integrated in two underlying
premises of the Fire Emissions Source Categorization Decision Tree:
a. All fires classified as either “natural” or “anthropogenic” sources must be managed
to minimize visibility impacts.
b. All fires classified as “anthropogenic” sources will be controlled to reduce emissions
to the maximum extent feasible.
II-58
The GCVTC acknowledged the role of fire across the region and several of their
Recommendations addressed the need for programmatic smoke management to address
public health and nuisance concerns as well as the minimization of visibility impacts from
increases in fire use. It is the intention of the FEJF concepts of Basic and Enhanced Smoke
Management Programs as well as annual emissions goals to further the GCVTC
Recommendations and satisfy the requirements in the Regional Haze Rule.
10. There is an inability to control an illegal, un-permitted, unregulated burns and subsequent
emissions in a meaningful way. Senior Staff Workshop participants recognized that this
seminal rationale is similar to that applied to wildfires that are being suppressed by
management action. Therefore, this distinction was removed from the Decision Tree.
11. The consideration of prescribed fires conducted in an area exempt from permitting or
external regulatory control did not prove to be an important distinction to the Senior Staff
Workshop participants in the classification of the resultant emissions and was removed from
the Decision Tree.
12. The various potential prescribed fire types did not prove to be separate distinctions to the
Senior Staff Workshop participants in the classification of the resultant emissions.
Prescribed fires that are not conducted for ecosystem maintenance are categorized the same,
regardless of the purpose for the burn, as Other Prescribed Fire.
13. Prescribed fires for ecosystem maintenance are classified as “natural” as these fires are
beneficial to the natural ecosystem process and are applied to keep the ecosystem in, as
closely as can be determined, the natural range of variability. Some Senior Staff Workshop
participants also expressed that prescribed fires of this type would produce emissions
comparable to natural emissions.
14. There was incomplete agreement at the Senior Staff Workshop on what other criteria, if any,
should be used to categorize prescribed fire, beyond the differentiation between prescribed
fire for maintenance purposes versus all other prescribed fire. Workshop participants
explored these possible criteria, which the shared underlying premise that opportunities
should be utilized to reduce visibility impacts if there is a chance to do so. These criteria
were removed from the Decision Tree due to the participants’ lack of agreement on one
criterion. However, the NBTT anticipates that states and tribes may utilize these possible
criteria in an Enhanced Smoke Management Program toward visibility impact reduction.
II-59
Agricultural
Land Branch
Change Guide
Arson
4
12
5
2
Intentional
Ignition
Native
American
Cultural
Burn
5
Escaped
Agricultural
Burn
1
Agricultural
Land
3
Accidental
Human
Ignition
3
Intensively
Managed
Vegetation
7
7
Wildland
Go To WildBranch land
Natural
Ignition
Intensively
Managed
Vegetation
12
2
6
12
NonCommodity
Waste
5
Traditional
Agricultural
Burn
Waste
Disposal
Religious or
Ceremonial
12
Commodity
Waste
Weed/
Pest/Disease
Mgt.
9
9
Burn
Authorization
Process
SMP
Authorized
12
Commodity
Production
11
Legal
Un-permitted
Unregulated
7
II-60
Yield
Improvement
12
Ecosystem
Restoration
14
More
Emissions
than Natural
Vegetation
14
12
10
Illegal
Un-permitted
Unregulated
14
Less
Emissions
than Natural
Vegetation
Less
Emissions
than Natural
Vegetation
14
More
Emissions
than Natural
Vegetation
4
Wildland Branch
Change Guide
Arson
2
Intentional
Ignition
Native
American
Cultural
Burn
5
12
Hazard
Reduction
Religious or
Ceremonial
5
Restore or 12
5
2
Attain
Sustainable
Ecosystem
6
Maintain
Ecosystem
Health
Traditional
Prescribed
Fire
1
Escaped
Prescribed
Fire
Wildland
3
Accidental
Human
Ignition
3
Natural
Ignition
13
Intensively
Managed
Vegetation
Natural
Vegetation
Intensively
Managed
Vegetation
Natural
Vegetation
WFMRB/PNF
Go To Pres.
Above Fire
9
Burn
Authorization
Process
7
SMP
Authorized
9
Illegal 10
Un-permitted
Unregulated
7
11
Legal
Un-permitted
Unregulated
7
Waste
Disposal
Single
Purpose
Benefit
12
12
12
7
Commodity
Production
8
II-61
Non-Fire
Treatment
Available
Only Fire
Treatment
Available
In Natural
Fire Season
14
14
14
14
Out of Natural
Fire Season
Commodity
Waste
12
NonCommodity
Waste
12
Less
Emissions
than Natural
Vegetation
14
More
Emissions
than Natural
Vegetation
14
Fire Emissions Source Categorization Decision Tree2
Religious,
Ceremonial,
Intra-Tribal
Commerce
5
1
Native
American
Cultural
Burn
5
N
13
2
9
Agricultural
Maintain
Ecosystem
Health
Prescribed
Fire
Land &
Wildland
8
3
4
Wildfire
(arson, natural,
accidental)
3
Wildfire
Suppressed
12
Other
Prescribed
Fire
Wildfire
Not
Suppressed
N
N
6
Escaped
Prescribed
Fire
A
N
6
Escaped
Prescribed
Fire
A
N - Natural Source
Classification
A - Anthropogenic Source
Classification
2 Natural Background Task Team of the Fire Emissions Joint Forum, Draft Policy for Categorizing Fire Emissions,
April 5, 2001, page 8.
II-62
Fire’s Contribution to Natural Visibility –
Policy Maker/Opinion Leader Workshop
May 2, 2001 – Tempe, Arizona
Participant Information
* Denotes Person that Participated in Senior Staff Workshop on Fire’s
Contribution to Natural Visibility, January 24-25, 2001, Denver, Colorado.
II-63
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II-64
Policy Maker Participants
Fire’s Contribution to Natural Visibility – Policy Maker/Opinion Leader Workshop
Tempe, Arizona
May 2, 2001
WRAP Members
Brian Gustafson
SD Dept. of Env. & Natural Resources
Designated Alternate WRAP Member
Air Quality Administrator
523 E. Capitol
Pierre, SD 57501
Ph 605-773-3151
brian.gustafson@state.sd.us
Margie M. Perkins
Colorado Dept. of Public Health & Env.
Designated Alternate WRAP Member
Director Air Pollution Control Division
4300 Cherry Creek Drive South
APCD-ADM B1
Denver, CO 80246
Ph 303-692-3115
Fax 303-782-5493
margie.perkins@state.co.us
Lyle Laverty*
USDA Forest Service
Designated WRAP Member
P.O. Box 25127
Lakewood, CO 80225_0127
Ph 303-275-5450
Fax 303-275-5754
llaverty@fs.fed.us
Robert Raisch
Montana Dept. of Environmental Quality
Designated WRAP Member
Chief, Resource Protection Planning Bureau
1520 East Sixth Avenue
P.O. Box 200901
Helena MT 59620-0901
Ph 406-444-3658
Fax 406-444-6836
braisch@state.mt.us
Dianne R. Nielson
UT Dept. of Environmental Quality
Designated Alternate WRAP Member
Executive Director
168 North 1950 West
Salt Lake City, UT 84114
Ph 801-536-4440
Fax 801-536-0061
drnielso@deq.state.ut.us
Chris Shaver
National Park Service, Air Resources Div.
Designated Alternate WRAP Member, DOI
Chief ARD
P.O. Box 25287
Denver, CO 80225
Ph 303-969-2074
Fax 303-969-2822
chris_shaver@nps.gov
II-65
WRAP State Regulatory
Dan Olson
Wyoming Dept. of Environmental Quality
Air Quality Division Administrator
122 W. 25th Street
Cheyenne, WY 82002
Ph 307-777-7391
Fax 307-777-5616
dolson@state.wy.us
Richard Tobin
Arizona Dept. of Environmental Quality
Deputy Director
3033 N. Central Avenue
Phoenix, AZ 85012
Ph 602-207-2204
rwt@ev.state.az.us
Tribal
Kevin McKernan*
Yurok Tribe
Environmental Program Director
PO Box 355
Orick, CA 95555
Ph 707-834-2536
Fax 707-488-2106
kevinmck@reninet.com
Moses D. Squeochs
Yakama Nation Environmental Program
Environmental Manager
PO Box 151
Toppenish, WA 98948
Ph 509-865-5121
Fax 509-865-6850
mose@yakama.com
EPA
Jack Edwardson
Associate Director, Air Quality Strategies & Standards Division
EPA OAQPS
Mail Drop 15
Research Triangle Park, NC 27711
Ph 919-541-4003
Fax 919-541-0804
edwardson.jack@epa.gov
Department of the Agriculture - Forest Service
Joel Holtrop
USDA - Forest Service
14th & Independence S.W.
Washington, DC 20250
Ph 202-205-1167
jholtrop@fs.fed.us
Department of the Interior
Tim Hartzell
BLM, Office of Wildland Fire Coordination
ms 2241-MIB
1849 C Street, NW
Washington, DC 20240
Ph 202-606-3211
Fax 202-606-3150
tim_hartzell@blm.gov
II-66
Non-WRAP State Regulatory
Colleen Cripps*
Nevada Division of Environ. Protection
333 W. Nye Lane
Carson City, NV 89701
Ph 775-687-4670, x3065
Fax 775-687-6396
ccripps@govmail.state.nv.us
Local Regulatory
David Jones*
San Joaquin Valley Air Pollution Control District
1990 E. Gettysburg Avenue
Fresno, CA 93726-0244
Ph 559-230-5812
Fax 559-230-6064
dave.jones@valleyair.org
Power
Edward Fox
Pinnacle West Capital Corporation
400 N. 5th Street
Phoenix, AZ 85004
Ph 602-250-2916
Fax 602-250-3813
Edward.Fox@pinnaclewest.com
Copper
Kenneth E. Evans
Phelps Dodge Corporation
1501 W. Fountainhead Pkwy, Ste 290
Tempe, AZ 85282-1846
Ph 480-929-4514
Fax 480-929-4506
kevans@phelpsdodge.com
Wood Product Industry
Chuck Burley
American Forest Resource Council
131 NW Hawthorne Ave., Ste 108
Bend, OR 97701
Ph 541-389-2306
Fax 541-388-0979
cburley@afrc.ws
II-67
Agriculture
Gregory J. Josten
South Dakota Dept. of Agriculture
3305 ½ West South Street
Rapid City, SD 57702
Ph 605-394-2395
Fax 605-394-2549
greg.josten@state.sd.us
Mike Weber
Central Oregon Seeds, Inc.
1747 NW Mill St.
Madras, OR 97741
Ph 541-475-7231
Fax 541-475-7233
mikew@madras.net
State Forestry
Louis Blumberg
CA Dept. of Forestry and Fire Protection
1416 9th Street
P.O. Box 944246
Sacramento, CA 94244_2460
Ph 916-653-1586
Louis_Blumberg@fire.ca.gov
Kirk Rowdabaugh*
Arizona State Land Department
Director, Fire Management Division
2901 W. Pinnacle Peak Road
Phoenix, AZ 85027
Ph 602-255-4059
Fax 602-255-1781
krowdabaughaz@cybertrails.com
Environmental
H.B. “Doc” Smith
Northern Arizona University
Ecological Restoration Institute
P.O. Box 15018
Flagstaff, AZ 86011
Ph 520-523-7502
Fax 520-523-0296
doc.smith@nau.edu
II-68
Concerned Stakeholder Participants
Fire’s Contribution to Natural Visibility – Policy Maker/Opinion Leader Workshop
Tempe, Arizona
May 2, 2001
WRAP State Regulatory
Mike George*
Arizona DEQ
3033 N. Central
Phoenix, AZ 85012
Ph 602-207-2274
Fax 602-207-2366
george.mike@ev.state.az.us
Dana K. Mount
ND Dept. of Health, Env. Health Section
1200 Missouri Avenue Room 304
Bismarck, ND 58506-5520
Ph 701-328-5202
Fax 701-328-5200
dmount@state.nd.us
Annette Liebe
Oregon Dept. of Environmental Quality
811 SW 6th Ave.
Portland, OR 97204_1390
Ph 503-229-6919
Fax 503-229-5675
liebe.annette@deq.state.or.us
Bob Saunders
WA Dept. of Ecology
Air Quality Division
PO Box 47600
Olympia, WA 98504
Ph 360-407-6888
Fax 360-407-7534
Rsau461@ecy.wa.gov
Tribal
Rose Lee*
Yakama Nation Environmental Program
P.O. Box 151
Toppenish, WA 98948
Ph 509-865-4565
Fax 509-865-5522
rose@yakama.com
Don Motanic*
Intertribal Timber Council
1112 NE 21st Avenue
Portland, OR 97232
Ph 503-828-4296
Fax 503-282-1274
donmo@itcnet.org
Amy Mignella
White Mountain Apache Tribe
Special Counsel
PO Box 64792
Tucson, AZ 85728-4792
Ph 520-319-2459
Fax 520-319-1275
amytm9@home.com
Molly Pitts
White Mountain Apache Tribe
Woodland Forester, Tribal Forestry
PO Box 700
Whiteriver, AZ 85941
Ph 520-338-1665
Fax 520-338-1907
mollypitts@cybertrails.com
II-69
EPA
Larry Biland
EPA Region IX (AIR-7)
75 Hawthorne St
San Francisco, CA 94105-3901
Ph 415-744-1227
biland.larry@epamail.epa.gov
Rich Damberg
EPA OAQPS
Mail Drop 15
Research Triangle Park, NC 27711
Ph 919_541_5592
damberg.rich@epa.gov
Department of the Interior
John Philbin
Bureau of Indian Affairs
Western Region, Regional Forester
PO BOX 10
Phoenix, AZ 85001
Ph 602-379-6798
Fax 602-379-6826
johnphilbin@bia.gov
Dr. Peter Teensma
USDI – Bureau of Land Management
1849 C Street NW (MS314LS)
Washington, DC 20240
Ph 202-452-5053
Fax 202-653-5279
pteensma@blm.gov
Department of the Agriculture - Forest Service
Suraj Ahuja, Ph.D.
USDA - Forest Service
Mendocino National Forest
825 N. Humboldt
Willows, CA 95988
Ph 530-934-3316
Fax 530-934-7384
sahuja@fs.fed.us
Patti Hirami*
USDA - Forest Service/Fire & Aviation
P.O. Box 96090
Washington, DC 20090
Ph 202-205-1498
Fax 202-205-1272
phirami@fs.fed.us
Donna V. Lamb*
USDA - Forest Service
14th & Independence S.W.
Washington, DC 20250
Ph 202-205-0800
dlamb@fs.fed.us
Dennis Haddow*
USDA - Forest Service
Air Program Manager, Rocky Mountain and
Intermountain Regions
PO Box 25127
Lakewood, CO 80225
Ph 303-275-5759
Fax 303-275-5754
dhaddow@fs.fed.us
Non-WRAP State Regulatory
Ron King
Alaska Dept. of Environ. Conservation
410 Willoughby Ave., Suite 303
Juneau, AK 99801-1795
Ph 907-465-5100
Fax 907-465-5129
rking@envircon.state.ak.us
II-70
Wood Product Industry
Mike Dykzeul*
Oregon Forest Industries Council
Director, Forest Protection
P.O. Box 12826
Salem, OR 97309-0826
Ph 503-371-2942
Fax 503-371-6223
mike@ofic.com
Scott Kuehn*
Plum Creek Timber
140 N. Russell
Missoula, MT 59801
Ph 406-542-3273
Fax 406-549-1885
skuehn@plumcreek.com
Small Industry
Steve Brittle
Don’t Waste AZ, Inc., President
6205 S. 12th St.
Phoenix, AZ 85040
ph 602-268-6110
fax 602-268-0915
dwaz@fastq.com
Agriculture
Kim Christy
Utah Farm Bureau
9865 So. State
Sandy, UT 84070
Ph 801-233-3004
Fax 801-233-3030
kimchristy@sisna.com
Forestry
Steve Ambrose
USDA - Forest Service
Assistant Regional Forester
Western Forestry Coordination Center
2950 Youngfield St.
Littleton, CO 80127
ph 303-239-3882
fax 303-239-3811
sambrose@fs.fed.us
Environmental
Joseph L. Johnson
Nevada State Environ. Commission
(state lobbyist for Sierra Club)
935 Sherwood Drive
Reno, NV 89509-2234
Ph 775-348-7192
sierrajj@aol.com
Dr. Robert Palzer
Chair, Sierra Club Air Committee
501 Euclid
Ashland, OR 97520
Ph 541-482-2492
Fax 541-482-0152
bob.palzer@sierraclub.org
II-71
Academic
F.E. “Fee” Busby
Utah State University
College of Natural Resources
5200 Old Main Hill
Logan, UT 84322-5200
Ph 435-797-2452
Fax 435-797-2443
feebusby@cnr.usu.edu
Charlie Denton
Northern Arizona University
Ecological Restoration Institute
P.O. Box 15018
Flagstaff, AZ 86011
Ph 520-523-7502
Fax 520-523-0296
charlie.denton@nau.edu
WRAP State Non-Regulatory
Art Reese*
WY Office of Federal Land Policy, Director
122 West 25th St
Herschler Building, 1 West
Cheyenne, WY 82002
Ph 307-777-3697
areese@state.wy.us
WRAP Project Officers
Patrick Cummins*
Western Governors’ Association
1515 Cleveland Place, Suite 200
Denver, CO 80202
Ph 303-623-9378
Fax 303-534-7309
pcummins@westgov.org
Bill Grantham
National Tribal Environmental Council
2221 Rio Grande Blvd. NW
Albuquerque, NM 87104
Ph 505-242-2175
Fax 505_242_2654
bgrantham@ntec.org
WRAP Communications Committee
Dan Clark
Communications Committee Representative
Wyoming DEQ, Office of Outreach
122 W. 25th Street
Cheyenne, WY 82002
Ph 307-777-7388
Fax 307-777-3610
dclark@state.wy.us
Regional Planning Organization
Bob Hannesschlager
CenSARA
Senior Advisor
10005 S. Pennsylvania, Ste C
Oklahoma City, OK 73159
ph 214-665-3188
bobh@censara.org
II-72
NBTT Resource Team
Fire’s Contribution to Natural Visibility – Policy Maker/Opinion Leader Workshop
Tempe, Arizona
May 2, 2001
Mark Fitch*
Arizona DEQ; Air Quality Division
3003 N. Central Avenue
Phoenix, AZ 85012
Ph 602-207-2374
Fax 602-207-2366
fitch.mark@ev.state.az.us
Jim Russell*
Pacific Northwest Region/OR/WA State Office
FS and BLM
333 S.W. First Avenue
P.O. Box 3623
Portland, OR 97208-3624
Ph 503-808-2956
jrussell01@fs.fed.us
Carl Gossard*, NBTT Co-Chair
Bureau of Land Management
National Interagency Fire Ctr
3833 South Development Ave
Boise, ID 83704-5354
Ph 208-387-5419
Fax 208-387-5179
cgossard@nifc.blm.gov
David (Sam) Sandberg*, Ph.D.
Pacific Northwest Research Station, USDA
Forest Service
3200 SW Jefferson Way
Corvallis, OR 97331
Ph 541-750-7265
dsandberg@fs.fed.us
John Graves*
BIA c/o ADEQ-AQD
3033 N. Central Avenue
Phoenix, AZ 85014
Ph 602-207-2277
graves.john@ev.state.az.us
Mike Ziolko*
Oregon Department of Forestry
2600 State Street, Building 2
Salem, OR 97310
Ph 503-945-7452
mziolko@odf.state.or.us
Peter Lahm*, FEJF Co-Chair
USDA, Forest Service c/o ADEQ-AQD
3033 N. Central Avenue
Phoenix, AZ 85014
Ph 602-207-2356
Fax 602-207-2366
pete_lahm@compuserve.com
Facilitator
Darla Potter*, NBTT Co-Chair
Wyoming Air Quality Division
122 West 25th Street
Herschler Building, 4 West
Cheyenne, WY 82002
Ph 307-777-7346
Fax 307-777-5616
dpotte@state.wy.us
Rebecca Reynolds*
Rebecca Reynolds Consulting, Inc.
10841 East 155th Place
Brighton, CO 80602
Ph 303-655-3773
Fax 303-655-3776
rbr@thunderworks.com
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II-74
APPENDIX III.
FURTHER POLICY DEVELOPMENT
WRAP May 23-24, 2001 Meeting
FEJF July 11-12, 2001 Meeting
AAQTF July 18-19, 2001 Meeting
[Ed note: This document has been formatted
for 2-sided printing (i.e., duplex printing).]
Further Policy Development
WRAP May 23-24, 2001 Meeting
NBTT Work Summary
NBTT Briefing Summary
Summary Paper
III-1
[This page intentionally left blank.]
III-2
NBTT Briefing Summary
WRAP Meeting – May 24, 2001
Introduction
Peter Lahm, FEJF Co-Chair, presented a Fire Emissions Joint Forum (FEJF), Natural
Background Task Team (NBTT) Work Summary at the May 24, 2001 Western Regional Air
Partnership (WRAP) meeting. In preparation for the presentation a Summary Paper, Fire’s
Contribution to Natural Visibility Senior Staff Workshop and Policy Maker/Opinion Leader
Workshop, May 17, 2001 was prepared by the NBTT of the FEJF for the May 23-24, 2001
WRAP meeting.
The Work Summary was designed to allow the meeting participants to follow the progression of
the work accomplished to date as well as the NBTT and FEJF decisions, and was composed of
the following elements:
•
•
•
•
•
NBTT Task: Develop a Categorization Methodology for Fire
Senior Staff Workshop
Draft Policy for Categorizing Fire Emissions
Policy Maker Workshop
Post Policy Maker Workshop
During the presentation of the Post Policy Maker Workshop portion of the Work Summary,
WRAP meeting attendees were asked for their feedback on the following items:
! Initial Post Policy Maker Workshop Findings
" Restructure Draft Policy into two associated sections.
# Classification Policy for “natural” and “anthropogenic” fire sources
# Implementation Policy
Note: The interrelationships between the implementation approach and classifications
were a key portion of the Work Summary.
" Better linkage with the National Fire Plan definitions.
! Guiding Principles
" Equity among all large sources of fire emissions.
" Application of emissions controls on sources that could feasibly be controlled to
demonstrate reasonable progress.
" Use of Regional Haze Rule and/or Grand Canyon Visibility Transport Commission
(GCVTC) language to ensure consistency and allow Draft Policy linkage to SIPs/TIPs.
" Consistent Smoke Management Programs for both Sections 309 and 308 of the Regional
Haze Rule.
A copy of the Work Summary presentation slides may be found at the end of this NBTT Briefing
Summary paper.
III-3
WRAP Feedback
The following is a summary of the feedback obtained at the WRAP meeting. The majority of the
people in attendance at the WRAP meeting are people who will implement the Recommended
Policy for Categorizing Fire Emissions through SIPs/TIPs.
•
The Draft Policy’s inclusion of arson ignition in wildfire caused some discussion of concerns
for the WRAP, as it contradicts the WRAP Annex language and approach to stationary
sources. The Annex approach subtracts illegal emissions out of the overall emissions budget.
This has implications for the Annex and its treatment of illegal emissions and is an issue for
the WRAP to consider and sort out.
•
Some feedback was obtained on Draft Policy Statement #6 (re: Escaped Prescribed Fire)
regarding the perception of a “free lunch” for a fire that escapes. However, there was
acknowledgement that in reality the magnitude of acreage burned is small for this category.
The discussion regarding the classification of Escaped Prescribed Fire did not resolve the
classification for this type of fire or result in absolute disagreement in the direction being
taken in the Draft Policy by the NBTT.
•
The relationship between Draft Policy Statements #4 & #5 (re: Prescribed Fire) was
discussed, as well as similar programs for Sections 308 & 309 with the possible need for
augmentation for Section 308. The concept of similar Section 308 & 309 programs made
sense to those in attendance at the WRAP meeting.
•
The addition of feasibility language (i.e., “subject to economic, technical,…”) in Draft Policy
Statement #2 is supported by those in attendance at the WRAP meeting. However, there is an
expectation that the FEJF provide some guidance toward the feasibility segment. This can be
accomplished as a tag-on to the Alternatives Work being done by other Task Teams of the
FEJF on Agricultural Land and Wildland.
•
The biggest concern expressed at the meeting will be the tie in with Agriculture.
• Pete Lahm will be on the agenda for the July 19th Agriculture Air Quality Task Force
meeting in Denver, CO.
• Assistance with the agricultural community may be necessary and some assistance was
offered in this area. The assistance mentioned includes the ability for the NBTT and FEJF to
ask WRAP representatives to go to their agriculture constituency for comment on the Draft
Policy.
• In Colorado there is no agricultural land smoke management program and the wildland
program has just been set up. How would the Implementation Policy steps work in
Colorado?
• To assist states, such as Colorado, a commitment was made by Pete Lahm to create a
matrix relating Draft Policy Statement #3 (re: tracking) to Policy Statements #1 (re:
management) and #2 (re: control), i.e., how management goes from nothing now to the next
levels.
III-4
•
A question was raised by California as to how a state would have an existing program and
add the elements of Draft Policy Statement #2 through an ESMP. A follow-up question was
what constitutes an ESMP. An Emissions Inventory analogy was used to explain the
difference: a BSMP emissions inventory may track particulate matter on an annual basis vs.
an ESMP which may track all pollutants including those that affect visibility on an episodic
basis.
•
For the BSMP/ESMP the FEJF needs to develop a matrix of how emissions tracking fits into
a BSMP and progresses to an ESMP to identify the differentiation points. A matrix such as
this will be the most helpful for states and tribes with programs at various stages of
development.
•
When a Recommended Policy is brought before the WRAP in the fall of 2001 for approval it
needs to be a firm, full Recommended Policy from the FEJF so that the WRAP can consider
its approval.
•
The Draft Policy needs to relate the emissions inventory and tracking aspects.
•
The NBTT has the liberty not to follow the feedback from the Policy Maker Workshop.
•
The WRAP meeting attendees gave no negative feedback regarding the equity among all
large sources of fire emissions regardless of land ownership (federal, state, tribal, private,
etc.). The Draft Policy should specify the same management/control scheme and treatment
for all large sources of fire emissions.
•
Concern was expressed about managing and/or controlling wildfire as an additional
consideration on top of all the other considerations wildfire incident teams deal with “on the
ground”. The Forest Service responded that to a certain extent wildfires are already being
managed given air quality considerations, but this would be supported more when included in
the Draft Policy.
•
Link Draft Policy as tightly to the Grand Canyon Visibility Transport Commission and
Regional Haze Rule Section 309 (i.e., pre-existing agreements) as possible!
NBTT Next Steps
The NBTT is committed to the following items in the preparation of a Recommended Policy for
Categorizing Fire Emissions:
! Maintain the following Guiding Principles
" Equity among all large sources of fire emissions.
" Application of emissions controls on sources that could feasibly be controlled to
demonstrate reasonable progress.
" Use of Regional Haze Rule and/or Grand Canyon Visibility Transport Commission
(GCVTC) language to ensure consistency and allow Draft Policy linkage to SIPs/TIPs.
III-5
!
!
!
!
!
" Consistent Smoke Management Programs for both Sections 309 and 308 of the Regional
Haze Rule.
Split the classification from the implementation/management aspects of the Recommended
Policy. Although the sections are still interdependent it should help to reduce some issues.
Add “feasibility” language to Draft Policy Statement #2 with an associated commitment from
the FEJF to develop guidance for the “feasibility” implementation.
Recognize traditional Native American burning in association with religious and ceremonial
burning in Draft Policy Statement #9.
Removal of Draft Policy Statement #10 (re: Native American Prescribed Burning).
Several changes and additions to the Annotation Sections
" Include linkage to the National Fire Plan (elements & definitions) explicitly not
implicitly.
" Recognize severe wildland fuel conditions in the West.
" Recognize that the use of prescribed fire will increase in federal, state, and private sectors
through the National Fire Plan. The funds are in place through the National Fire Plan.
" Discuss that assessment and classification will occur at the local level rather than at a
programmatic level.
" Discuss alternatives to burning.
" Discuss suggestions for tracking emissions.
" Remove the Magnitude, Linkage, and Senior Staff Workshop Results sections from the
Annotation Sections.
The NBTT is now in the process of analyzing the WRAP feedback and Policy Maker Workshop
discussion notes to identify suggested changes to the Draft Policy Statements and annotated
sections. The results of this analysis will be the basis for the Recommended Policy for
Categorizing Fire Emissions.
III-6
Categorization of Fire Sources
Fire Emissions Joint Forum
Natural Background Task Team
Work Summary
v Scientific
inability to identify the source of
monitored organic carbon aerosol
v Categorization of Fire is Necessary
v Ambient
Monitoring & Reporting Forum (AMRF)
request to Fire Emissions Joint Forum (FEJF)
v FEJF formation of the Natural Background Task
Team (NBTT)
WRAP Meeting
May 24, 2001
Peter Lahm, FEJF Co-Chair
1
2
Regional Haze Rule Preamble
FEJF / NBTT Process
“The EPA also recognizes that fire of all kinds (wildfire,
prescribed fire, etc.) contributes to regional haze, and
that there is a complex relationship between what is
considered a natural source of fire versus a humancaused source of fire.”
v “Consequently, in determining natural background for a
Class I area, EPA believes States [and Tribes] should be
permitted to consider some amount of fire in the
calculation to reflect the fact that some prescribed fire
effects serve merely to offset what would be expected to
3
occur naturally.”
v
1. Develop a methodology to categorize fire into
“anthropogenic” and “natural” source
classifications.
2. Develop approaches for estimating the
contribution of fire emissions to natural
background visibility conditions.
3. Establish methods for tracking and apportioning
fire emissions into the classifications above.
4
Senior Staff Workshop
Focus of Work to Date
January 24-25, 2001 Denver, CO
1. Develop a methodology to categorize fire
into “anthropogenic” and “natural” source
classifications.
v Two-Workshop
v Workshop
fire emissions sources into two
classifications, “natural” and “anthropogenic”
v Assess the technical and policy implications
Format
v1
v Senior Staff Workshop
v Technical
Input
½ day workshop
v½
& Policy Input
v Policy Maker Workshop
v Policy
Objective
v Categorize
v1
5
day - establish a common level of understanding
day - small workgroup discussions
6
1
“Natural” & “Anthropogenic”
Classifications
v
Natural Source Classification
v
v
“Natural” Classification
Clarification
v The
A categorization that designates which fire emissions result in a
natural reduction of visibility for each Federal Class I area in the
WRAP region. This classification may include natural and humancaused ignitions.
Anthropogenic Source Classification
v
A categorization that designates which fire emissions contribute to
visibility impairment and must be managed to achieve progress
toward the 2064 natural visibility goal for each Federal Class I area
in the WRAP region. This classification may include natural and
human-caused ignitions.
7
Agricultural
Land Branch
term “natural” is not synonymous with
historical conditions.
v Pre-settlement
history provides one estimate of
natural emissions from fire
v Knowledge of fire history is a useful starting point for
analysis, but not a surrogate for the natural role of fire
in the future
v Patterns of land use, vegetation change, and climate
variability can and will affect the role of fire
8
Wildland Branch
Arson
Intentional
Ignition
Waste
Disposal
Religious or
Ceremonial
Native
American
Cultural
Burn
Commodity
Waste
NonCommodity
Waste
Traditional
Weed/
Pest/Disease
Mgt.
Agricultural
Burn
Escaped
Agricultural
Burn
Agricultural
Land
Accidental
Human
Ignition
Burn
Authorization
Process
Intensively
Managed
Vegetation
SMP
Authorized
Commodity
Production
Illegal
Un-permitted
Unregulated
Legal
Un-permitted
Unregulated
Wildland
Go To WildBranch land
Yield
Improvement
Ecosystem
Restoration
Intentional
Ignition
Less
Emissions
than Natural
Vegetation
More
Emissions
than Natural
Vegetation
Less
Emissions
than Natural
Vegetation
More
Emissions
than Natural
Vegetation
Natural
Ignition
Accidental
Human
Ignition
Burn
Authorization
Process
Intensively
Managed
Vegetation
SMP
Authorized
Maintain
Ecosystem
Health
Illegal
Un-permitted
Unregulated
Waste
Disposal
Legal
Un-permitted
Unregulated
Single
Purpose
Benefit
Natural
Vegetation
Natural
Vegetation
Commodity
Production
WFMRB/PNF
Go To Pres.
Above Fire
Non-Fire
Treatment
Available
Only Fire
Treatment
Available
In Natural
Fire Season
Out of Natural
Fire Season
Commodity
Waste
NonCommodity
Waste
Less
Emissions
than Natural
Vegetation
More
Emissions
than
10 Natural
Vegetation
Workshop Atmosphere
v Broad
stakeholder groups
Stakeholder Representation
v Language
tribal, state, and local agencies
v natural
v air
quality regulatory
v land management
and small industries
v agriculture
v forest products industry
v environmental and public interest groups
v academic community
Restore or
Attain
Sustainable
Ecosystem
Traditional
Intensively
Managed
Vegetation
Participants
v federal,
Religious or
Ceremonial
Native
American
Cultural
Burn
Escaped
Prescribed
Fire
Wildland
9
v Representative
Hazard
Reduction
Prescribed
Fire
Natural
Ignition
Intensively
Managed
Vegetation
Arson
v natural
ignition (e.g., lightning)
visibility conditions
v natural vegetation
v Natural Source Classification (“natural”)
v natural
v large
v control
v control
11
v control
of a fire
of emissions
12
2
Senior Staff Workshop Results
NBTT Review
v No
Draft Policy for
Categorizing Fire Emissions
Consensus between Workgroups
v Represents
the convergence of thought from
the Senior Staff Workshop
v Convergence of Workgroups
v Similar
v Similar
Approaches
Decision-Making Rationale
v Not
representative of any one workgroup or
workshop participant in particular
v Equitable and livable Draft Policy that can be
v Basis
for NBTT’s development of a
comprehensive policy approach for
categorizing fire emissions.
implemented in the WRAP region
13
14
Policy Maker Workshop
Scope & Applicability
Fire’s Contribution to Natural Visibility
v Impacts
v Workshop
Objective
v Build
upon outcomes and information gained at
the Senior Staff Workshop
v Review Draft Policy for Categorizing Fire
Emissions
v Discuss
stakeholder viewpoint of the Draft Policy
v Understand the Draft Policy elements, their implications
and barriers to implementation
v Move Draft Policy toward consensus
15
Does Not Apply To
v Residential
of the purpose of the burn
property or Tribal lands
v Examples
v backyard
burning
incineration
v cremation
v sweat lodge fires
v residential wood combustion
v Regardless of Ownership
v Regardless
v Regardless
of Cause of Ignition
of Purpose of the Fire
16
Policy Statements
v Other open burning activities
v Regardless
on Federal Class I areas in the
WRAP Region
v Wildland and Agricultural Lands
v garbage
17
1. All fires classified as either “natural” or
“anthropogenic” sources must be managed
to minimize visibility impacts.
2. All fires classified as “anthropogenic”
sources will be controlled to reduce
emissions to the maximum extent feasible.
3. Emissions from all fires, classified as
“natural” or “anthropogenic”, will be
tracked.
18
3
Policy Statements (cont.)
Policy Statements (cont.)
4. Prescribed fires to maintain ecosystem
health in a sustainable ecosystem are
classified as a “natural” source.
5. All other applications of prescribed fire are
to be classified as an “anthropogenic”
source.
6. Any escaped prescribed fire retains its preescape classification.
7. Wildfires, regardless of cause (accidental human
ignitions, natural ignitions, or arson), that are
suppressed by management action are classified as
a “natural” source. Visibility impacts from
wildfires under suppression, as determined by the
monitoring data from the IMPROVE network that
have a statistically significant (e.g., =>1 deciview)
effect on the natural background condition values,
will be flagged and removed from that natural
background condition calculation.
20
19
Fire Emissions Categorization Decision Tree1
Policy Statements (cont.)
8. Wildfires that are not suppressed by
management action are classified the same
as prescribed fires.
9. Native American cultural burning for
religious, ceremonial or for intra-tribal
commerce is considered to be a “natural”
source.
10. Native American prescribed burns will be
classified the same as prescribed fires.
21
Native
American
Cultural
Burn
Core Group Members – balanced stakeholder group
Concerned Stakeholders
v Input
N
Escaped
Prescribed
Fire
N
Other
Prescribed
Fire
A
Escaped
Prescribed
Fire
A
Prescribed
Fire
Wildfire
Not
Suppressed
Wildfire
(arson, natural,
accidental)
Wildfire
Suppressed
N
N - Natural Source
Classification
A - Anthropogenic Source
Classification
22
1 Natural Background Task Team of the Fire Emissions Joint Forum, Draft Policy for Categorizing Fire Emissions, April 5, 2001, page 8.
v General assent on changes to some Draft Policy
May 2 in Tempe, Arizona
v Participants
v Facilitated
Maintain
Ecosystem
Health
Policy Maker Workshop
v Held
v 31
N
Agricultural
Land &
Wildland
Policy Maker Workshop
v 23
Religious,
Ceremonial,
Intra-Tribal
Commerce
and Moderated discussion
gathered from both groups
23
Statements
Draft Policy Statements unchanged
v Some Draft Policy Statements not addressed-Time
v A number of changes recommended to annotated
sections of Draft Policy
v No Consensus of Policy Makers
v Some
24
4
Post Policy Maker Workshop
Post Policy Maker Workshop
v NBTT – Current Work
v Previous
v Compile
a Recommended Policy for Categorizing
Fire Emissions based on the Policy Maker Workshop
v Initial
Findings
v Restructure
Policy into two associated sections
v Management
Approach to Natural and Anthropogenic
Classifications
v Classification of Fires
v Better
linkage with National Fire Plan definitions
25
NBTT Principles Utilized-WRAP Input
v Equity
among all large sources of fire emissions
regardless of land ownership – “No loopholes”
v Application of emissions controls on sources that could
feasibly be controlled to demonstrate reasonable
progress – eg. Wildfires
v Use of Rule or GCVTC language to ensure consistency
and allow policy linkage to SIP/TIP’s – “control”
v Consistent Programs for both 309 and 308
26
Post Policy Maker Workshop
FEJF - Review and Approve the Recommended Policy
submitted by the NBTT.
v WRAP - Review and Approve the Recommended Policy
submitted by the FEJF
v Ambient Monitoring & Reporting Forum - Utilize the
WRAP approved Policy to apportion fire emissions
v States and Tribes in the WRAP Region - Incorporate the
WRAP approved Policy into the technical support
documentation for a SIP/TIP
v
27
5
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III-12
Summary Paper
Fire’s Contribution to Natural Visibility
Senior Staff Workshop
and
Policy Maker/Opinion Leader Workshop
May 17, 2001
Prepared by:
Natural Background Task Team of the Fire Emissions Joint Forum
for the May 23-24, 2001 WRAP Meeting
Workshops Sponsored by:
Western Regional Air Partnership
Fire Emissions Joint Forum and its Natural Background Task Team
III-13
[This page intentionally left blank.]
III-14
Summary Paper
Fire’s Contribution to Natural Visibility
Senior Staff Workshop and Policy Maker/Opinion Leader Workshop
I. Introduction
The Regional Haze Rule (Rule) was issued by the Environmental Protection Agency (EPA) in
July 1999 and outlines the requirements for addressing regional haze in Federal Class I areas. A
critical element of the Rule is the establishment of the natural background condition values for
each Federal Class I area, against which improvements of the 20 percent worst visibility days
and maintenance of the 20 percent cleanest visibility days will be compared. This comparison
will allow for a state or tribe to demonstrate that their emissions management program will meet
the required reasonable progress goals established in the State Implementation Plan (SIP) or
Tribal Implementation Plan (TIP) for the Regional Haze Rule.
There are a number of sources that EPA has suggested as contributors to natural background
conditions, including fire. Fire had been identified by the Grand Canyon Visibility Transport
Commission (GCVTC) as a source that would have increasing emissions and could potentially
overwhelm the visibility effects of all other sources on an episodic basis. The GCVTC also
established a series of Recommendations to address this potential, which were later adopted into
Section 309 of the Rule.
Fire emissions are acknowledged by EPA in the Regional Haze Rule to be a significant
contributor to regional haze and that there is a complex relationship between what may be
considered natural versus human-caused sources of fire. In the Preamble to the Rule, EPA states
that “in determining natural background for a Class I area, EPA believes states [and tribes]
should be permitted to consider some amount of fire in the calculation to reflect the fact that
some prescribed fire effects serve merely to offset what would be expected to occur naturally” 1.
II. NBTT Task: Develop a Categorization Methodology for Fire
The Ambient Monitoring and Reporting Forum (AMRF) is responsible for establishing guidance
on the determination of natural background to the WRAP, as well as analyzing the Interagency
Monitoring of Protected Visual Environments (IMPROVE) visibility monitoring data to
demonstrate progress toward the National Visibility Goal. The categorization of fire is necessary
due to the current scientific inability to identify the source of organic carbon aerosol monitored
by IMPROVE at Federal Class I areas. Therefore, the AMRF requested the Fire Emissions Joint
Forum (FEJF) determine which smoke emissions should be classified as either “natural” or
“anthropogenic” to facilitate the tracking of reasonable progress as well as the establishment of
natural background condition values.
1 64 FR 35735-35736 (July 1, 1999)
III-15
Over the past year and a half, the Natural Background Task Team (NBTT) of the FEJF has
conducted a thorough discussion of the distinction between “natural” and “anthropogenic” fire
emissions. Integral to this discussion has been NBTT’s focus on developing a methodology to
categorize fire into “anthropogenic” and “natural” source classifications. In developing the
approach to categorize fire emissions, the NBTT decided a two-workshop format would best
enable the Task Team to gain the necessary review and input surrounding both the technical and
policy implications involved.
Once the categorization system is established, the tracking and apportionment of current fire
emissions to the source classifications can commence. In addition, the approach for estimating
the contribution of future fire emissions to natural background visibility conditions, needed for
the establishment of the 2064 natural visibility goal, can begin to be developed.
III. Senior Staff Workshop Summary
A. Senior Staff Workshop Structure and Content
The Fire’s Contribution to Natural Visibility – Senior Staff Workshop was held in Denver,
Colorado on January 24-25, 2001 with the following objective:
To categorize fire emissions sources into two classifications, “natural” &
“anthropogenic”, and to assess the policy and technical implications. These
classifications will help define the natural visibility conditions in the Federal
Class I parks and wilderness areas in the West.
The Senior Staff Workshop involved 65 participants from the following stakeholder groups:
federal, tribal, state, and local governmental and land management agencies; large and small
industries; agricultural and forestry industries; environmental groups and the academic
community. In order to facilitate and focus the discussion of the Senior Staff Workshop, the
NBTT developed a set of assumptions and a proposed decision tree methodology to categorize
potential source emissions into either “natural” or “anthropogenic” classifications.
After a half-day of background discussion, the Workshop participants met in eight small
workgroups that were tasked with reviewing the assumptions and decision tree as well as
determining what criteria would be used to classify all wildland fires, agricultural land burns, and
Native American cultural burns. Each workgroup was encouraged to simplify or modify the
decision tree to reflect the workgroup’s concepts regarding fire emission source categorization.
The workgroups also discussed the implications of the classification for tracking and regulating
sources. For example, it was stressed that a “natural” source designation did not exempt a source
from other regulations such as those enforced to protect human health or ambient air quality.
III-16
B. Senior Staff Workshop Results
At the conclusion of the Senior Staff Workshop, the NBTT compiled and reviewed the results of
the eight workgroups to identify comparable recommendations, similar rationale for changes and
recommendations, and whenever possible, consensus between workgroups. There were few
issues that represented a complete consensus of all Workshop participants. However, a number
of workgroups converged on similar approaches, rationale and decision-making criteria.
C. Conclusion
The level of agreement within and between the eight workgroups at the Fire’s Contribution to
Natural Visibility - Senior Staff Workshop was quite substantial, and the discussions and
decisions reached by each workgroup were both constructive and illuminating. The results of the
Senior Staff Workshop exceeded expectations.
From the Senior Staff Workshop results, the NBTT developed a comprehensive policy approach
that addresses the classification of fire emissions and poses a future emissions management
approach for fire under the Regional Haze Rule, toward the 2064 Natural Visibility Goal. This
comprehensive policy approach was to be assessed at the second NBTT workshop, designed for
policy maker participants, to provide additional stakeholder feedback prior to final NBTT
development and FEJF approval as a proposed WRAP policy.
IV. Draft Policy for Categorizing Fire Emissions Summary
A. Introduction
The Draft Policy for Categorizing Fire Emissions was crafted to help determine which fire
emissions will be considered as part of the natural background conditions in Federal Class I
areas, and which of the remaining fire emissions are considered “anthropogenic” and therefore
subject to reasonable progress requirements of the Rule.
The Draft Policy clarifies the relationship between what would be defined as a “natural” fire
source and what would be defined as an “anthropogenic” fire source, thereby addressing the
complex relationship EPA acknowledges in the Preamble to the Rule. By clarifying the
categorization of fire emission sources, the Draft Policy provides a basis to the approach for
estimating the contribution of future fire emissions to natural background visibility conditions.
The Draft Policy also provides an approach towards management of “natural” and
“anthropogenic” fire emissions, which would result in an alignment of Sections 308 and 309 of
the Rule and could lead toward a reasonable progress demonstration for fire sources.
B. Scope and Applicability
The Draft Policy only addressed the effects of fire emissions in terms of natural background
visibility and the requirements of the Rule. Air pollutant emissions from fires may also impact
public health and cause nuisance smoke intrusions; those issues have been left for other task
teams of the FEJF to address.
III-17
All kinds of fire (e.g., wildfire, prescribed fire, agricultural burns, Native American cultural
burns) contribute to regional haze. The Draft Policy applies to both wildland and agricultural
lands regardless of ownership (e.g., federal, state, tribal, public, private), cause of ignition (e.g.,
lightning, arson, accidental human, land management decision) or purpose of the fire (e.g.,
commodity benefit, hazard reduction, maintain ecosystem health). The Draft Policy does not
apply to other open burning activities, regardless of the purpose of the burn, on residential
property or tribal lands (e.g., backyard burning, garbage incineration, cremation, sweat lodge
fires, residential wood combustion). The Draft Policy applies to impacts on Federal Class I areas
in the WRAP region.
C. Key Definitions
The following key definitions were used in the Senior Staff Workshop and are maintained in the
Draft Policy:
Natural Source Classification (“natural”) - A categorization that designates which fire
emissions result in a natural reduction of visibility for each Federal Class I area in the
WRAP region. This classification may include natural and human-caused ignitions.
Anthropogenic Source Classification (“anthropogenic”) - A categorization that designates
which fire emissions contribute to visibility impairment and must be managed to achieve
progress toward the 2064 natural visibility goal for each Federal Class I area in the
WRAP region. This classification may include natural and human-caused ignitions.
D. Draft Policy Statements
The ten Draft Policy Statements that follow are the core of the Draft Policy for Categorizing Fire
Emissions.
1. All fires classified as either “natural” or “anthropogenic” sources must be managed to
minimize visibility impacts.
2. All fires classified as “anthropogenic” sources will be controlled to reduce emissions to the
maximum extent feasible.
3. Emissions from all fires, classified as “natural” or “anthropogenic”, will be tracked.
4. Prescribed fires to maintain ecosystem health in a sustainable ecosystem are classified as a
“natural” source.
5. All other applications of prescribed fire are to be classified as an “anthropogenic” source.
6. Any escaped prescribed fire retains its pre-escape classification.
7. Wildfires, regardless of cause (accidental human ignitions, natural ignitions, or arson), that
are suppressed by management action are classified as a “natural” source. Visibility impacts
from wildfires under suppression, as determined by the monitoring data from the IMPROVE
network that have a statistically significant (e.g., =>1 deciview) effect on the natural
background condition values, will be flagged and removed from that natural background
condition calculation.
III-18
8. Wildfires that are not suppressed by management action are classified the same as prescribed
fires.
9. Native American cultural burning for religious, ceremonial or for intra-tribal commerce is
considered to be a “natural” source.
10. Native American prescribed burns will be classified the same as prescribed fires.
The following Fire Emissions Source Categorization Decision Tree is a diagrammatic
representation of the Draft Policy.
Native
American
Cultural
Burn
Religious,
Ceremonial,
Intra-Tribal
Commerce
N
Agricultural
Land &
Wildland
Maintain
Ecosystem
Health
N
Escaped
Prescribed
Fire
N
Other
Prescribed
Fire
A
Escaped
Prescribed
Fire
A
Prescribed
Fire
Wildfire
Not
Suppressed
Wildfire
(arson, natural,
accidental)
Wildfire
Suppressed
N
N - Natural Source
Classification
A - Anthropogenic Source
Classification
V. Policy Maker/Opinion Leader Workshop Summary
A. Policy Maker Workshop Structure and Content
The Fire’s Contribution to Natural Visibility -- Policy Maker/Opinion Leader Workshop (Policy
Maker Workshop) was designed as a follow-up workshop to the Senior Staff Workshop. The
Policy Maker Workshop was held in Tempe, Arizona on May 2, 2001.
The objective of the Policy Maker Workshop was to build upon the outcomes and information
gained at the Senior Staff Workshop, toward the development of a Draft Policy for Categorizing
Fire Emissions that ultimately will be recommended through the FEJF to the WRAP. It was the
expectation of the NBTT that the Policy Maker participants would discuss their stakeholder
viewpoint of the Draft Policy developed by the NBTT from the Senior Staff Workshop and move
toward consensus, making modifications that would result in a Recommended Policy for
Categorizing Fire Emissions.
III-19
The Policy Maker Workshop was a one-day facilitated and moderated meeting. Invitees to the
Workshop were chosen to participate as either a Policy Maker or as a Concerned Stakeholder.
The purpose of designating two groups of participants was to focus the Workshop around a
balanced Policy Maker core group of 23 participants for the main discussion. This core group
was enhanced by the input of 31 Concerned Stakeholder participants. Of the 54 participants, 8
were WRAP Members and/or their designated alternates. The participants formed a large and
very diverse stakeholder base, ranging from governmental and land management agencies to the
agricultural community.
The NBTT utilized the Draft Policy for Categorizing Fire Emissions to facilitate and focus the
discussion of the Policy Maker Workshop. During the Workshop, valuable discussion took place
among the participants regarding the components of the Draft Policy, stakeholder viewpoints,
and Draft Policy implications, resulting in specific feedback for Draft Policy revisions.
B. Policy Maker Workshop Results
From the discussion, the Policy Maker Workshop participants arrived at general assent toward
some changes to the Draft Policy and convergence on certain key issues that will change the
format of what was developed by the NBTT. The majority of suggested changes to the Draft
Policy concern the supporting and explanatory language in the annotated sections of the Draft
Policy. The Workshop participants also came to resolution on some Draft Policy Statements
endorsing removal and/or modification, while several Draft Policy Statements were approved as
originally written.
Due to time constraints, not all of the topics addressed in the Draft Policy were covered by the
Policy Maker Workshop participant discussion. To address this, Workshop participants were
asked to submit written comments by the close of the Workshop.
C. Conclusion
It is apparent that the Policy Maker Workshop has substantially augmented the outcomes and
information gained at the Senior Staff Workshop, and the dialogue and decisions reached by the
participants captured in the discussion notes and evaluations are both insightful and illustrative.
The NBTT is now in the process of analyzing the Policy Maker Workshop discussion notes to
identify suggested changes to the Draft Policy Statements and annotated sections. An analysis of
similar rationale for recommendations, and whenever possible, convergence on key issues will
change the work to date. The results of this analysis will be the basis for the Recommended
Policy for Categorizing Fire Emissions.
The Recommended Policy for Categorizing Fire Emissions will be finalized and presented by the
NBTT to the FEJF for approval. The FEJF will then submit the Recommended Policy to the
WRAP for consideration and utilization by WRAP states and tribes. The FEJF would then
submit the Recommended Policy to the Ambient Monitoring and Reporting Forum, for inclusion
into the overall natural background condition determination guidance needed to meet the
requirements of the Regional Haze Rule.
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VI. WRAP Input
The Draft Policy for Categorizing Fire Emissions was based on input from the Senior Staff
Workshop as well as the expertise of the NBTT members. Several guiding principles were used
by the NBTT in the development of the Draft Policy. The NBTT is currently analyzing the
results of the Policy Maker Workshop and the Task Team wishes to re-affirm the use of these
principles in preparation of the Recommended Policy for Categorizing Fire Emissions. These
principles would be used by the NBTT to assess the recommendations from the Policy Maker
Workshop.
Guiding principles include:
- applying equity among all large sources of fire emission regardless of land
ownership,
- development of clear linkage between approaches of Sections 308 and 309 of the
Rule for emissions management and/or control of fire sources,
- application of emissions controls on sources that could feasibly be controlled to
demonstrate reasonable progress,
- development of a policy that can be implemented by the WRAP, and
- verbatim use of the Rule language to ensure consistency with the Rule and allow
for clear policy inclusion in SIPs/TIPs.
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Further Policy Development
FEJF July 11-12, 2001 Meeting
NBTT Briefing
NBTT Briefing Paper
Recommended Policy Content and Structure Overview
FEJF Recorded Comments and Discussion
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III-24
NBTT Briefing Paper
Prepared by the Natural Background Task Team
for the July 11–12, 2001 FEJF Meeting
7/3/01
Introduction
The Ambient Monitoring and Reporting Forum (AMRF) is responsible for establishing guidance
on the determination of natural background to the WRAP, as well as analyzing the Interagency
Monitoring of Protected Visual Environments (IMPROVE) visibility monitoring data to
demonstrate progress toward the National Visibility Goal. The categorization of fire is necessary
due to the current scientific inability to identify the source of organic carbon aerosol monitored
by IMPROVE at Federal Class I areas. Therefore, the AMRF requested the Fire Emissions Joint
Forum (FEJF) determine which smoke emissions should be classified as either “natural” or
“anthropogenic” to facilitate the tracking of reasonable progress as well as the establishment of
natural background condition values.
Over the past year and a half, the Natural Background Task Team (NBTT) of the FEJF has
conducted a thorough discussion of the distinction between “natural” and “anthropogenic” fire
emissions. Integral to this discussion has been NBTT’s focus on developing a methodology to
categorize fire into “anthropogenic” and “natural” source classifications. In developing the
approach to categorize fire emissions, the NBTT decided a two-workshop format would best
enable the Task Team to gain the necessary review and input surrounding both the technical and
policy implications involved.
Background
The Fire’s Contribution to Natural Visibility – Senior Staff Workshop was held in Denver,
Colorado on January 24-25, 2001. Senior Staff Workshop participants were tasked with
reviewing the assumptions and decision tree as well as determining what criteria would be used
to classify all wildland fires, agricultural land burns, and Native American cultural burns.
From the Senior Staff Workshop results, the NBTT developed a comprehensive policy approach
(i.e., Draft Policy for Categorizing Fire Emissions) that addresses the classification of fire
emissions and poses a future emissions management approach for fire under the Regional Haze
Rule, toward the 2064 Natural Visibility Goal.
The Fire’s Contribution to Natural Visibility -- Policy Maker/Opinion Leader Workshop was
designed as a follow-up workshop to the Senior Staff Workshop. The Policy Maker Workshop
was held in Tempe, Arizona on May 2, 2001. During the Policy Maker Workshop, valuable
discussion took place among the participants regarding the component of the Draft Policy for
Categorizing Fire Emissions, stakeholder viewpoints, and Draft Policy implications. The
dialogue at the Policy Maker Workshop substantially augmented the outcomes and information
gained at the Senior Staff Workshop.
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A NBTT Work Summary was presented at the May 24, 2001 WRAP meeting held at the Pueblo
of Acoma. The Work Summary was designed to allow the meeting participants to follow the
progression of the work accomplished to date as well as the NBTT and FEJF decisions. During
the presentation of the post Policy Maker Workshop portion of the Work Summary, WRAP
meeting attendees were asked for their feedback on initial Policy Maker Workshop findings and
guiding principles for the Draft Policy.
Conclusions are still being drawn from the input received on the Draft Policy for Categorizing
Fire Emissions at the WRAP meeting and Policy Maker Workshop. The basis of the
Recommended Policy for Categorizing Fire Emissions is still being developed based on the input
that will be obtained in the near future from the NBTT, Agricultural Air Quality Task Force
meeting, and FEJF.
Next Steps
The NBTT will present a briefing to the FEJF at the July 11-12, 2001 meeting in Rapid City,
South Dakota with the following objective.
NBTT Briefing Objective: To clarify the newly revised Draft Policy for FEJF
members, and to gain their input toward finalization of the Recommended Policy
for Categorizing Fire Emissions for the WRAP region.
After the conclusion of the NBTT briefing, the NBTT Management and Content Team will take
into consideration suggested changes to the finalization of the Recommended Policy.
The Recommended Policy will be finalized and given to the FEJF in August 2001 for
consideration and approval. The FEJF would then submit the Recommended Policy to the
WRAP for consideration and utilization by WRAP states and tribes at the October 2001 meeting.
Should the FEJF be unable to reach approval via consensus, the Recommended Policy will be
referred to the Initiative Oversight Committee and Technical Oversight Committee of the WRAP
for resolution at their September 2001 meeting.
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Recommended Policy Content and Structure Overview
Prepared by the Natural Background Task Team
for the July 11–12, 2001 FEJF Meeting
7/3/01
Recommend Policy for Categorizing Fire Emissions
Classification Policy
These Policy Statements apply to both wildland and agricultural lands regardless of ownership,
cause of ignition, or purpose of the fire within the WRAP region.
A. Prescribed Fire utilized to maintain an ecosystem that is currently in an ecologically
functional and fire resilient condition is a “natural” source. Prescribed fire for all other
purposes is an “anthropogenic” source. Escaped prescribed fire is classified according to its
pre-escape classification.
B. Wildfire that is suppressed by management action is a “natural” source. Wildfire, when
suppression is limited for safety, economic, or resource limitations, remains a “natural”
source. Wildfires managed for resource objectives are classified the same as prescribed fires.
C. Native American cultural burning for traditional, religious, and ceremonial purposes is a
“natural” source.
Implementation Policy
A. All fires must be managed to minimize visibility impacts.
B. All emissions from fires classified as an “anthropogenic” source will be controlled to the
maximum extent feasible subject to economic, safety, technical and environmental
considerations.
C. Emissions from all fire will be tracked.
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“Natural” and “Anthropogenic” Definitions
Natural Source Classification (“natural”) - A categorization that designates which fire
emissions can result in a natural reduction of visibility for each Federal Class I area in the
WRAP region. This classification includes natural and human-caused ignitions.
Anthropogenic Source Classification (“anthropogenic”) - A categorization that designates
which fire emissions contribute to visibility impairment for a Federal Class I area.
“Anthropogenic” emissions must be controlled to achieve progress toward the 2064 natural
visibility goal for each Federal Class I area in the WRAP region. This classification includes
natural and human-caused ignitions.
Structure
I.
II.
III.
IV.
V.
VI.
VII.
VIII.
B.
PURPOSE
SCOPE & APPLICABILITY
BACKGROUND
CLASSIFICATION POLICY
CLASSIFICATION POLICY ANNOTATION*
A.
Prescribed Fire
B.
Wildfire
C.
Native American Cultural Burning
IMPLEMENTATION POLICY
IMPLEMENTATION POLICY ANNOTATION*
A.
Management to Minimize Visibility Impacts
B.
Control Emissions from “Anthropogenic” Sources
C.
Tracking Fire Emissions
APPENDICES
A.
Monitoring Guidance (i.e., greater than 1 deciview impact from
wildfire events)
Definitions
Others as determined to be appropriate.
* Annotation will provide clarification and supporting information for the Policy
Statements including discussion of applicability, examples, implementation, and
inter-Policy Statement relationships.
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Preparation of Recommended Policy document
! Maintain the following Guiding Principles
" Equity among all large sources of fire emissions.
" Application of emissions controls on sources that could feasibly be controlled to
demonstrate reasonable progress.
" Use of Regional Haze Rule and/or Grand Canyon Visibility Transport Commission
(GCVTC) language to ensure consistency and allow Draft Policy linkage to SIPs/TIPs.
" Consistent Smoke Management Programs for both Sections 309 and 308 of the Regional
Haze Rule.
! Split the classification from the implementation/management aspects of the Recommended
Policy. Although the sections are still interdependent it should help to reduce some issues.
! Add “feasibility” language to Draft Policy Statement #2 with an associated commitment from
the FEJF to develop guidance for the “feasibility” implementation.
! Recognize traditional Native American burning in association with religious and ceremonial
burning in Draft Policy Statement #9.
! Removal of Draft Policy Statement #10 (re: Native American Prescribed Burning).
! Several changes and additions to the Annotation Sections
" Include linkage to the National Fire Plan (elements & definitions) explicitly not
implicitly.
" Recognize severe wildland fuel conditions in the West.
" Recognize that the use of prescribed fire will increase in federal, state, and private sectors
through the National Fire Plan. The funds are in place through the National Fire Plan.
" Discuss that assessment and classification will occur at the local level rather than at a
programmatic level.
" Discuss alternatives to burning.
" Discuss emissions averted/reduced and tracking emissions.
" Discuss Matrix of Implementation (Management) Policy items.
" Remove the Magnitude, Linkage, and Senior Staff Workshop Results sections from the
Annotation Sections.
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III-30
NBTT Briefing at FEJF Meeting
Tuesday, July 11, 2001
8:30 –11:45 a.m.
Rapid City, South Dakota
In attendance: Pete Lahm, Mark Fitch, Bob Palzer, Steve Gerritson, Mike Ziolko, Diane Riley, Phil
Harwell, Pat Shaver, Scott Kuehn, Dave Randall, Carl Gossard, Tom Pace, Frances Bernards, Gregory
Josten, Brian Gustafson, Suraj Ahuja, Charlene Schildwachter, Dave Jones, Pete Stewart, Vicky Komie,
Jim Russell, Darla Potter, Larry Biland, Rick Sprott, Rich Fisher, Rebecca Reynolds
FEJF Comments & Questions
Prescribed Fire (Classification Policy A)
--Ecosystem Maintenance Burning definition: Concerned that if this definition is based on the Cohesive
Strategies’ condition class numbers it will result in unrealistic emissions based on the number of acres
projected at the macro scale. (S. Kuehn)
NBTT Response: Although the Policy will be tied to the National Fire Plan (which includes the
Cohesive Strategies), the decision as to what is an ecosystem maintenance burn will be made at the
local level, and not based on the national acreage projections.
The local decision will be made through land use planning and fire management planning.
--Who will determine the classification of the burn on non-federal land? (P. Shaver)
NBTT Response: The person(s) responsible for the burn.
--There are many reasons to burn, as long as ecosystem maintenance is one of them, will the burn be
considered “natural”?
NBTT Response: No, the primary reason for the burn will be the determining factor. The NBTT will
more strictly determine/narrowly define this in the Annotation.
--Consistency will be imperative – where is “maintenance burning” defined? (D. Riley)
NBTT Response: It will be defined in the Annotation although specific criteria may not be utilized in
the definition.
--What does “fire resilient,” mean exactly? (V. Komie)
NBTT Response: It will be defined in the Annotation.
--Need a specific link to an air quality manager in the decision process in regard to the classification made
at the local level (i.e., collaborative decision). The classification cannot just be up to the fire instigator.
The determination needs to be made between the instigator and the regulator. The classification needs to
be made in a trackable, enforceable, and culpable way. (D. Randall)
Native American Burning (Classification Policy C)
--The changes to Policy Statement #9 and the deletion of #10 are agreeable. Does want to emphasize that
there are 149 Tribes in the Western region and not all have reviewed this document. Therefore it is
important to recognize that this Policy does not speak for them all. (K. McKernan)
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--I still have difficulty with Tribal burning being “natural”, and I want that expressed even though I am
aware that I am in the minority. (S. Kuehn)
--Will there be a definition of “religious, ceremonial and traditional” in the Annotation? (D. Riley)
NBTT Response: A tribe or tribal council will determine what is religious, ceremonial or traditional,
which will most likely vary from tribe to tribe. However, if Native American burning meets the
definition of Prescribed Fire, then it will follow that classification in the Policy.
--It would be nice to have some clarification on what “traditional” is. (D. Riley)
NBTT Request: K. McKernan will pull together some specific examples from each (religious,
ceremonial, traditional) type of burning by next week for NBTT to use. [Some examples may be
subsistence plant material burning such as basket weaving materials, grasses, huckleberries, and tule.]
Prescribed Fire – Escaped (Classification Policy A)
--Concern that escaped prescribed fires will retain their original classification – if what is originally
considered a maintenance burn escapes, then a lot more emissions will result that will not be counted. (B.
Palzer)
NBTT Response: The opposite will also be true. We have had a lot of consideration over this one: the
decision to do it this way made the most sense. Less than 1% of prescribed fires actually escape, and
tracking it this way is much more practical.
--Remember that this is only a classification for visibility purposes. (D. Jones)
--What acreage results from an escaped fire as compared to the acreage originally intended in the
prescribed fire? (B. Palzer)
NBTT Response: We do not know that information and are not sure if this data is being tracked. It
would be helpful if it is available.
--This gets back to the point that definitions are the key between maintenance and restoration burning: not
all prescribed fire is “natural”. (S. Kuehn)
NBTT Response: Correct.
--Will the two classifications of escaped prescribed fire offset each other in the long run? (S. Kuehn)
NBTT Response: We do not know.
--If there is to be a break in the classification of escaped prescribed fire from the original prescribed fire, I
suggest using suppression as a further criterion to re-classify, but I can live with it the way it is. (S.
Kuehn)
--What % of prescribed fire would be “anthropogenic” currently or over the last 5 years? (T. Pace)
Response (T. Sexton): About 90% in the WRAP region.
NBTT Response: 80% of the maintenance burning is mostly in the southeast. The focus for the
National Fire Plan is urban/interface burning (i.e., hazardous fuel reduction) over the next 10 years
and will be classified as “anthropogenic”.
III-32
--Confusing: are we looking at fuel loading in the natural range of variability as “natural” or ecosystem
maintenance as “natural”? These are two different things, and I am not sure which one is the focus of the
classification. (G. Josten)
NBTT Response: “Natural range of variability” was not a useful criterion because no one could
determine (agree on) the definition. We also considered a historical view but it was discounted, as we
couldn’t agree on how far back to go. So we decided on “fire resilient” as it represents consensus (i.e.,
people can live with it). We also kept in mind the tracking implications to this – chose this for
efficiency’s sake.
--Concerned that we’ll get people lying to get their fire “natural” or there will be so many loopholes that
this will be for naught. Also concerned that huge fuel load all being counted “anthropogenic” (restoration)
will hide the fuel that would be there naturally, skewing the number of emissions that must be reduced.
We should be giving credit back to compensate for the “natural” fuel levels that would be there anyway.
(V. Komie)
NBTT Response: Burning in the maintenance state will actually produce lower emissions due to the
burn being conducted at a lower intensity. Keep in mind that the NBTT is only establishing the
Policy for the classification, not the determination of the Natural Background Value in 2064.
--If you are doing restoration burning, you aren’t burning the natural fuel component (i.e., taking it back
to ground zero). The “anthropogenic” restoration burn will take care of the accrued fuel buildup but not
the natural fuel. (T. Sexton)
--Standard deviation in fire is high to begin with. (P. Stewart)
NBTT Response: Fire is a highly variable source that will be recognized in the Background of the
Policy.
--I acknowledge that NBTT is only doing classification at this point, but by classifying, we are defining
the way to get to numbers. I am concerned about Ag. Burning: there seem to be many ways to define
maintenance so that most of Ag burning could be considered “natural” – especially in eastern
Washington. (S. Gerritson)
NBTT Response: We see very few instances where this would be the case. We can clarify our
intention in the Annotation. Also, give examples that communicate “commodity production” to
clarify the intent of classification as “anthropogenic”.
--Concern about interpretation at local levels – how to get consistency? (S. Gerritson)
Response (T. Sexton): Although the fire instigator will initiate the classification, state air regulators
will provide checks and balances.
Implementation Policy
--If NBTT is just classifying, why is it necessary to have the Implementation Policy? Couldn’t that be left
to other Task Teams, i.e., isn’t it premature? (D. Riley)
NBTT Response: Because of the many opposing interests involved, and the concern that some would
get a “free lunch”, NBTT felt it was important to level the playing field by developing the
Implementation Policy statements. These arose out of the Senior Staff Workshop and the concerns
about what the classification would actually mean.
III-33
--Suggest that NBTT acknowledge these concerns in the background to the Classification Policy and refer
to the other Task Teams’ work instead of the Implementation Policy. (D. Riley)
NBTT Response: The Implementation Policy is stating what needs to happen in order for the
Classification Policy to work effectively and equitably. NBTT can refer to other Task Teams
work/role in this.
--Concern over assigning “natural” and “anthropogenic” to a BSMP and ESMP when this work has yet to
be done to establish the elements of a BSMP or ESMP. (D. Riley)
NBTT Response: That part of the Annotation has been revised. Also, WRAP supports consistency of
smoke management programs between 308 and 309 states.
--I feel this could be a goal, but should not be a Policy. (D. Riley)
Implementation Policy A
--This needs more clarification – it sounds like it is the priority rather than a priority among many,
including fire fighter safety. (T. Sexton)
NBTT Response: This is made clear in the Annotation.
--How are wildfires managed for visibility impacts? (F. Bernards)
Response (P. Stewart): Where you put a control line in or place retardant will have an impact on
emissions, even for a wildfire.
--Where is “minimize visibility impacts” in the RHR or GCVTC Recommendations? (D. Riley)
NBTT Response: In the Annotation we will tie back to the original documents as much as possible.
Implementation Policy B
--For “anthropogenic” sources, alternative uses need to be emphasized. (V. Komie)
NBTT Response: This will be included in the Annotation. Also, clarifying the difference between
control and manage was the reason behind referring to BSMP and ESMP.
--Need to include a definitions page at the beginning, and then repeat the definition for control in a
footnote where it is used. (L. Biland)
--All emissions from all fires will be under a SMP – I’d like this added back into the Implementation
Policy. (S. Kuehn)
--Where is “control to the maximum extent feasible” in the RHR or GCVTC Recommendations? (D.
Riley)
NBTT Response: “control” is from the RHR. In the Annotation we will tie back to the original
documents as much as possible.
Response (D. Randall): “maximum extent feasible” comes from the GCVTC Recommendation #7.
The NBTT is going a little beyond the GCVTC Recommendation but is consistent with the intent of
the Recommendation language.
III-34
Implementation Policy C
--Will the tracking be handled (and how – e.g., proximity, de minimus, etc.) by another Task Team? (B.
Gustafson)
NBTT Response: Yes, and we can specifically refer to this in the Annotation.
--Where is the “tracking of all fires” in the RHR or GCVTC Recommendations? (D. Riley)
NBTT Response: In the Annotation we will tie back to the original documents as much as possible.
Response (D. Randall): GCVTC Recommendation #2.
Implementation Policy
--The Implementation Policy is not policy. It is rather “considerations” for the Classification Policy.
Change the “will” language to “should”. (T. Pace)
--NBTT could refer to this section as References to the GCVTC Recommendations, e.g., Policy B =
GCVTC Recommendation #7. (D. Randall)
--Describe in Annotation that the actual methodologies and mechanics of A, B and C will be worked out
and specified by other Task Teams. (D. Riley)
NBTT Response: OK. The Implementation Policy also emphasizes the equity issue.
--Instead of “Policy”, suggest “Guiding Principles.” (R. Fisher)
--Implementation Policy A is more strict than the GCVTC recommendations, and Implementation Policy
B is more lenient. Perhaps NBTT could paraphrase what’s in the RHR or GCVTC rather than come up
with new guiding principles. (D. Riley)
Response (D. Jones): I disagree that A is stricter.
--More RHR language can be included in Annotation – keep statements simple. (D. Jones)
--Why not keep B simple too? Take out the caveat “subject to…” – or add it to A as well. (D. Riley)
--Keep in mind, the FEJF would have to develop additional guidance for this if the feasibility statement
was added to A. (P. Lahm)
--Add the feasibility statement in the Annotation for A and keep the Policy Statement simple. (D. Jones)
NBTT Response: OK
--The NBTT will go back and review all comments and make sure that our language is consistent to that
of both the RHR and the GCVTC, and refer to other Task Teams’ work/role. The Policy Statements will
remain an “Implementation Policy” pending the above consideration.
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III-36
Further Policy Development
Agricultural Air Quality Task Force (AAQTF)
July 18-19, 2001 Meeting
WRAP FEJF Update
Briefing Paper - Recommended Policy for Categorizing Fire Emissions
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III-38
Co-Chairs
Michael O. Leavitt
Governor
State of Utah
Cyrus J. Chino
Governor
Pueblo of Acoma
Briefing Paper – Recommended Policy for Categorizing Fire Emissions
Prepared by the Natural Background Task Team of the Fire Emissions Joint Forum
for the July 18-19, 2001 AAQTF Meeting
Introduction
The Regional Haze Rule was issued by the Environmental Protection Agency (EPA) in July 1999 and
outlines the requirements for addressing regional haze in Federal Class I areas. A critical element of the
Rule is the establishment of the natural background condition values for each Federal Class I area, against
which improvements of the 20 percent worst visibility days and maintenance of the 20 percent cleanest
visibility days will be compared. This comparison will allow for a state or tribe to demonstrate that their
emissions management program will meet the required reasonable progress goals established in the State
or Tribal Implementation Plan for the Regional Haze Rule.
There are a number of sources that EPA has suggested as contributors to natural background conditions,
including fugitive dust and fire emissions. The Regional Haze Rule Preamble also stipulates that fire
contributes to regional haze and that fire can have both natural and anthropogenic sources. The Preamble
to the Rule further states that some fire that is set by human ignition may be included in a state’s or tribe’s
determination of natural background conditions. In the Preamble to the Rule, EPA states that “…in
determining natural background for a Class I area, EPA believes states [and tribes] should be permitted to
consider some amount of fire in the calculation to reflect the fact that some prescribed fire effects serve
merely to offset what would be expected to occur naturally” 2.
Background
The Western Regional Air Partnership (WRAP) is recognized by EPA as the Regional Planning
Organization developing processes to improve visibility in all western Federal Class I areas by developing
the necessary technical and policy tools needed by states and tribes to implement the Regional Haze Rule.
The WRAP is comprised of the Western Governors and Tribal Leaders and is led by Michael O. Leavitt,
Governor of the State of Utah and Cyrus J. Chino, Governor of the Pueblo of Acoma. WRAP participants
include state air quality agencies, federal/state/private land managers, the Environmental Protection
Agency, environmental groups, industry, academia, and other interested parties.
2 64 FR 35735-35736 (July 1, 1999)
Staffed by:
Western Governors’ Association
1515 Cleveland Place, Suite 200
Denver, CO 80202
(303) 623-9378
Fax (303) 534-7309
www.wrapair.org
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Staffed by:
National Tribal Environmental Council
2221 Rio Grande NW
Albuquerque, NM 87104
(505) 242-2175
Fax (505) 242-2654
The WRAP established the Fire Emissions Joint Forum (FEJF) to address policy and technical issues
concerning smoke effects from wildland and agricultural burning activities on public and private lands in
the western states. The FEJF established the Natural Background Task Team (NBTT) to assist in
determining which smoke emissions should be classified as either “natural” or “anthropogenic.” This
classification system will facilitate the tracking of reasonable progress toward the 2064 natural visibility
goal as well as define the role of fire in the establishment of natural background condition values as
stipulated in the Regional Haze Rule.
Over the past year and a half, the NBTT has conducted two workshops on Fire’s Contribution to Natural
Visibility, one for Senior Staff and one for Policy Makers, to gain the necessary review and input
surrounding both the technical and policy implications involved in categorizing fire emissions. The
workshop participants formed a large and diverse stakeholder base, ranging from governmental and land
management agencies to the agricultural community. Input gained from the Senior Staff Workshop
allowed the NBTT to develop the Draft Policy for Categorizing Fire Emissions. The NBTT utilized this
Draft Policy to facilitate and focus the discussion at the Policy Maker Workshop. The dialogue at the
Policy Maker Workshop substantially augmented this initial Draft Policy. The key policy statements of
the Draft Policy were fundamentally supported at the Policy Maker Workshop. The Draft Policy and the
input from the Policy Maker Workshop were presented to the WRAP. The WRAP provided further
guidance toward the finalization of the Draft Policy into a Recommended Policy for Categorizing Fire
Emissions.
Recommended Policy for Categorizing Fire Emissions
The Recommended Policy will be based on six policy statements addressing the classification of fires and
the implementation of the classification system. The Policy is currently being finalized by the FEJF and
NBTT for adoption by the WRAP in the Autumn of 2001. The policy statements will be accompanied by
clarifying and supporting information, including discussion of applicability with examples. For this
briefing paper, the recommended policy statements are accompanied by a brief summary of supporting
information.
These policy statements apply to both wildland and agricultural lands regardless of ownership, cause of
ignition, or purpose of the fire within the WRAP region. The Recommended Policy will not apply to
other open burning activities, regardless of the purpose of the burn, on residential property or tribal lands
(e.g., garbage incineration, cremation, sweat lodge fires, residential wood combustion, camp fires).
Classification Policy
A. Prescribed Fire utilized to maintain an ecosystem that is currently in an ecologically functional and
fire resilient condition is a “natural”2 source. Prescribed fire for all other purposes is an
“anthropogenic”3 source.
B. Wildfire that is suppressed by management action is a “natural” source. Wildfire, when suppression is
limited for safety, economic, or resource limitations, remains a “natural” source. Wildfires managed
for resource objectives are classified the same as prescribed fires.
2 Natural Emissions Source Classification (“natural”) - A categorization that designates which fire emissions can
result in a natural reduction of visibility for each Federal Class I area in the WRAP region. This classification
includes natural and human-caused ignitions.
3 Anthropogenic Emissions Source Classification (“anthropogenic”) - A categorization that designates which fire
emissions contribute to visibility impairment for a Federal Class I area. “Anthropogenic” emissions must be
controlled to achieve progress toward the 2064 natural visibility goal for each Federal Class I area in the WRAP
region. This classification includes natural and human-caused ignitions.
III-40
C. Native American cultural burning for traditional, religious, and ceremonial purposes is a “natural”
source.
For the categorization system to function appropriately, the person(s) who initiates a fire or manages the
land where fire occurs is responsible for determining the classification in a collaborative process with the
local regulatory authority.
The underlying principle for the classification of prescribed fires for ecosystem maintenance as “natural”
is the fact that these ecosystems are in, as closely as can be determined, an ecologically functional and fire
resilient condition. These areas do not contain excess fuel generated through past land management
decisions and as such; prescribed fires for ecosystem maintenance would produce emissions comparable
to natural emissions. Ecosystem maintenance prescribed fires are beneficial to these natural ecosystems
that are resilient to the application of fire. These fires have the opportunity for smoke management.
Additionally, this classification is supported by the Preamble to the Regional Haze Rule.
Other prescribed fires have various purposes including vegetative residue disposal; weeds reduction, pest
and disease control; yield improvement; commodity production; ecosystem restoration; and fire hazard
reduction. Prescribed fires that are initiated for special interests such as wildlife, recreation, range, water,
or other resources also fit into this other prescribed fire category. An underlying assumption for this
categorization is the potential for some of these types of fires to have emission controls, (e.g. use of
alternatives or emission reduction practices), in addition to smoke management. These prescribed fires
may also produce emissions greater than what most stakeholders considered could be anticipated as
natural emissions. The categorization split between prescribed fire sources was a key to agreement on the
Draft Policy at the Policy Maker Workshop and supported by the input from WRAP. Through the
consideration of economic, safety, technical and environmental considerations, the control of emissions
from some of these fire types will not be feasible.
A wildfire is any unwanted, non-structural fire that can occur on wildlands or agricultural lands caused by
human or natural ignitions. Wildfires may be suppressed by management action during which air quality
impacts can be considered. However, the ability to control the emissions from wildfires under
suppression is limited and was a key reason for the inclusion of this category as a “natural” source.
Further, the inability to control these fires and subsequent emissions does not lend this source category to
comparisons for improving the 20 percent worst visibility days and maintaining the 20 percent cleanest
visibility days under the Regional Haze Rule.
Wildfires may be managed for resource objectives through the rejection of the suppression option or
application of limited suppression. There is a conscious management decision to allow these incidents to
grow because of the resource benefits that may be accrued. The underlying principle guiding the
classification of these fires is the potential for emissions management or control similar to that of
prescribed fires and is based on the ecological condition of the land. Therefore, a wildfire managed for
resource objectives will be treated as a prescribed fire and classified according to the same criteria.
Native American prescribed burns on wildlands and agricultural lands would follow the prescribed fire
classification scheme. However, the Recommended Policy does not apply to Native American cultural
non-vegetative burning for traditional, religious or ceremonial purposes, (e.g., cremation and sweat lodge
fires. Burning for traditional, ceremonial or religious purposes will be established by the individual tribe
or tribal council. Vegetative burning is conducted by Native Americans for traditional, religious and
ceremonial purposes. Burning of this type may include, but is not limited to, sustainable plant vegetation
land burning (e.g., huckleberries and tule burning for basket making). These types of burning and
resultant classification was supported by the Policy Maker Workshop findings and input from the WRAP.
III-41
Implementation Policy
A. All fires must be managed to minimize visibility impacts.
B. All emissions from fires classified as an “anthropogenic” source will be controlled to the maximum
extent feasible subject to economic, safety, technical and environmental considerations.
C. Emissions from all fire will be tracked.
The Recommended Implementation Policy addresses the pressing need that all fires, regardless of
subsequent classification as “natural” or “anthropogenic,” must be managed to minimize their impacts on
visibility, in addition to public health and nuisance concerns. This policy was supported at the workshops
and by the WRAP as critical to addressing equity amongst fire sources and other types of air pollution
sources. Wildfire was included in this commitment as suppression decisions can be made which have air
quality as a consideration among the many others such as protection of property and firefighter safety.
This policy for management of fire addressing visibility impacts may include concepts such as the use of
best management practices, timing of ignitions for better dispersion or consideration of downwind air
quality. The FEJF is developing recommendations for the elements that should be useful for managing
fire sources with the goal of minimizing visibility impacts.
The Anthropogenic Emissions Source Classification is a categorization that designates which fire
emissions may contribute to visibility impairment and must demonstrate reasonable progress toward the
2064 natural visibility goal for each Federal Class I area in the WRAP Region. This classification
includes natural and human-caused ignitions. Previously the GCVTC Recommendations acknowledged
the role of fire across the region and noted that the use of fire would increase in the future. Several of
their Recommendations addressed the need to manage and control such fire emissions in order to achieve
reasonable progress. These Recommendations are requirements in the Regional Haze Rule. The control
of these anthropogenic sources could be accomplished by using Enhanced Smoke Management Programs
(ESMP) if needed and/or establishment of annual emissions goals to ensure visibility goals are attained.
The application of emissions reduction techniques and use of alternatives to burning subject to economic,
environmental and technical feasibility criteria would be utilized in order to meet these control objectives.
These programs and techniques are further supported by the Regional Haze Rule.
In order to determine fire’s contribution to natural background visibility conditions and/or anthropogenic
visibility impairment, all fire sources, regardless of ownership or land use type, need to be tracked across
the western region. Emissions from all fires will be tracked for two purposes, in order to classify the fire
as “natural” or “anthropogenic”, and if “anthropogenic”, to allow the demonstration of reasonable
progress toward the 2064 natural visibility goal. The GCVTC Recommendations committed to by the
Western Governors in 1996 and the subsequent 1999 Regional Haze Rule, both establish the need and
requirement for the tracking of emissions for all fire sources. The FEJF will be developing
recommendations on the parameters that will need to be tracked and at what source size level.
Currently there are vast differences in smoke management programs, use of emissions reduction
practices, and approaches to addressing the visibility effects of fire across the western region. The FEJF
is working to insure that the policy recommendations above and requirements that they represent are to be
implemented in a progressive manner. The first step for implementation of this policy is to develop
recommendations for emissions tracking, followed by the management of fires for the minimization of
visibility impacts, and then followed by potential implementation of Enhanced Smoke Management
Programs. These policies will be used in State or Tribal Implementation Plans for meeting the Regional
Haze Rule requirements.
III-42
APPENDIX IV.
RECOMMENDED POLICY APPROVAL PROCESS
NBTT Submission to FEJF - August 14, 2001
FEJF Submission to IOC/TOC - August 30, 2001
IOC Submission to WRAP - October 31, 2001
[Ed note: This document has been formatted
for 2-sided printing (i.e., duplex printing).]
Recommended Policy Approval Process
NBTT Submission to FEJF – August 14, 2001
Recommended Policy for Categorizing Fire Emissions, Draft August 14, 2001
Comments Received on Recommended Policy
August 30, 2001 FEJF Conference Call Notes
IV-1
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IV-2
RECOMMENDED POLICY FOR
CATEGORIZING FIRE EMISSIONS
PREPARED BY:
NATURAL BACKGROUND TASK TEAM OF THE FIRE EMISSIONS JOINT FORUM
DRAFT AUGUST 14, 2001
IV-3
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IV-4
TABLE OF CONTENTS
Page
1.
2.
3.
4.
INTRODUCTION
1
1.1.
Background
1
1.2.
Context
1.2.1. Current Condition and Future Fire Emissions
1.2.2. Natural Background Conditions
1.2.3. The Classification of Fire
2
2
4
5
1.3.
Purpose
6
1.4.
Scope and Applicability
6
CLASSIFICATION POLICY
7
2.1.
Classification Program Management
8
2.2.
Classification Criteria
8
CLASSIFICATION POLICY ANNOTATION
9
3.1.
Classification Program Management
3.1.1. Management to Minimize Visibility Impacts
3.1.2. Control Emissions from “Anthropogenic” Sources
3.1.3. Tracking Fire Emissions
9
10
11
12
3.2.
Classification Criteria
3.2.1. Prescribed Fire
3.2.2. Wildfire
3.2.3. Native American Cultural Burning
12
13
15
17
APPENDICES
19
Appendix A. Glossary
19
Appendix B. Recommendation for the Flagging of Visibility Data
Affected by Wildfires Under Suppression
25
Appendix C. Website References
27
IV-5
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IV-6
1. INTRODUCTION
1.1.
BACKGROUND
In 1990, Congress amended the Clean Air Act, and as part of these amendments created the
Grand Canyon Visibility Transport Commission1 (GCVTC). The GCVTC was charged with
assessing the current scientific information on visibility impacts and making recommendations
for addressing regional haze in the western United States. The GCVTC signed and submitted
more than 70 Recommendations to the Environmental Protection Agency (EPA) in a report dated
June 1996 that indicated that visibility impairment was caused by a wide variety of sources and
pollutants, and that a comprehensive strategy was needed to remedy regional haze.
The Western Regional Air Partnership (WRAP) was established in 1997 as the successor
organization to the GCVTC. The WRAP is a voluntary organization comprised of western
governors, tribal leaders and Federal agencies,2 and is charged with implementing the GCVTC
Recommendations, as well as addressing broader air quality issues, such as the Regional Haze
Rule (Rule). The WRAP is designed as a stakeholder-based organization, which uses consensus
for development of policy and technical tools. WRAP participants include state air quality
agencies, tribes, Federal/state/private land managers, the EPA, environmental groups, industry,
academia and other interested parties.
Following the issuance of the GCVTC Recommendations, the EPA issued the Regional Haze
Rule3 in July 1999 to improve visibility in 156 national parks and wilderness areas across the
country. The Rule outlines the requirements for states and tribes to address regional haze in
Federal Class I areas. EPA incorporated all of the GCVTC Recommendations into Section 309
of the Rule, which may be used by some of the WRAP states. The remaining WRAP states must
utilize the nationally applicable Section 308 provisions of the Rule.
“The State must identify all anthropogenic sources of visibility impairment considered by
the State in developing its long-term strategy. The State should consider major and minor
stationary sources, mobile sources, and area sources.”4
EPA recognizes the WRAP as the Regional Planning Organization that is developing the
necessary policy and technical tools to implement the Regional Haze Rule in the WRAP region5.
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 InterTribal Fish Commission, and the Environmental Protection Agency.
2 The WRAP members include the governors of twelve western states (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, Jicarilla Apache 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.
3 Published in the Federal Register on July 1, 1999 (64 FR 35714).
4 64 FR 35767, §51.308(d)(3)(iv).
5 The states of AZ, CA, CO, ID, MT, ND, NM, OR, SD, UT, WA, WY and 247 tribes.
Draft August 14, 2001
1
1.2.
CONTEXT
1.2.1. Current Condition and Future Fire Emissions
The GCVTC recognized fire (wildfire, prescribed fire and agricultural burning) as playing a
major role in ecosystem health in the West, and at the same time, contributing to regional haze.
“Emissions from fire (wildfire and prescribed fire) are an important contributor to
visibility-impairing aerosols,…Agricultural burning emissions and their effects have
[also] been identified as a concern of the GCVTC…”6
Throughout the WRAP region, fire is occurring as part of the natural landscape. Prescribed fire
is used for a wide variety of purposes on both wildlands and agricultural land in the region. In
addition, fire has been an integral part of tribal communities in their practice of religion and
traditional cultural activities. Tribal communities also utilize prescribed fire on wildlands and for
agricultural purposes.
All sources of fire can have an effect on air quality and visibility. Although there is uncertainty
as to the amount and apportionment of emissions from these sources vis-à-vis regional haze, it is
agreed that fire and its emissions contribute to regional haze.
The use of fire, as well as alternative treatments, is intended to provide more effective fire
suppression, predictable fire effects and management of air pollutant emissions.
“Prescribed fire promotes better fire control, predictable fire effects and allows for
management of emissions as compared to wildfire.”7
Despite the use of alternative treatments, it is recognized that prescribed fire use and resulting
emissions will increase on Federal, state, tribal and private land. These emissions will contribute
to regional haze. However, it is anticipated that the implementation of the Regional Haze Rule
can accommodate the increased use of fire on wildlands as well as the maintenance and
opportunity for continued use of fire in agricultural management.
Wildland
The GCVTC Recommendations indicated that wildfire and prescribed fire emissions could
potentially overwhelm the visibility effects of all other sources on an episodic basis, due to the
unnatural condition of vegetative fuel build-up, projected increased use of prescribed fire and the
current likelihood of catastrophic wildfire. This is true across all land ownership types.
6 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”), page 47.
7 GCVTC Report, page 47.
Draft August 14, 2001
2
“In fact, land managers propose aggressive prescribed fire programs aimed at correcting
the buildup of biomass due to decades of suppression. Therefore, prescribed fire and
wildfire levels are projected to increase significantly during the studied period [19952040]. The Commission recommends the implementation of programs to minimize
emissions and visibility impacts from prescribed fire, as well as to educate the public.”8
EPA’s Interim Air Quality Policy on Wildland and Prescribed Fires was “…prepared in
response to plans by some Federal, Tribal and State wildland owners/managers to significantly
increase the use of wildland and prescribed fires to achieve resource benefits in the wildlands.”9
Under the EPA Policy, it was acknowledged that “Many wildland ecosystems are considered to
be unhealthy as a result of past management strategies…. Wildland owners/managers plan to
significantly increase their use of fires to correct these unhealthy conditions and to reduce the
risk of wildfires to public and firefighter safety.”10
Recognition of the current ecological state of the wildlands and increased wildfire severity has
led to the development of the National Fire Plan, which has begun to be addressed through recent
Federal appropriations11. It represents a long-term commitment based on cooperation and
communication among Federal agencies, states, local governments, tribes, and concerned
publics. The Federal wildland fire management agencies have worked in close consultation with
states, governors, and interested partners to prepare a collaborative ten-year strategy12 for
implementation of the National Fire Plan.
This ten-year strategy is predicated on a commitment to the reduction of hazardous fuel loads,
with current priority in the urban-interface area. Addressing the wildland fire and hazardous fuels
situation, as well as the needs to restore and maintain forest and rangeland ecosystem health and
to ensure human safety, will necessitate a range of fuel management options. The fuel
management options include mechanical, chemical, biological, and prescribed fire treatments.
The GCVTC emphasized the need for alternatives to fire in order to address regional haze
concerns and equity among the many sources of visibility impairment. The Preamble to the Rule
cites the GCVTC Recommendation of “full consideration of alternatives to fire.”13
8 GCVTC Report, page iii.
9 U.S. EPA, Office of Air Quality Planning and Standards, Interim Air Quality Policy on Wildland and Prescribed
Fires, April 23, 1998, page 1.
10 U.S. EPA, Office of Air Quality Planning and Standards, Interim Air Quality Policy on Wildland and Prescribed
Fires, April 23, 1998, page 1.
11 2001 Interior and Related Agencies Appropriations Act (Public Law 106-291), Making Appropriations for the
Department of Interior and related agencies for the fiscal year ending September 30, 2001, and for other purposes.
12 A Collaborative Approach for Reducing Wildland Fire Risks to Communities and the Environment, 10-Year
Comprehensive Strategy, August 2001.
13 64 FR 35736.
Draft August 14, 2001
3
Agricultural Land
The Air Quality Policy on Agricultural Burning prepared by the Agricultural Air Quality Task
Force (AAQTF) asserts that “Fire has been an integral part of agricultural management as long
as man has systematically grown crops. Modern technologically based agriculture still utilizes
burning and for some crops it is the only economical means available to deal with residue.”14
Agricultural burning is utilized for a variety of purposes, the most common of which is to reduce
pre- and post-harvest vegetation that interferes with harvest, tillage or subsequent seedbed
preparation. Burning is also used for pest and weed control, as well as to reduce fire hazard from
weed infestation and clogging of ditches and irrigation canals. Tribal communities also utilize
fire for agricultural management, including weed abatement and ditch and canal clearing.
“The burning of vegetative matter associated with agricultural land management
produces a range of particulate emissions and ozone precursors. Therefore, it has the
potential to impact visibility in mandatory Class I Federal areas.”15
One of the goals of the AAQTF Policy is “to protect public health and welfare by mitigating the
impacts of air pollution emissions on air quality and visibility.”16 Toward this end, the AAQTF
Policy encourages alternatives to burning, as well as “…identifying burning methods and
determining alternative treatment strategies that can effectively reduce emissions….”17
The use of fire by agriculture is well documented. However, the extent of the fire use is not well
known in some areas, and is the cause of uncertainty as to the contribution of agricultural
burning sources on regional haze. Accordingly, the AAQTF Policy states that “…the
contribution from agriculture, specifically the impact of burning practices on regional air quality,
must be accurately assessed in relative proportion to the region’s total emissions.”18
Acknowledging this uncertainty, both the GCVTC and the Rule include agricultural burning as a
contributor to regional haze that needs to be addressed.
1.2.2. Natural Background Conditions
The Regional Haze Rule outlines the requirements for addressing regional haze in Federal Class
I park and wilderness areas, a critical element of which is the establishment of natural
background condition values. When established, these values will provide the basis by which a
state or tribe may demonstrate reasonable progress toward attaining the 2064 natural conditions
goal, as required in the Rule under both Sections 308 and 309.
There are a number of sources that EPA has identified as potential contributors to natural
background conditions, one of which is fire. The determination of natural background conditions
14 Agricultural Air Quality Task Force, Air Quality Policy on Agricultural Burning, Recommendation to the U.S.
Department of Agriculture, November 10, 1999 (hereafter “AAQTF Air Quality Policy on Agricultural Burning”),
Section IV, A.
15 AAQTF Air Quality Policy on Agricultural Burning, Section IV, E.
16 AAQTF Air Quality Policy on Agricultural Burning, Section II.
17 AAQTF Air Quality Policy on Agricultural Burning, Section VI, B, 2.
18 AAQTF Air Quality Policy on Agricultural Burning, Section VII.
Draft August 14, 2001
4
may take into account impacts from potential natural sources of visibility impairing pollutants
such as natural vegetative hydrocarbon emissions (e.g., terpines from trees), oceanic sulfates,
natural wind suspended dust, fire, and sulfate and nitrate from volcanoes.
Due to climatic variations that affect the role of fire on the landscape, natural background
conditions are anticipated to fluctuate. The use of tree ring analysis has scientifically
demonstrated this phenomenon. For example, an increase of fire scars is indicative of higher fire
occurrence during times of drought. To this end, climatic changes will have a direct effect on the
variability of natural background conditions as influenced by fire.
The Regional Haze Rule Preamble stipulates that fire of all kinds contributes to regional haze
and that fire can have both natural and human-caused sources. The Preamble further states that
some fire that is human ignited may be included in a state’s or tribe’s determination of natural
background conditions.
“EPA believes that States [and Tribes] must take into account the degree to which fire
emissions cause or contribute to ‘manmade’ visibility impairment and its contribution to
natural background conditions.”19
To address the implementation of specific sections of the Rule, the WRAP has established
several committees and forums. The Ambient Air Monitoring & Reporting Forum (AMRF) is
working to develop guidance on the determination of natural background, taking into
consideration emissions that can result in a natural reduction of visibility. The Fire Emissions
Joint Forum (FEJF) is addressing both policy and technical issues concerning smoke effects that
are caused by wildland and agricultural fire on public, tribal and private lands.
The AMRF will analyze the Interagency Monitoring of Protected Visual Environments
(IMPROVE) visibility monitoring data to establish a baseline, current conditions, and track
reasonable progress toward the 2064 natural conditions goal, as required in the Rule. Organic
carbon aerosol, as monitored by IMPROVE, is a significant contributor to regional haze in the
WRAP region. The current monitoring technology is unable to identify the source of organic
carbon aerosol monitored at Federal Class I areas, of which fire has been acknowledged as a
major source. As technology and science develops, with regard to the ability to differentiate fire
impacts as compared to other sources for the purposes of tracking reasonable progress toward the
2064 natural conditions goal, the needs and methods of tracking are anticipated to change.
1.2.3. The Classification of Fire
Due to the limitations of the current monitoring technology, the AMRF requested that the FEJF
work on determining the classification of fire emissions as either “natural” or “anthropogenic”.
This classification will be an important component for fire’s inclusion in natural background
condition values and ultimately, the tracking of reasonable progress. The Natural Background
Task Team (NBTT) was created by the FEJF to assist in this effort.
19 64 FR 35735.
Draft August 14, 2001
5
This Policy was developed through a broad, multi-stakeholder-based public review process that
included two workshops designed to gather both technical and policy input. The review process
included direct input from the FEJF, WRAP, and other parties. The NBTT has submitted
progress reports as well as work products to the FEJF for input and approval. The Policy is a
work product of the FEJF for the WRAP.
1.3.
PURPOSE
“The EPA also recognizes that fire of all kinds (wildfire, prescribed fire, etc.) contributes
to regional haze, and that there is a complex relationship between what is considered a
natural source of fire versus a human-caused source of fire.”20
This Policy, developed under the WRAP, will aid states and tribes in determining which fire
emissions will be considered as part of the natural background conditions in Federal Class I
areas. The remaining fire emissions will be considered “anthropogenic” and, as such, subject to
reasonable progress requirements of the Rule. This Policy clarifies the relationship between what
would be defined as a “natural” fire emissions source and what would be defined as an
“anthropogenic” fire emissions source, thereby addressing the complex relationship EPA
acknowledges in the Preamble to the Rule.
Under this Policy, fire emissions sources are, for the most part, classified as “anthropogenic”.
These sources will be controlled to the maximum extent feasible, which is in keeping with the
Rule’s primary objective of the development of long-term strategies for reducing emissions of
visibility impairing pollutants. Additionally, the “anthropogenic” classification recognizes that
there is potential to control the emissions from most fires, as acknowledged in the GCVTC
Recommendations, the Regional Haze Rule, and the stakeholder participation process.
Some fire emissions sources have been classified as “natural”, and, like “anthropogenic” sources,
will be managed to minimize potential air quality impacts. The rationale for “natural”
classifications is clearly stated in the annotated sections, and reflects the reasoning of the
GCVTC, the Rule, stakeholder input, as well as current smoke management capabilities.
Furthermore, both the management of “natural” source emissions, and the management and
control of “anthropogenic” source emissions represent key points of convergence among
stakeholders that are fundamental to the development of this Policy.
1.4.
SCOPE AND APPLICABILITY
This Policy exclusively addresses the effects of fire emissions in terms of visibility and the
requirements of the Regional Haze Rule. It does not address potential natural sources of
visibility reducing pollutants such as natural vegetative hydrocarbon emissions (e.g., terpines
from trees), oceanic sulfates, natural wind suspended dust, and sulfate and nitrate from
volcanoes. Air pollutant emissions from fires may also impact public health and cause nuisance
smoke intrusions. This Policy may strengthen processes and current systems in place that
address these smoke concerns; however, this specific interaction is being addressed through
further recommendations by the FEJF.
20 64 FR 35735.
Draft August 14, 2001
6
“All types of fire (prescribed fire and agricultural burning) must be addressed equitably
as part of a visibility protection strategy.”21
This Policy applies to both wildland and agricultural lands regardless of ownership (i.e., Federal,
state, tribal, public, private), cause of ignition (e.g., lightning, arson, accidental human, land
management practices) or purpose of the fire (e.g., vegetative residue disposal, hazard reduction,
maintain ecosystem health). It is the intent that this Policy be applied equitably across all land
types and sources.
This Policy does not apply to other open burning activities on residential, commercial, or
industrial property (e.g., backyard burning, garbage incineration, residential wood combustion,
construction debris). This Policy does not apply to Native American cultural non-vegetative
burning for traditional, religious or ceremonial purposes (e.g., cremation, sweat lodge fires).
This Policy applies to impacts on Federal Class I areas in the WRAP region. Emissions from all
fire (wildland and agricultural) are to be accounted for in both Sections 308 and 309 of the Rule.
Stakeholder input advocated a consistent consideration of fire utilizing either Section 308 or 309
of the Rule. This input was a guiding principle for the development of this Policy. States and
tribes in the WRAP region are anticipated to incorporate this Policy into the technical support
documentation for a State or Tribal Implementation Plan (SIP/TIP) submitted to EPA in order to
meet the requirements of the Rule.
The categorization of fire emissions, as established by the Policy, will facilitate the establishment
of natural background condition values and ultimately, the tracking of reasonable progress for a
SIP or TIP. As the SIPs/TIPs will be revisited and revised, per the schedule specified in the
Rule, there will be opportunities to refine this Policy to reflect scientific advances and/or policy
changes.
2. CLASSIFICATION POLICY
The Classification Policy is made up of six statements, three of which address the program
management of classification, and three that address the criteria for the classification of fire
emission sources. The Classification Criteria statements of the Policy determine the “natural”
and “anthropogenic” sources of fire that contribute to regional haze, as stated in the Preamble to
the Rule. The Classification Program Management statements express the requirements that
enable classification to be effective and equitable. The Program Management statements adhere
to the findings and Recommendations of the GCVTC related to fire and fire emissions, as well as
the reasoning expressed in the Rule.
The Classification Program Management statements express requirements that need to exist but
do not attempt to describe how they will be brought about (e.g., the development of requirements
for a tracking system or smoke management program). That work is currently underway in the
FEJF as well as other WRAP Forums.
21 GCVTC Report, page 47.
Draft August 14, 2001
7
The classification of fire emissions is predicated on the distinction between a “natural” emissions
source classification and an “anthropogenic” emissions source classification, the definitions of
which follow.
Natural Emissions Source Classification (“natural”) - A categorization that designates
which fire emissions can result in a natural reduction of visibility for each Federal Class I
area in the WRAP region. This classification includes natural and human-caused
ignitions.
Anthropogenic Emissions Source Classification (“anthropogenic”) - A categorization that
designates which fire emissions contribute to visibility impairment in a Federal Class I
area. “Anthropogenic” emissions must be controlled to achieve progress toward the 2064
natural conditions goal for each Federal Class I area in the WRAP region. This
classification includes natural and human-caused ignitions.
The following Classification Program Management and Classification Criteria statements apply
to both wildland and agricultural lands regardless of ownership, cause of ignition, or purpose of
the fire within the WRAP region.
2.1.
CLASSIFICATION PROGRAM MANAGEMENT
A. All fires must be managed to minimize visibility impacts.
B. All emissions from fires classified as an “anthropogenic” source will be controlled to the
maximum extent feasible subject to economic, safety, technical and environmental
considerations.
C. Emissions from all fire will be tracked.
2.2.
CLASSIFICATION CRITERIA
A. Prescribed Fire is an “anthropogenic” source, except where it is utilized to maintain an
ecosystem that is currently in an ecologically functional and fire resilient condition, in which
case it is classified as a “natural” source.
B. Wildfire that is suppressed by management action is a “natural” source. Wildfire, when
suppression is limited for safety, economic, or resource limitations, remains a “natural”
source. Wildfires managed for resource objectives are classified the same as prescribed fires.
C. Native American cultural burning for traditional, religious, and ceremonial purposes is a
“natural” source.
Draft August 14, 2001
8
3. CLASSIFICATION POLICY ANNOTATION
3.1.
CLASSIFICATION PROGRAM MANAGEMENT
The following sections provide clarifying and supporting information regarding each of the three
Classification Program Management statements from Section 2 above. The three Program
Management statements apply to both wildland and agricultural lands regardless of ownership,
cause of ignition, or purpose of the fire within the WRAP region.
The Classification Program Management statements express the management elements that
enable classification of fire emissions sources to be effective and equitable. The Program
Management statements adhere to the findings and Recommendations of the GCVTC related to
fire and fire emissions, as well as to the reasoning expressed in the Rule.
The Rule requires that states, “…must consider, at a minimum, the following factors in
developing its long-term strategy: (E) Smoke management techniques for agricultural and
forestry management purposes including plans as currently exist within the State for these
purposes;”22
However, there are currently vast differences in smoke management programs, use of emissions
reduction practices, and approaches to addressing the visibility effects of fire across the WRAP
region. These differences may include state legislative requirements or those of tribal
government that exist in the implementation of some of the program management elements.
Generally, most current smoke management programs address only public health and nuisance
concerns, and do not address all the potential visibility-impacting fire emissions sources, nor do
they have procedures to address minimization of visibility impacts.
In recognition of this, the FEJF is working to insure that the policy and program management
recommendations that the Forum develops are implemented through the WRAP in a progressive
manner. The first step for implementation of this Policy is to develop emissions tracking,
followed by the management of fires for the minimization of visibility impacts, and then
followed by potential implementation of Enhanced Smoke Management Programs (ESMP). The
timeframe for implementation of this Policy will be affected by a state’s or tribe’s current
approach to address smoke effects.
22 64 FR 35767, §51.308(d)(3)(v)(E).
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3.1.1. Management to Minimize Visibility Impacts
Statement: All fires must be managed to minimize visibility impacts.
“All types of fire (prescribed fire and agricultural burning) must be addressed equitably
as part of the visibility protection strategy.”23
“The [implementation] plan must provide for: (i) 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….”24
This policy statement addresses the pressing need that all fires, regardless of subsequent
classification as “natural” or “anthropogenic”, must be managed to minimize their impacts on
visibility in Federal Class I areas, in addition to public health and nuisance concerns. This
concept is recognized in both the GCVTC Recommendations and in the Regional Haze Rule.
This policy statement was also supported by both stakeholder input and by the WRAP as critical
to achieving equity among fire emissions sources and other types of air pollution sources.
Some stakeholders, however, did express concern that air quality considerations would prove
difficult to apply to wildfires under suppression, since they are managed with firefighter and
public safety and protection of property and resources as primary criteria for strategic decisionmaking. It should be noted that consideration of air quality is already required on Federal lands25
during the evaluation of alternate fire management strategies and, under this Policy, will need to
be considered regardless of land ownership. However, air quality considerations are just one of
several important criteria that are weighed according to positive, neutral, or negative effects and
evaluated to select the appropriate management response to the wildfire.
It should be emphasized that the ability to control the emissions from wildfires under suppression
can be limited. Therefore, these emissions cannot be incorporated into the demonstration of
reasonable progress toward the 2064 natural conditions goal, and as a result, are classified as
“natural”.
Management of all fire emissions to minimize visibility impacts must include, but is not limited
to, concepts such as the timing of ignitions for better dispersion and consideration of downwind
air quality and visibility. It may also include the use of best management practices, such as the
use of alternatives, biomass utilization, and other emission reduction techniques. Responsibility
for the utilization of fire emissions management techniques resides with the person(s) or entity
that initiates a fire or manages the land where fire occurs. Due to economic, safety, technical and
environmental considerations, the use of some of the management techniques may not be
feasible. The FEJF is developing recommendations for managing fire emissions sources with the
goal of minimizing visibility impacts.
23 GCVTC Report, page 47.
24 64 FR 35771, §51.309(d)(6)(i).
25 Wildland Fire Situation Analysis (WFSA).
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3.1.2. Control Emissions from “Anthropogenic” Sources
Statement: All emissions from fires classified as an “anthropogenic” source will be
controlled to the maximum extent feasible, subject to economic, safety, technical and
environmental considerations.
The Anthropogenic Emissions Source Classification is a categorization that designates which fire
emissions may contribute to visibility impairment and therefore, must demonstrate reasonable
progress toward the 2064 natural conditions goal for each Federal Class I area in the WRAP
Region. This classification includes natural and human-caused ignitions.
The “anthropogenic” classification recognizes the fact that there is potential for most fires to
have emission controls (e.g., use of alternatives or emission reduction practices), in addition to
being managed to minimize visibility impacts as discussed above. Per the GCVTC
Recommendations, economic, safety, technical and environmental considerations are part of the
application of emission controls for the implementation of this Policy statement. Due to these
considerations, the control of emissions from some fire types may not be feasible, which will be
determined by the land manager in collaboration with the applicable air quality regulatory
authority. The FEJF is developing guidance for feasibility (i.e., economic, safety, technical and
environmental considerations) determinations.
“The [implementation] plan must provide for: (v) Establishment of annual emission goals
for fire, excluding wildfire, that will minimize emission increases from fire to the
maximum extent feasible and that are established in cooperation with States, tribes,
Federal land management agencies, and private entities.”26
The control of these anthropogenic sources to ensure visibility goals are attained will be
accomplished by the establishment of annual emissions goals and, if applicable, by using an
Enhanced Smoke Management Program (ESMP), as stated in the Regional Haze Rule. The FEJF
is developing recommendations for the WRAP for the ESMP and how an annual emissions goal
may be created.
The application of emissions reduction techniques and use of alternatives to burning subject to
economic, safety, technical and environmental feasibility criteria would be utilized in order to
meet the control objectives for fire emissions sources classified as “anthropogenic”. These
programs and techniques are further supported by the Regional Haze Rule. The FEJF is assessing
the availability and feasibility of alternatives to burning for both wildlands and agricultural lands.
26 64 FR 35771, §51.309(d)(6)(v).
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3.1.3. Tracking Fire Emissions
Statement: Emissions from all fire will be tracked.
In order to determine fire’s contribution to natural background visibility conditions and
anthropogenic visibility impairment, all fire emissions sources, regardless of ownership or land
use type, need to be tracked across the WRAP region. The GCVTC Recommendations,
committed to by the western Governors in 1996, and the subsequent 1999 Regional Haze Rule,
both establish the need and requirement for the tracking of emissions for all fire emissions
sources.
“Implement an emissions tracking system for all fire activities.”27
“The [implementation] plan must provide for: (ii) A statewide inventory and emission
tracking system (spatial and temporal) of VOC, NOx, elemental and organic carbon, and
fire particle emissions from fire….”28
Emissions from all fires will be tracked for two purposes, to classify the fire as “natural” or
“anthropogenic”, and, if “anthropogenic”, to facilitate the demonstration of reasonable progress
toward the 2064 natural conditions goal. The use of alternatives and emission reduction practices
needs to be in a fire emissions tracking system for the demonstration of reasonable progress and
annual emissions goal accounting process. The FEJF will be developing recommendations on the
parameters that will need to be tracked and for what source size.
3.2.
CLASSIFICATION CRITERIA
The following sections provide clarifying and supporting information regarding each of the three
Classification Criteria statements from Section 2 above. The three Criteria statements apply to
both wildland and agricultural lands regardless of ownership, cause of ignition, or purpose of the
fire within the WRAP region.
For the most part, fire emissions sources are classified “anthropogenic”. The “anthropogenic”
classification recognizes that there is potential to control the emissions from most fires, as
acknowledged in the GCVTC Recommendations, the Regional Haze Rule, and the stakeholder
participation process. Some fire emissions sources have been classified as “natural”, and, like
“anthropogenic” sources, will be managed to minimize potential air quality impacts. The
rationale for “natural” classifications is clearly stated in the following annotated sections, and
reflects the reasoning of the GCVTC, the Rule, stakeholder input, as well as current smoke
management capabilities.
For the categorization of fire emissions to function appropriately, the person(s) or entity that
initiates a fire or manages the land where fire occurs is responsible for determining the
classification using this Policy, with oversight by the applicable air quality regulatory authority.
27 GCVTC Report, page 48.
28 64 FR 35771, §51.309(d)(6)(ii).
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3.2.1. Prescribed Fire
Statement: Prescribed Fire is an “anthropogenic” source, except where it is utilized
to maintain an ecosystem that is currently in an ecologically functional and fire
resilient condition, in which case it is classified as a “natural” source.
A prescribed fire is any fire ignited by a planned management action to meet specific objectives
on agricultural land or wildland, regardless of land ownership. Prescribed fires may have various
purposes including, but not limited to, vegetative residue disposal, pest and disease control, yield
improvement, ecosystem restoration, ecosystem maintenance, and hazardous fuel reduction.
Often, prescribed fire will meet multiple objectives. It is the intent of this Policy that the fire’s
classification will be determined based on the primary and predominant purpose for the fire.
This portion of the Policy also applies to wildfires managed for resource benefits, as addressed
by Classification Criteria statement B.
Ecosystem Maintenance
“…EPA believes States should be permitted to consider some amount of fire in the
calculation [of natural background] to reflect the fact that some prescribed fire effects
serve merely to offset what would be expected to occur naturally.”29
The primary distinction in classifying prescribed fire is between ecosystem restoration and
maintenance. Only prescribed fire used to maintain an ecosystem is classified as “natural”. All
other prescribed fire, including restoration of ecosystems, is classified as “anthropogenic”. This
distinction was based on stakeholder input as a key to agreement on the development of this
Policy, and reflects the reasoning of both the Regional Haze Rule Preamble and the GCVTC
Recommendations.
“Fire has played a major role in the development and maintenance of most ecosystems in
the West. The long-term future of the West is dependent on healthy ecosystems that are
capable of sustaining natural processes and human uses. ... Fire is an essential component
of most natural ecosystems, and perpetuation of fire at a level required to maintain
ecosystem processes is necessary.”30
Ecosystem maintenance prescribed fires are beneficial to natural ecosystems that are resilient to
the application of fire.31 Further, these areas are free from excess fuel generated through past
land management decisions. Where fire is used to mimic the natural process, that fire is
classified “natural”, which recognizes that these fires have the opportunity for smoke
management. Additionally, stakeholder input recognized that imitating the natural process with
prescribed fires for ecosystem maintenance produces emissions comparable to those that would
occur naturally.
29 64 FR 37535-35736.
30 GCVTC Report, page 47.
31 For example, in a big sage and grass ecosystem, diversity of species and age class is required for the fire to be
classified as maintenance burn.
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It should be noted that the science of determining a fully functional and fire resilient ecosystem
is continually evolving. It is the intent of this Policy to accommodate future changes in the
understanding and subsequent determination of the broad range of ecosystems.
A “natural” classification may only be assigned to a prescribed fire when the person(s) or entity
that initiates the prescribed fire determines that the fire is in an area identified as being in an
ecologically functional and fire resilient condition.32 Further, the “natural” classification will
only hold if maintenance of the area’s ecosystem is the primary and predominant purpose of the
burn. This classification will be made with oversight by the applicable air quality regulatory
authority.
Ecosystem Restoration & Prescribed Fire for Other Purposes
“The EPA recognizes the natural role of fire in forest ecosystems, and the fact that forest
fuels have built up over many years due to past management practices designed to protect
public health and safety through fire suppression. Research has shown that these practices
have led to an increased risk of catastrophic wildfire as well as reduced forest health. In
response to this situation, the Federal land management agencies, as well as some States
and private landowners, have recommended the increased use of prescribed fire in order
to return certain forest ecosystems to a more natural fire cycle and to reduce the risk of
adverse health and environmental impacts due to catastrophic wildfire.”33
Ecosystem restoration is the re-establishment of natural vegetation and may be accomplished
through the reduction of unwanted and/or unnatural levels of biomass, which may have
accumulated due to management action (e.g., long-term wildland fire suppression or hazardous
fuel treatment). Prescribed fires and mechanical treatments may be necessary to restore an
ecosystem to an ecologically functional and fire resilient condition. Ecosystem restoration may
also be used to control undesirable plant species.34 All burning for ecosystem restoration
purposes is classified as “anthropogenic”.
Prescribed fire may be utilized for purposes other than ecosystem restoration and maintenance. It
may be conducted for the purpose of vegetative residue disposal (e.g., timber slash or wheat
stubble burning). Prescribed fire may be used to increase or maintain agricultural and
silvicultural output or increase forage values.35 Fires may also be utilized to control weeds, pests,
and diseases, and improve yield (e.g., grass and rice field burning). Hazard reduction burning
32 Currently, there is an assessment of condition classes for wildlands at the national programmatic level, as defined
in the National Fire Plan and the Cohesive Strategies for the USDA-Forest Service and Department of Interior. This
assessment will help in defining those ecosystems that are in a condition where burning can be classified as
“natural”. More refined planning, to determine both fire’s role and application, will be done at the land-use planning
level or site-specific level.
33 64 FR 35735.
34 For example, in the Great Basin, prescribed fire used in conjunction with an application of herbicide followed by
reseeding is proving to be successful in reducing the spread of cheatgrass (an invasive Mediterranean annual grass),
which burns at a much higher frequency than the natural vegetation.
35 For example, periodic burning eliminates shrubs that have invaded grasslands, thereby improving forage on the
rangeland for livestock.
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may be conducted in areas of accumulated wildland fuels to reduce the risk of wildfire.36
Prescribed fires that are initiated for special interests such as wildlife, recreation, range, water, or
other resources also fit into this other prescribed fire category.37
Key to the categorization of other prescribed fire (except ecosystem maintenance) as an
“anthropogenic” source, is the recognition that there is potential to control the emissions from
most fires, in addition to smoke management. Stakeholders additionally recognized that these
fires, in most cases, could produce emissions greater than what could be anticipated to occur
naturally.
3.2.2. Wildfire
Statement: Wildfire that is suppressed by management action is a “natural” source.
Wildfire, when suppression is limited for safety, economic, or suppression resource
limitations, remains a “natural” source. Wildfires managed for resource objectives
are classified the same as prescribed fires.
A wildfire is any unwanted, non-structural fire that can occur on wildlands or agricultural lands.
Unwanted wildfires can be ignited by both natural causes such as lightning, or human causes
such as accidental human ignitions or intentional ignitions (i.e., arson). Examples of accidental
human ignitions include fireworks, cigarettes, escaped campfires, vehicle fires, and fires from
farm machinery. Arson is defined as the intentional start of a fire with the intent to either
maliciously or fraudulently damage property of one’s own or that of another.
Wildfires may be suppressed by management action, or they may be managed for resource
objectives through the rejection of the suppression option or application of limited suppression.
Suppressed by Management Action
Wildfires that are under suppression are unwanted, non-structural fires that are being actively
suppressed due to threats to public health and safety, firefighter safety, or damage to property
and/or natural resources (e.g., South Canyon wildfire of 1994 in Colorado). The term
“management action” denotes the overriding intent to suppress (i.e., control) the unwanted
wildfire due to the considerations expressed above.
The ability to control the emissions from wildfires under suppression is limited, which was the
underlying principle for the inclusion of this source in the “natural” classification. Further, the
fact that, in most instances, everything possible is being done to suppress the fire safely and
economically also supported a “natural” source classification.
36 For example, in the wildland/urban interface a prescribed fire in Ponderosa Pine may be ignited during the fall to
consume an over-accumulation of pine needles and other undergrowth that, if left untreated, would provide a
“ladder” for fire to reach the crowns of the trees.
37 Several examples follow: 1) To protect a watershed, prescribed fire can be used to create a mosaic of age classes
in many vegetation types each having a different flammability, reducing the likelihood that an entire watershed will
all burn at the same time. 2) Brush or forest fuels may be burned to improve a scenic vista. 3) A prescribed fire may
be utilized to improve forage and/or habitat that will increase hunting opportunities.
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In the evaluation of alternative wildfire management strategies, several constraints are
considered in selecting the appropriate management action. These constraints may include
firefighter and public safety, risk to property, available firefighting resources, and others, such as
air quality considerations. In some instances, suppression efforts for a wildfire may be limited
due to safety, economic or suppression resource limitations (e.g., equipment or personnel), as
was the case in Montana during the wildfires of 2000 when the need exceeded the available
resources. In these cases, the wildfire is classified as “natural”.
On Federal lands38, one of the constraints already under consideration during the evaluation of
alternate fire management strategies is air quality. Air quality will need to be considered on all
lands, regardless of ownership. However, air quality considerations are just one of several
important criteria, such as firefighter and public safety and protection of property and resources,
that are weighed according to positive, neutral, or negative effects, and evaluated to select the
appropriate management response to the wildfire.
The potential is high for significant visibility impacts from episodic wildfires under suppression,
as demonstrated by recent wildfire seasons (i.e., 1996 and 2000). During the development of this
Policy, stakeholders expressed concern that the visibility improvements resulting from emissions
reduction programs for industrial, mobile, and other anthropogenic sources may be masked by
visibility impacts from wildfires under suppression. This Policy contains a recommendation in
Appendix B that a workgroup be formed to study the effects from unwanted wildfire events and
consider the development of an approach similar to that of EPA’s Natural Events Policy for
visibility data.
Managed for Resource Objectives
The key distinction between wildfires suppressed by management action and wildfires managed
for resource objectives is the conscious management decision to allow these incidents to grow
toward the achievement of specific resource benefits.
Wildland Fire Managed for Resource Benefits, Prescribed Natural Fire, and Wildland Fire Use
are all terms that have current use in regulations and policies, and are considered to be
synonymous. These terms refer to the management of wildland fires to accomplish specific, prestated resource management objectives in predefined geographic areas, under pre-determined
conditions (e.g., weather, firefighting resources available, etc.) as outlined in an approved fire
management plan or as applied on non-Federal land in the field without a plan.39
At present, these types of fires occur primarily on federally managed lands. It is possible that in
the future, state, tribal, municipal, or private landowners may choose to utilize the same
management response, with or without a plan in place.
38 Wildland Fire Situation Analysis (WFSA).
39 For example, a wildfire that starts in a wilderness area, where the ecosystem is currently in an ecologically
functional and fire resilient condition and there is little or no threat to life or property, can be allowed to play its
natural role as outlined in an approved fire management plan.
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The underlying principle guiding the classification of these fires is the potential for emissions
management and/or control, which is the same as that of prescribed fires. The classification in
these instances, just like prescribed fire, is based on the ecological condition of the land.
Therefore, a wildfire managed for resource objectives will be treated as a prescribed fire and
classified according to the same criteria.
Escaped Prescribed Fire
It is estimated that more than 99 percent of the prescribed fires in the WRAP region are
accomplished with few or no control problems, i.e., do not escape. An escaped prescribed fire is
any fire ignited by management actions on wildland or agricultural land to meet specific
objectives, that goes out of prescription (e.g., fire intensity greater than specified in a pre-set fire
plan, pre-set wind speeds exceeded, fire jumps pre-established boundaries, etc.) in a predefined
geographic area. For example, the Cerro Grande fire of 2000 in New Mexico was an escaped
prescribed fire. An escaped prescribed fire can no longer accomplish the land and resource
management objective of the prescribed fire when it goes out of prescription.
The few prescribed fires that do escape become wildfires, and require appropriate suppression
action by the land manager. The underlying principle guiding the classification of these fires is
the recognition that the ability to control the emissions from escaped prescribed fires is limited,
which is the same as that of wildfires under suppression. Therefore, an escaped prescribed fire
will be treated as a wildfire under suppression and classified according to the same criteria (i.e.,
as “natural”).
The classification of an escaped prescribed fire as a wildfire under suppression is consistent with
EPA’s Natural Events Policy. Under the Natural Events Policy, high particulate matter
concentrations attributable to unwanted wildfires can be treated as due to a natural event. 40
3.2.3. Native American Cultural Burning
Statement: Native American cultural burning for traditional, religious, and
ceremonial purposes is a “natural” source.
This Classification Criteria statement applies to vegetative burning conducted by Native
Americans for traditional, religious and ceremonial purposes. The purposes of burning may
include, but are not limited to, burning grasslands and forestlands for basket materials (e.g.,
hazel, bear grass, tule, and iris), medicinal and ceremonial plants, and subsistence plants (e.g.,
acorns, huckleberry, and pine nuts). Where fire is used for traditional, religious or ceremonial
purposes, that fire is classified as “natural”, which recognizes that these fires have the
opportunity for smoke management. Individual tribes and/or tribal councils will establish the
vegetative burning that falls into this categorization.
40 U.S. EPA, Natural Events Policy for Particulate Matter, June 6, 1996, page 6.
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This Policy makes a distinction between traditional, religious and ceremonial vegetative burning
purposes and other non-vegetative burning activities. This Policy does not apply to Native
American cultural non-vegetative burning for traditional, religious or ceremonial purposes (e.g.,
cremation, sweat lodge fires). Individual tribes and/or tribal councils may identify these purposes
of burning by resolution, rule or ordinance as established by the tribal council for traditional,
ceremonial or religious use. These burns will not be tracked or considered in the establishment of
either natural background conditions nor toward the reasonable progress requirements of the
Regional Haze Rule.
A “natural” classification may be assigned to a Native American cultural burn when the
person(s) or entity that initiates the vegetative burn determines, with oversight by the applicable
air quality regulatory authority, that the fire has been established by the tribe or tribal council for
a traditional, religious, or ceremonial purpose. All other Native American vegetative burning is
prescribed fire and will be classified accordingly. The categorization distinction within Native
American fire (i.e., vegetative burning for traditional, religious, and ceremonial purposes vs.
prescribed fire) was based on stakeholder recognition of certain traditions specific to the Native
American culture.
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4. APPENDICES
APPENDIX A.
GLOSSARY
This glossary is intended to provide readers with several operating definitions to facilitate a
consistent review of the Policy. However, this glossary is not intended to be a complete list of all
terms and acronyms.
2064 Natural Conditions Goal - The ultimate goal of the regional haze program is the absence of
visibility impairment due to human-caused emissions.
AAQTF - Agricultural Air Quality Task Force. A task force to address agricultural air quality
issues established by the Chief of the Natural Resources Conservation Service.
Accidental Human Ignition - An unintentional random event. (E.g., Fire ignited by a cigarette
butt, an escaped campfire, or a combine.)
Agricultural Fire/Burning* - Any fire ignited by management actions to meet specific objectives
(i.e., managed to achieve resource benefits) on agricultural land.
Agricultural Land* - Agricultural land includes croplands, pasture, and other lands on which
crops or livestock are produced (PL 104-127, Section 1240A). Rangeland will be included
with wildland for the purposes of the Fire Emissions Joint Forum work.
AMRF - Ambient Air Monitoring and Reporting Forum. The Ambient Air Monitoring and
Reporting Forum was established to make recommendations to the Western Regional Air
Partnership with regard to appropriate approaches for collection, use, and reporting of
ambient air quality and meteorological monitoring data as needed to further the overall
goals of the Western Regional Air Partnership.
Anthropogenic Emissions Source Classification (“anthropogenic”) - A categorization that
designates which fire emissions contribute to visibility impairment in a Federal Class I
area. “Anthropogenic” emissions must be controlled to achieve progress toward the 2064
natural conditions goal for each Federal Class I area in the WRAP region. This
classification includes natural and human-caused ignitions.
Arson - The intentional, malicious or fraudulent ignition of a fire or explosion that damages
property of the arsonist or another. (E.g., A fire intentionally ignited to accrue ill-gotten
gains, such as from an insurance settlement, or a fire intentionally ignited as retribution
against a land manager.)
* Operating Definitions from Section 1.1 of the WRAP FEJF Workplan dated February 25, 1999.
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Control of Fire - The controllability of a fire is dictated by a variety of considerations such as fire
fighter and public safety, risk to property and resources, fire fighting resources available,
land management objectives, and environmental, social, economic, and political
constraints. The environmental and social constraints include, among other things, how
air quality and/or visibility will be affected at sensitive receptors. Control of fire is
analogous to full suppression by management action.
Control of Fire Emissions - Actions may be taken to control fire emissions by utilizing best
management practices such as the use of alternatives, biomass utilization, and other
emission reduction techniques.
Ecosystem Maintenance - 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.
Ecosystem Restoration - The re-establishment of natural vegetation that may be accomplished
through the reduction of unwanted and/or unnatural levels of biomass, which may have
accumulated due to management action. Prescribed fires, wildfires managed for resource
benefits and mechanical treatments may be utilized to restore an ecosystem to an
ecologically functional and fire resilient condition.
EPA - United States Environmental Protection Agency
Escaped Prescribed Fire - Any fire ignited by management actions on wildland or agricultural
land to meet specific objectives that goes out of prescription (e.g., fire intensity greater
than specified in a pre-set fire plan, pre-set wind speeds exceeded, fire jumps preestablished boundaries, etc.) in a predefined geographic area.
Federal Class I area - In 1977, Congress identified 156 national parks, wilderness areas,
international parks and other areas that were to receive the most stringent protection from
increases in air pollution. It also set a visibility goal for these areas to protect them from
future human-caused haze, and to eliminate existing human-caused haze, and required
reasonable progress toward that goal.
FEJF - Fire Emissions Joint Forum. The Fire Emissions Joint Forum’s mission is to address both
policy and technical issues while developing programs and tools relating to prescribed
fire and air quality for the Western Regional Air Partnership and related Western
Regional Air Partnership forums.
Fire* - When this term appears, it refers inclusively to wildfire, prescribed natural fire/wildland
fire managed for resource benefits, prescribed fire, rangeland fire, and agricultural fire.
* Operating Definitions from Section 1.1 of the WRAP FEJF Workplan dated February 25, 1999.
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GCVTC - Grand Canyon Visibility Transport Commission. The GCVTC was authorized under
Section 169B(f) of the Clean Air Act and 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. The Commission was established to recommend methods to preserve
and improve visibility on the Colorado Plateau, and submitted Recommendations to EPA
in June 1996.
Hazard Reduction - Burning of accumulated wildland fuels to reduce the risk of wildfire. (E.g.,
Wildland/urban interface burning or burning in areas of especially combustible fuels.)
IMPROVE - Interagency Monitoring of Protected Visual Environments. A cooperative visibility
monitoring effort, using a common set of standards across the United States, between the
EPA, Federal land management agencies, and state air agencies.
Land Managers* - When this term appears, it refers inclusively to Federal, state, tribal, and
private land managers.
Manage Fire Emissions - Actions may be taken to manage fire emissions to minimize impacts on
visibility, public health, and nuisance concerns. Some management actions include
concepts such as the timing of ignitions for better dispersion and consideration of
downwind air quality and visibility. It may also include consideration of factors related to
the area to be burned such as the fuel moisture condition and other physical parameters.
Manage fire emissions is analogous to smoke management.
NAAQS – National Ambient Air Quality Standards
Natural Background Condition - An estimate of the visibility conditions at each Federal Class I
area that would exist in the absence of human-caused impairment.
Natural Emissions Source Classification (“natural”) - A categorization that designates which fire
emissions can result in a natural reduction of visibility for each Federal Class I area in the
WRAP region. This classification includes natural and human-caused ignitions.
Natural Ignition - Fire/Burn ignited due to a natural (i.e., non-human-caused) event. (E.g., Fire
ignited by lightning or volcanic eruption.)
NBTT - Natural Background Task Team. A task team of the Fire Emissions Joint Forum
working on determining the classification of fire emissions as either “natural” or
“anthropogenic”. Team members include Forum and non-Forum members with special
expertise.
* Operating Definitions from Section 1.1 of the WRAP FEJF Workplan dated February 25, 1999.
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Organic Carbon - Complex carbon-containing compounds often emitted by plants and from
many human activities.
Pasture Land - Grazing lands comprised of introduced or domesticated native forage species that
are used primarily for the production of livestock. They receive periodic renovation
and/or cultural treatments such as tillage, fertilization, mowing, weed control, and may be
irrigated. They are not in rotation with crops (Natural Resources Conservation Service
National Range and Pasture Handbook, 1997.)
Prescribed Fire* - Any fire ignited by management actions to meet specific objectives (i.e.,
managed to achieve resource benefits).
Rangeland - Land on which the historic climax plant community is predominantly grasses, grasslike plants, forbs, or shrubs. Includes lands re-vegetated naturally or artificially when
routine management of that vegetation is accomplished mainly through manipulation of
ecological principles. Rangeland includes natural grasslands, savannas, shrublands, most
deserts, tundra, alpine communities, coastal marshes and wet meadows (Natural
Resources Conservation Service National Range and Pasture Handbook, 1997.)
Regional Planning Organization - An organization that will first evaluate technical information
on regional haze and related issues to better understand how their states and tribes impact
national park and wilderness areas (Federal Class I areas) across the country. The
organization will then pursue the development of regional strategies to reduce emissions
of particulate matter and other pollutants leading to regional haze. The five Regional
Planning Organizations that receive funding from EPA to address regional haze and
related issues are: Central States Regional Air Partnership (CENRAP) for the central
states, Midwest Regional Planning Organization for the mid-western states, Ozone
Transport Commission (OTC) for the northeastern states, Southeast States Air Resource
Managers (SESARM) for the southeastern states, and Western Regional Air Partnership
(WRAP) for the western states.
Rule - Regional Haze Rule. Regulations published in the Federal Register on July 1, 1999 (64 FR
35714) that require states to establish goals for improving visibility and to develop longterm strategies for reducing emissions of pollutants that cause visibility impairment.
Silviculture - The theory and practice of controlling forest establishment, composition, and
growth. The art of producing and tending a forest.
SIP - State Implementation Plan. Plans devised by states to carry out their responsibilities under
the Clean Air Act. SIPs must be approved by the U.S. Environmental Protection Agency
and include public review.
Smoke Effects* - The effects on visibility (both plume blight and regional haze), public
nuisance, and the health-based NAAQS due to emissions from fire.
* Operating Definitions from Section 1.1 of the WRAP FEJF Workplan dated February 25, 1999.
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Smoke Management Program (SMP) - The objectives of a basic or enhanced smoke management
program are to ensure: 1) no health-based NAAQS are exceeded; 2) nuisance smoke is
mitigated; and 3) smoke impacts on visibility are minimized in Class I areas and meet the
Grand Canyon Visibility Transport Commission Recommendations.
TIP - Tribal Implementation Plan. Plans devised by tribes to carry out their responsibilities under
the Clean Air Act. TIPs must be approved by the U.S. Environmental Protection Agency
and include public review.
Vegetative Residue Disposal - Burning of land management related fuel or vegetation that is the
by-product of a commercial operation. (E.g., Burning of wheat stubble, orchard prunings,
orchard or vineyard removals, leftover Christmas trees, timber slash or landing residues.)
Weed/Pest/Disease Management - Burning with the pre- and post-harvest objective of reducing
and/or eliminating competing weeds or other non-target vegetation during a standard crop
rotation. Burning with the pre- and post-harvest objective of controlling and/or reducing
the incidence of pests and disease impacting a crop. (E.g., Weed – goat crass, star thistle
control, cheatgrass, dodder; Pest – hessian fly, lygus bugs, weevils; Disease –
cepholosporium stripe rust, fire blight, tristeza virus.)
Wildfire* - Any unwanted, non-structural fire.
Wildland* - An area where development is generally limited to roads, railroads, power lines, and
widely scattered structures. The land is not cultivated (i.e., the soil is disturbed less
frequently than once in 10 years), is not fallow, and is not in the USDA Conservation
Reserve Program (CRP). The land may be neglected altogether or managed for such
purposes as wood or forage production, wildlife, recreation, wetlands, or protective plant
cover (EPA Interim Air Quality Policy on Wildlands and Prescribed Fires). The land is
not “agricultural land” as operationally defined above. Silvicultural land and rangelands
(per the FEJF charge), woodlots, and private timberlands will be included with wildlands
for the purposes of the FEJF work.
Wildland Fire - All types of fire (see definition of fire above), except fire on agricultural land.
Wildland Fire Managed for Resource Benefits/Prescribed Natural Fire* - These terms both have
current use in regulations and policies. They are considered to be synonymous and are
used interchangeably in this workplan. These terms refer to the management of naturally
ignited fires to accomplish specific, pre-stated resource management objectives in
predefined geographic areas outlined in the fire management plan.
WRAP region - The WRAP region includes 247 tribes and the states of Arizona, California,
Colorado, Idaho, Montana, North Dakota, New Mexico, Oregon, South Dakota, Utah,
Washington, and Wyoming.
* Operating Definitions from Section 1.1 of the WRAP FEJF Workplan dated February 25, 1999.
Draft August 14, 2001
23
WRAP - Western Regional Air Partnership. The WRAP is a collaborative effort of tribal
governments, state governments and Federal agencies to promote and monitor
implementation of Recommendations from the Grand Canyon Visibility Transport
Commission. The WRAP may also address other common western regional air quality
issues as raised by its membership. The activities of the WRAP are conducted by a
network of committees and forums, composed of WRAP members and stakeholders who
represent a wide range of social, cultural, economic, geographic and technical
viewpoints. The WRAP members include the governors of twelve western states (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, Jicarilla Apache 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. The National
Tribal Environmental Council and the Western Governors’ Association administer the
WRAP.
Yield Improvement - Burning that improves growing conditions for subsequent crops (i.e., by
adding nutrients or available water to the soil) or burning that stimulates new growth.
(E.g., Field burning on seed production fields.)
Draft August 14, 2001
24
APPENDIX B.
RECOMMENDATION FOR THE FLAGGING OF VISIBILITY
DATA AFFECTED BY WILDFIRES UNDER SUPPRESSION
The potential is high for significant visibility impacts from episodic wildfires under suppression,
classified as “natural”, as demonstrated by recent wildfire seasons (i.e., 1996 and 2000).
Significant visibility impacts may be caused by an individual unwanted wildfire event that can
last for months at a time, and may be compounded when combined with impacts from other
unwanted wildfire events across the landscape.
The emissions and subsequent visibility effects of wildfire are highly variable both spatially and
temporally. Wildfire activity can range dramatically from year to year in the same state, as
demonstrated in Wyoming where approximately 1.5 million acres were burned by wildfire in
198841 and less than 9 thousand acres were burned in 199342. Further support of this variability,
which will dramatically affect visibility, can be found in Graph B-1 that depicts the high, low,
and median values of acres burned by wildfire for the respective year.
Depending on the frequency and magnitude of the unwanted wildfire events, the calculated
baseline, current, and natural background visibility conditions may not represent an accurate
portrayal of the visibility conditions at a given Federal Class I area in the WRAP region.
Stakeholders have expressed concern that the visibility improvements resulting from emissions
reduction programs for industrial, mobile, and other anthropogenic sources may be masked by
visibility impacts from wildfires under suppression. Concomitantly, the demonstration of
reasonable progress may be dominated by visibility impacts to the natural background condition
from these unwanted wildfires.
“The contribution from fires can be substantial over short-term periods, but fires occur
relatively infrequently and thus have a lower contribution to long-term averages….than
sources for which emissions are more continuous.”43
Unwanted wildfire events that occur relatively infrequently may have a lower contribution to
long-term averages, such as baseline and current conditions. However, if unwanted wildfire
events have a significant contribution to visibility impacts for three of the five years used to
calculate the baseline conditions, the baseline conditions portrayed would be artificially high.
This also holds true if unwanted wildfire events occur at a greater frequency and magnitude
during the five years utilized to establish current conditions, against which, states are required to
demonstrate reasonable progress toward the 2064 natural conditions goal. Thus, the frequency
and magnitude of unwanted wildfires has a potential to conceal visibility improvements from
other source types, particularly for the 20 percent most-impaired days.
41 USDA – Forest Service, Fire and Aviation Management, 1984 – 1990 Wildland Fire Statistics, January 1992.
42 USDA – Forest Service, Fire and Aviation Management, 1991 – 1997 Wildland Fire Statistics, September 1998.
43 64 FR 35736.
Draft August 14, 2001
25
Based on the variability and the magnitude of wildfire emissions, the FEJF recommends that in
conjunction with the AMRF, a workgroup be formed to study the effects from unwanted wildfire
events on the establishment of baseline, current, and natural background visibility conditions, as
well as on the demonstration of reasonable progress. The development of an approach similar to
the Natural Events Policy44 for wildfires under suppression should be considered by the
aforementioned workgroup, to ensure that visibility improvements from other source types are
not masked by visibility impacts from unwanted wildfire events.
Graph B-1. Wildfire Variability – Acres Burned per Year45
Variance in Wildland Acres Burned for Western States
(1984 - 1997)
1,600,000
1,537,302
(1988)
Median
1,400,000
1,200,000
Acres
1,000,000
840,399
(1987)
800,000
740,161
(1996)
600,000
820,400
(1985)
658,714
(1988)
553,110
(1996)
390,431
(1994)
400,000
200,000
0
307,675
(1994)
251,555
(1995)
15,203
(1997)
AZ
42,354
(1991)
CA
7,275
(1992)
CO
184,477
(1985)
137,758
(1988)
104,966
(1996)
4,958
(1993)
ID
8,701
(1987)
MT
4,480
(1995)
ND
37,307
(1984)
NM
32,280
(1997)
NV
12,688
(1993)
OR
4,979
(1986)
SD
6,271
(1995)
WA
8,911
(1993)
WY
44 The monitored data for visibility could be flagged using an approach parallel to the Natural Events Policy for
flagging and exempting monitored data exceeding the particulate matter health standard caused by a natural event.
The flagged IMPROVE data could potentially be exempted from the calculation of baseline, current and natural
background visibility conditions, as well as the determination of reasonable progress. This could occur when the
data monitored by the IMPROVE network appears to have a significant effect (e.g., => 1 deciview) from wildfires
under suppression.
45 USDA – Forest Service, Fire and Aviation Management, 1984 – 1990 Wildland Fire Statistics, January 1992.
USDA – Forest Service, Fire and Aviation Management, 1991 – 1997 Wildland Fire Statistics, September 1998.
Draft August 14, 2001
26
APPENDIX C.
WEBSITE REFERENCES
This appendix is intended to provide readers with several website addresses that were used to
locate supporting information for the development of this Policy.
— Western Regional Air Partnership (WRAP) website
(http://www.wrapair.org)
— WRAP Fire Emissions Joint Forum (FEJF) website
(http://www.airsci.com/splprj.htm)
— U.S. Environmental Protection Agency’s Visibility Improvement Program website
(http://www.epa.gov/oar/vis)
— Agricultural Air Quality Task Force website
(http://www.nhq.nrcs.usda.gov/faca/aaqtf.html)
— National Fire Plan, Interagency website
(http://www.fireplan.gov)
— GCVTC Recommendations for Improving Western Vistas, June 10, 1996
(http://www.nmia.com/gcvtc)
(http://www.wrapair.org) Click on the GCVTC link
The report was used as the basis for developing Section 51.309 of the Regional Haze Rule.
— Regional Haze Rule, 40 CFR Part 51, July 1, 1999
(http://www.epa.gov/ttn/oarpg/t1/fr_notices/rhfedreg.pdf)
— The EPA Interim Air Quality Policy on Wildland and Prescribed Burning, April 23, 1998
(http://www.epa.gov/ttn/oarpg/t1/memoranda/firefnl.pdf)
This document describes the components of a state/tribal basic smoke management program.
— White Papers associated with the Interim Policy:
(http://www.westar.org/projects_fp.html)
1. Background on the Role of Fire
2. What Wildland Fire Conditions Minimize Emissions and Hazardous Air Pollutants and
Can Land Management Goals Still Be Met?
3. Air Monitoring for Wildland Fire Operations
4. Emissions Inventories for SIP Development
5. Estimating Natural Emissions from Wildland and Prescribed Fire
— The EPA Natural Events Policy for Particulate Matter, June 6, 1996
(http://www.epa.gov/ttn/caaa/t1/memoranda/nepol.pdf)
This document outlines how states should address “natural events” that produce high levels
of particulate matter.
Draft August 14, 2001
27
— Agricultural Air Quality Task Force
Air Quality Policy on Agricultural Burning, November 10, 1999
(http://www.nhq.nrcs.usda.gov/faca/Policies/Burning%20Policy.htm)
Production Agriculture Voluntary (Incentive Based) Air Quality Compliance Program,
November 10, 1999
(http://www.nhq.nrcs.usda.gov/faca/Policies/Voluntary.htm)
FR Vol. 65, No. 181, September 18, 2000 (56308-56310).
(http://www.epa.gov/fedrgstr/EPA-AIR/2000/September/Day-18/a23948.htm)
The task force recommendations and public comment will be used by the EPA to develop a
policy for agricultural burning.
— A Collaborative Approach for Reducing Wildland Fire Risks to Communities and the
Environment, 10-Year Comprehensive Strategy
(http://www.westgov.org/wga/initiatives/fire/)
— EPA Prescribed Burning Background Document and Technical Information Document for
Prescribed Burning Best Available Control measures, EPA-450/2-92-003, September, 1992
(http://www.epa.gov/ttncaaa1/t1bid.html)
This document provides RACM and BACM for prescribed burning (includes measures for
agricultural burning).
Draft August 14, 2001
28
COMMENTS RECEIVED ON
RECOMMENDED POLICY FOR CATEGORIZING FIRE EMISSIONS
The following comments were received via e-mail on the Recommended Policy for Categorizing Fire
Emissions, Draft August 14, 2001. Comments were received from the following FEJF Members: Diane
Riley, State Representative - ID DEQ; Scott Kuehn, Wood Product Industry Representative – Plum Creek
Timber Co.; John Veranth, Environmental Representative – Dept. of Chemical & Fuels Engineering
University of UT; and Frances Bernards State Representative – UT DEQ. Comments were also received
from the following FEJF Outer Circle Participants: Bill Grantham, National Tribal Environmental
Council; Rose Lee, Yakama Nation; Robert Saunders, WA DEQ; and Brian Finneran, OR DEQ.
John Veranth, – rcvd 8/27/01 2:11 PM by PL via e-mail
I read the draft policy dated Aug 14 and am comfortable with the
recommendations. The application of "Natural" to maintain an ecosystem that is
currently in an ecologically functional and fire resilient condition is a
reasonable position. However, I think the phrase should include the word
"wildland."
Revised wording: "Prescribed fire is an anthropogenic source, except where it
is utilized to maintain a wildland ecosystem that is currently in an
ecologically functional and fire resilient condition, in which case it is
classified as a natural source."
A minor concern is on Page 18.
The sentence in the first paragraph "These
burns will not be tracked .... " took a bit of time to figure out the
antecendent of "These" because several types of burns are discussed earlier
in the paragraph.
I think the intent was "Traditional, religious, and
ceremonial burns will not be tracked or considered in the establishment of
either natural background conditions or toward the reasonable progress ..."
Bill Grantham, NTEC – rcvd 8/28/01 2:33 PM by DJP via e-mail
Dear Tribal members of the FEJF,
As today is the deadline, I'm submitting my
Classification Policy to you for your consideration.
comments
on
the
Fire
Before getting into specifics about the wording of the report, I have a basic
substantive comment, which is that I'm concerned that the consideration of
"economic" factors may remove the teeth from the requirement to control
emissions to the maximum extent feasible.
I suppose though that this
represents the consensus of the group and can't be changed. Perhaps it could
be clarified. Does "economic" refer just to the costs of controlling natural
fires (helicopters, firefighters, etc), or does it include costs and benefits
of allowing the fire to burn? I think that air quality considerations should
not be subordinate to the economic interest of some parties in allowing
anthropogenic fires to burn (e.g., to create opportunites for "salvage"
logging).
Another somewhat general comment is that it would help me to have more
elaboration on the purpose of the policy, especially with respect to the
determination of natural background conditions. I can understand how
classifying fires as they happen helps you look back over a time period and
determine how much of the visibility degradation due to fire during that
period should be counted as natural and how much as anthropogenic, and thereby
determine if you are making reasonable progress in the anthropogenic realm.
But how do you know how much "natural" fire there would be in the "natural"
state of things, and will this classification scheme help answer that? (The
IV-35
document says the categorization will "facilitate the establishment of natural
background conditions" (p7) -- could this be elaborated upon?
Now for more specific, wordsmithing type comment:
Native American Cultural Burning
p.18, paragraph 1:
"Individual tribes and/or tribal councils may identify
these purposes of burning by resolution, rule, or ordinance. . . etc." -- The
meaning of "these purposes" is not clear.
The previous sentence refers to
non-vegative burning for various ceramonial purposes.
The sentence before
that
refers
to
vegatative
burning
for
ceremonial/traditional/cultural
purposes.
I assume that the sentence about tribal resolutions etc. is
referring to vegative burning (because the policy does not apply in the first
place to non-vegetative), but this is not at all clear.
Also, I think references to "and/or tribal
Simply use the term "tribe" as synonomous with
form it may take for a particular tribe. What
context? (One would not say "the state and/or
council" should be eliminated.
the tribal government, whatever
else could "tribe" mean in this
the state government").
Finally, the last sentence, providing the rationale for this policy, is rather
vague ("stakeholder recognition of certain traditions").
What about the
traditions did they recognize? That the traditions were a form of ecosystem
maintenance? Or just that tribal burning is "natural" because it was part of
the pre-european scene. Perhaps this needs to be glossed over due to lack of
consensus on the rationale, but I think if there was agreement on the
reasoning that should be better articulated.
Also, the term "stakeholders"
may present perception problems here. I believe you mean all the participants
in the process -- tribal, state, federal, private -- but many tribes are
sensitive to being considered mere "stakeholders" (on par with enviro and
industry groups), rather than governments, let alone being subject to the
consideration of stakeholders.
I would just strike the word.
Other comments
a.. Should add definitions of "manage" and "control" to discussion preceding
2.1, where "natural" and "anthropogenic" are defined. The definitions emerge
later but it would help the reader better understand the "classification
program management" statements better. Also, the definitions could use more
elaboration -- e.g., the term "other emissions reduction techniques" appears
several times, including in the definition in appendix -- examples of these
techniques would be helpful.
b.. "Classification Program Management" is an awkward and un-informative
term.
It is really fire (or smoke) that is being managed, right?, not a
"classification program." Perhaps "Management of Classified Fires"?
c.. Generally, the rationale for each classification should be stated more
actively (as opposed to passively) and at the beginning of the annotation for
each classification, not the end. For example, re Presribed Fire, begin with
"Prescribed Fire (other than for ecosystem maintenance) is classified as
'anthropogenic' because [reasons],"
rather than introducing the reasons at
the end of the discussion in a passive voice ("Key to the categorization . . .
is the recognition . . . etc). Otherwise the definitions seem circular and
the reasons like post-hoc rationalizations.
d.. The discussions of prescribed fire and native american cultural burning
both state that "the fire is classified as natural, which recognizes that
these fires have the opportunity for smoke management." This seems a little
misleading, as it implies that the anthro classification does not recognize
the opportunity for management, when in fact the anthro designation recognizes
not only the opportunity for management, but also control (a stricter
standard). At a minimum, perhaps you could insert "still" before recognizes,
or give fuller explanation, such as "the fire is classified as natural, which
recognizes that although control of emissions may not be appropriate, these
fires do present the opportunity for smoke management.
IV-36
e.. WRAP membership, p.24: strike Jicarilla Apache and add Nez Perce Tribe.
Thanks for your consideration,
Bill Grantham
Frances Bernards, UT – rcvd 8/29/01 2:06 PM by DJP via e-mail
Darla and Pete:
I cannot participate in the conference call this Thursday, but I do have some
comments that I wanted to pass on to you.
Since Pete has been away and is probably swamped with phone messages and
emails (!), I thought it would be a good idea to pass my comments on to Darla
as well.
I have received comments from other state regulatory staff on how maintenance
burning is defined in the Policy and I also have some concerns on this subject
as well. As you know, the Policy states that prescribed fires are classified
as a "natural" source if the fire is utilized to maintain an ecosystem that is
currently in an ecologically functional and fire resilient condition.
The
Policy also recognizes that the science of determining a fully functional and
fire resilient ecosystem is continually evolving. And that the Policy will be
updated to accommodate future study results.
The concern with this current approach centers on the fact that the Policy
does not elaborate on the size of a maintenance burns or the emission
potential of a maintenance burn.
Obviously, the burn characteristics will
vary depending on the ecosystems. But, generally, these type of burns tend to
be lit by hand and often do not produce a significant convective smoke plume
which results in poor smoke dispersion. Since these burns will be considered
"natural", they are not subject to Enhanced Smoke Management Program
requirements or controlled through the establishment of annual emissions
goals.
Do we know how these types of burns will be "managed" to minimize
visibility impacts?
More information is also necessary on how this Policy will be updated to
accomodate "future changes in the understanding and subsequent determination
of the broad range of ecosystems." The Policy does refer to the National Fire
Plan as an example of an assessment tool, but additional information should be
provided in the Policy on what is meant by an "ecologically functional and
fire resilient condition."
Thanks for your time and efforts on this challenging issue. I appreciate the
opportunity to provide comments on the task team's efforts thus far.
Diane Riley, ID – rcvd 8/29/01 4:33 PM by DJP via e-mail
Mike,
I have a number of comments on the draft nb policy.
I believe the WRAP region includes AK, HI, and NV too (footnote #5, page 1).
I voiced my opinion that the "Classification Program Management" should not
be included in this policy in Rapid City because it goes beyond
classification. I think these are troublesome and do not add to the document.
In any event, I think the "Classification Program Management" is awkward
terminology.
IV-37
The phrases "Wildfires managed for resource objectives "and "wildfires managed
for resource benefits" are used in many places (Page 8 - Classification
Criteria letter B, page 13 - 2nd paragraph, page 15 – sect 3.2.2 (statement),
page 16 - 1st paragraph under "Managed for Resource Objectives", page 20 Ecosystem Restoration definition). This is very confusing terminology since
wildfire is defined as "Any unwanted, non-structural fire." I think what is
meant is "wildland fire managed for resouce benefits."
It would make more
sense if this is included under Classification Criteria letter A where
prescribed fires are discussed rather than letter B.
(comment in larger font) Anthropogenic Emissions Source Classification
("anthropogenic") - A categorization that designates which fire emissions
contribute to visibility impairment in a Federal Class I area. "Anthropogenic"
emissions must be controlled to achieve progress toward the 2064 natural
conditions goal for each Federal Class I area in the WRAP region and any
downwind Federal Class I areas in non-WRAP region states. This classification
includes natural and human-caused ignitions.
The following two sections only apply to states choosing to comply with
section 309 of the regional haze rule. Since this document should be written
so all can understand, this needs to be explained.
Page 11
"The [implementation] plan must provide for: (v) Establishment of annual
emission goals for fire, excluding wildfire, that will minimize emission
increases from fire to the maximum extent feasible and that are established in
cooperation with States, tribes, Federal land management agencies, and private
entities."
The control of these anthropogenic sources to ensure visibility goals are
attained will be accomplished by the establishment of annual emissions goals
and, if applicable, by using an Enhanced Smoke Management Program (ESMP), as
stated in the Regional Haze Rule. The FEJF is developing recommendations for
the WRAP for the ESMP and how an annual emissions goal may be created.
page 12
"The [implementation] plan must provide for: (ii) A statewide inventory and
emission tracking system (spatial and temporal) of VOC, NOx, elemental and
organic carbon, and fire particle emissions from fire*."
page 11- last paragraph indicates "these programs and techniques are futher
supported by the regional haze rule. Where?
I would like to suggest that implementation guidance be developed to ensure
state-to-state and agency-to-agency determination of when a piece of land is
in the "maintenance" state.
page 17 - "Escaped Prescribed Fire" section.
This is new and was not
discussed at the Rapid City meeting. It is not consistent with the Interim
Air Quality Policy on Wildland and Prescribed Fires. Page 25-26 of the policy
states "However, any resulting high PM concentrations [from an escaped
prescribed fire] must continue to be addressed under this policy, ..." ie, not
the natural events policy. The natural events policy only includes lightning
ignited fires and not escaped prescribed fires.
I have double checked this
with Ken Woodard who wrote the interim policy.
He agrees this section is
problematic. Has this section been reviewd by the EPA? I don't think it can
be implemented as written and we don't want to wait until we submit SIPs to
find this out.
Diane
IV-38
Scott Kuehn, Plum Creek Timber – rcvd 8/29/01 4:55 PM by DJP via e-mail
Note: Comments were submitted as additional text in a copy of the Recommended Policy for
Categorizing Fire Emissions. The additional text has been extracted and is reprinted below.
Page 8, Section 2.1., Bullet A.
There used to be a statement that all fires classified as Natural must go through a Smoke Management
Plan. What happened to this? The fact that all emissions had to go through a SMP was the balance
between Natural and Anthropogenic and somewhat neutralized the “Get out of jail free card.”
Page 8, Section 2.2., Bullet C.
As stated before, we do not agree that this type of burning should be classified as Natural! Historic, Yes,
Natural NO.
nd
rd
Page 12, Section 3.2., 2 paragraph, after 3 sentence
Does this mean that all emissions (Natural and Anthropogenic) go through a SMP? I think it should be
stated that, “All emissions, regardless of classification are will be part of a Smoke Management Program.”
Page 13, Footnote 31
I would also like to see a wildland example of Maintenance.
Page 14, Section 3.2.1., Ecosystem Maintenance, after last sentence in last paragraph
Will Air Quality Regulators really know when an ecosystem is in Restoration or Maintenance? I doubt it.
If left up to the prescribed burner, what safeguard is there that after only one restoration burn, a manager
can call all subsequent burns Natural?
Page 14, Footnote 32
I strongly disagree with the use of any lands “tagged” through the Fire Plan assessment be used to
determine if an ecosystem is in need of restoration or in maintenance. This was a broad macro scale
study and to allow land managers use this as a method of labeling certain ecosystems as in “need of
restoration” (Anthropogenic) or “in Maintenance” (Natural) is a big mistake.
Page 15, Footnote 36
The removal of “Pine Needles” is an important part of fuel reduction, though pine needles are not
generally considered “ladder fuels.”
st
st
Page 15, Section 3.2.2., Suppressed by Management Action, 1 paragraph, 1 sentence
This example might not mean anything to the general reader. Maybe the Oakland Hills fire might be a
better example.
nd
Page 17, Section 3.2.2., Escaped Prescribed Fire, after last sentence in 2 paragraph
We agreed at the last meeting that all fires would retain their original purpose (label) even if they
escaped. This is not what this paragraph says.
Page 17, Section 3.2.3, after Statement
Again, we are opposed to this type of fire being considered natural. Historic yes, natural, no.
Page 18, Section 3.2.3., after last sentence in last paragraph
There is no safeguard that a Tribal Council could deem all of their lands “Traditional” and thus all burning
(possibly including all prescribed burning) on tribal land would be labeled as natural.
Throughout entire document
??? after the word “unwanted”
IV-39
Page 19, Appendix A., after 2064 Natural Conditions Goal
This definition is going to cause LOTS of confusion. If the goal is to mimic by 2064 what conditions would
have been like without “human-caused emissions” than how can Native American burning be deemed
natural? Natural to me means “in the absence of any human influence.”
Page 23, Appendix A., after Wildfire*
An “unwanted” fire is defined as a Wildfire.
document.
The term “Unwanted Wildfire” is used throughout the
Rose Lee, Yakama Nation – Input re: Bill Grantham’s comments - rcvd 8/30/01 5:26 PM by DJP
via e-mail
Great comments Bill!
As I explained to you earlier I haven't had the opportunity to fully read the
Fire Classification Policy document, but I did quickly review the parts that
are directly related to tribes. At this point, the only additional comment
that I have relates to paragraph 2 on page 18. The first sentence reads, "A
natural classification may be assigned to a Native American cultural burn when
the person(s) or entity that initiates the vegetative burn determines, with
oversight by the applicable air quality regulatory authority, that the fire
has been established by the tribe or tribal council for a traditional,
religious, or ceremonial purpose."
When I first read this sentence I paused because it seemed like the tribes
were some how subjugated to state or local regulatory authority. Although, I'm
pretty sure that the NBTT was trying to use oversight by the applicable air
quality regulatory authority as a catch all for BIA, EPA, tribes, or other
entities that manage air quality on Reservations. I'm not sure how to rewrite
this sentence to avoid giving the impression that tribes may be subjugated to
state/local authority.
I do believe that it is important that any burn classified as Native American
Cultural Burning be approved by the tribe or the tribal program responsible
for air quality management. Even if BIA or EPA made the classification they
would still have to consult with the tribe.
Robert Sauders, WA – fwd by Diane Riley - rcvd 8/30/01 2:03 PM by DJP via e-mail
Diane,
Stu Clark and I looked at the draft fairly quickly and we offer these
comments.
The general thrust of the classification scheme is OK.
Mostly
these comments clarify what is being said.
Also, I believe this draft responds to Oregon comments in May that said it
should focus more narrowly on classification and not go as deeply into the
management implications of classifications and it appears to do this.
It
does, appropriately, indicate that all fire should be managed, but it retains
a distinction about emission reduction goals for anthropongenic fires but not
for natural or "maintenance" prescribed fires. Oregon and ourselves argued in
May that they should both be evaluated against the same standard (smoke
management + emission minimization).
It may be that in practice natural
maintenance burning may have less options and would be less likely to have
alternatives to burning, but the concept of evaluating the options against the
same standard should be retained. Comment 4 addresses this point.
IV-40
One of the reasons we took this position was statements by the fire experts
that indicated that even in a maintenance burn, if you pay attention to the
level of moisture and maybe other factors, a maintenance burn might produce
less emissions if done under optimum conditions for cleaner burning. Holding
the maintenance burns to a emission minimization standard would drive those
kinds of considerations.
Please do what you can with these comments. Given the short time frame I have
not checked with Oregon and I hope I haven't misstated their positions.
Comments on Draft FEJF Document:
1) Page 4: Section 1.2.1: Last sentence of last paragraph before the
subheading Wildlands:
Add to the end of the sentence: " as long as the effects on regional haze are
offset overtime by reductions in other sectors and the improved use of nonburning or lower emission alternatives."
The concern here is that the original statement implies that all increased
emissions from prescribed burning can occur without consequences under the
regional haze rule.
2) Page 6: Section 1.2.2: Agricultural Land: 1st paragraph, last sentence:
The AAQFT quote says that "for some crops it is the only economical means
available to deal with residue". WA. has extensive experience with many forms
of agricultural burning where this claim has been made and proven untrue. The
true statement is that burning is the least costly but not the
only economically viable option. I recommend that the quote be dropped and
replaced by an acknowledgement that the AAQTF recognized that burning is still
an important, widely used and low cost residue management tool.
3) Page 7: Section 1.2.2: Natural Background: 2nd paragraph, last line:
Replace the word "fire" with "wildfire". The paragraph talks about natural
sources and gives some examples. We don't want to imply the all fire might be
considered natural.
4) Page 10: Section 2: Classification Policy: Definition of natural emissions:
Add a new second sentence that reads: "Natural emission sources must be
managed to minimize visibility impacts and the frequency of their occurrence."
This adds a statement about level of control to make it parallel the
anthropogenic definition and is consistent with the following discussion under
Section 2.1
5) Page 10: Section 2.2: Classification Criteria:
Add a new subcategory D or insert into subcategory A statement that reads:
"All agricultural related burning is considered prescribed burning." Purpose
is to clarify where agricultural burning fits in the classification scheme.
st
6) Page 16: Section 3.2.2: Wildfire: 1st paragraph after Statement, 1
sentence:
Strike the words "intentional fire (i.e. arson)" and replace them with
"arson".
All prescribed fires are intentional fires. To avoid any misunderstanding just
use the specific word, arson.
IV-41
Diane Riley, ID – Input re: Robert Saunders comments – rcvd 8/30/01 3:20 PM by DJP via e-mail
Pete and Darla,
Since these 6 comments from OR have come in after the conference call today, I
am forwarding them to you and the others on the conference call today.
My
two cents on the comments are below.
I think #4 is worthy of further
discussion.
I have to agree with Robert's comments #1, #4, and #6 comments, especially #4,
but I am not sure #4 totally addresses the issue. Robert mentions that the
policy retains the distinction of annual emission goals for anthropogenic
sources (this appears on page 11, 2nd to last paragraph). I made the comment
today that it should be made clear that this only applies to states complying
with section 309.
But I have thought further on this point.
In section
309(6)(v), it reads "Establishment of annual emission goals for fire,
excluding wildfire, that will minimize emission increases from fire to the
maximum extent feasible..."
There is not a distinction of natural or
anthropogenic emissions here. However, the policy does not address emission
goals for natural emissions, only anthropogenic emissions. I don't think the
#4 comment totally addresses this gap.
Comment #2 would replace something taken directly out of the AAQTF
recommendations. I am not sure if that is needed or appropriate. Maybe an
additional sentence can be added about WA's experience???
I don't think comment #5 would get consensus, I think there has been a lot of
discussion on this topic and it has been addressed as much as possible.
I am not sure about comment #3, don't know if it would cause any problems to
make the change or not.
Thanks, Diane
Diane Riley, ID – Input re: Robert Saunders comments – rcvd 9/3/01 2:06 PM by DJP via e-mail
My apologies. Brian Finneran pointed out that I said these comments were from
OR when they were actually from WA! Thanks (Brian), Diane
Brian Finneran, OR – originally submitted to Diane Riley & Frances Bernards 8/21/01 - rcvd 9/4/01
1:10 PM by DJP via e-mail
1) The revised Policy defines Maintenance Burning as using fire in a "fully
functional and fire resilient ecosystem". It says this burning will be
considered "natural" and applied when the FLM determines "the fire is in an
area identified as being in an ecologically functional and fire resilient
condition" (pg. 14).
*
Question 1:
does this mean the FLM can subjectively determine what
represents Maintenance Burning? My interpretation is yes, since from what I
can tell there is no specific definition of what is an ecologically functional
and fire resilient forest.
*
Question 2:
does this mean that what is commonly referred to as
Understory Burning will be considered Maintenance Burning? My interpretation
is yes, since the reason I hear to justify understory burning is "to maintain
healthy forests". Right now there are major increases in understory burning
occurring throughout the West.
Most of the burning in Oregon is now
understory.
I see the possibility for all this burning to be ultimately
called "natural" and exempt (like wildfire) from the reasonable progress
requirements of the RHR. Does that raise any concern to you?
2) The Policy says that all man-made burning will be "managed" under a SMP,
including Maintenance Burning.
IV-42
*
Question 3: Assuming Understory burning = Maintenance burning, if major
increases in understory burning occur, is it realistic to think that even an
enhanced SMP will be able to will prevent regional haze problems? While
understory burning produces less emissions than traditional PF, it typically
generates considerable low level ground smoke and haze, that is difficult to
"manage".
Brian Finneran, OR – originally submitted to Pete Lahm 8/24/01 - rcvd 9/4/01 1:10 PM by DJP via
e-mail
1) The revised Policy defines Maintenance Burning as using fire in a "fully
functional and fire resilient ecosystem". It says this burning will be
considered "natural" and applied when the FLM determines "the fire is in an
area identified as being in an ecologically functional and fire resilient
condition" (pg. 14). (It should be noted that the Policy acknowledges there
is no definition of what is an ecologically functional and fire resilient
forest.)
*
Question 1: does this mean that only the FLM determines what represents
Maintenance Burning? What input will the states have in this determination?
My interpretation is none - this will be the FLM's call on a case by case
basis.
*
Question 2:
does this mean that what is now commonly referred to as
Understory Burning can be considered Maintenance Burning? My interpretation
is yes, since the justification for understory burning seems to be "to
maintain healthy forests". Right now there are major increases in understory
burning occurring throughout the West. Most of the burning in most parts of
Oregon is now understory. I see the possibility for all this burning to be
called "natural" and exempt (like wildfire) from the reasonable progress
requirements of the RHR. This is a big concern to us.
2) The Policy says that all man-made burning will be "managed" under a SMP,
including Maintenance Burning.
*
Question 3:
regardless of whether understory burning = maintenance
burning, shouldn't there be some discussion in the Policy about some limits on
the amount of maintenance burning. Saying this burning will be "managed" is
only half the answer (and a questionable one at that, given Q#4 below). We
feel strongly there has to be some limits, or ability to cap at some level.
*
Question 4: Assuming major increases in understory burning I mention in
Question 2, is it realistic that an Enhanced SMP would be able to will prevent
regional haze problems? Wouldn't large-scale understory burning produce such
widespread, low level ground smoke and haze that "managing" it, or controlling
where the smoke goes, would be near impossible?
IV-43
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IV-44
FEJF CONFERENCE CALL
August 30, 2001
9 – 11 am Mountain (8 - 10 am Pacific)
Topic: Recommended Policy for Categorizing Fire Emissions, Draft August 14, 2001
PARTICIPANTS
FEJF Members: Pete Lahm, FEJF Co-Chair - USDA Forest Service; John Veranth,
Environmental Representative – Dept. of Chemical & Fuels Engineering University of UT; John
Kennedy (until 10:10 am MTN), Federal Representative – USEPA Region IX; Pat Shaver
(joined call late ~ 9:40 am MTN), Federal Representative – USDA NRCS; Diane Riley, State
Representative – ID DEQ; Jim Lawrence, State Representative – Council of Western State
Foresters; Kevin McKernan, Tribal Representative – Yurok Tribal Environmental Program;
Scott Kuehn, Wood Product Industry Representative – Plum Creek Timber Co.; Dave Jones
(joined call late ~ 10:10 am MTN), Local Government Representative – San Joaquin Valley
APCD.
FEJF Alternate-Member: Larry Biland, USEPA Region IX
Non-FEJF Member: Darla Potter, NBTT Co-Chair – WY DEQ (NBTT Co-Chair participated to
answer questions and provide clarification to the FEJF Members during the conference call.)
Note: During the conference call, Frances Bernards’ comments (State Representative – UT
DEQ) were represented by Diane Riley.
COMMENTS RECEIVED
The comments received via e-mail on the Recommended Policy for Categorizing Fire Emissions,
Draft August 14, 2001 are compiled in a separate document. Both the conference call notes and
comments will be included in a report titled “Supporting Documentation for the Recommended
Policy for Categorizing Fire Emissions” being developed by the NBTT.
DISCUSSION
[Ed. Note: The discussion notes that follow indicate the person speaking and then their
comments as recorded during the conference call.]
Introductions & Introductory Remarks
Pete L. - Darla and Pete will take formal notes.
- Silence will be considered assent to the Policy, as stated in the conference call notice.
- E-mail notice for the conference call included the WRAP consensus definition.
Gauging of Consensus
Pete L. – I want to gauge how close/far we are from consensus regarding moving the
Recommended Policy forward. Considering the lowest level of consensus as “can you live with
the Policy as is” I am looking for substantive issues that make you say, “I cannot live with the
Policy as is”.
IV-45
Scott K. – I have a hard time with Native American cultural burning being part of the “natural”
classification but I’m not going to hold up the document due to that. I would just like my
objection noted.
John K. – I have one substantive comment to resolve before I can get to consensus. Classifying
escaped prescribed fire as a wildfire under suppression and subject to the Natural Events Policy
is not consistent with EPA’s Interim Air Quality Policy on Wildland and Prescribed Fires.
Diane R. – I want to note that the Classification Program Management should not be in the
Policy, but I can live with the document. I believe that the Recommended Policy would get a lot
more acceptance if that section (i.e., Classification Program Management) was not included as
the Recommended Policy moves forward.
John V. – Native American cultural burning classification as “natural” is OK for religious and
ceremonial burns because the intent is clear and the magnitude is small. However, traditional
burning could be about anything and should be tracked toward reasonable progress. I can live
with intent of document as is but I would like some additional tightening for what is included
with traditional.
Kevin M. – Traditional burning is determined by each tribe, so it is hard to “define” in a
document such as this. I have some editorial comments raised by Bill Grantham of NTEC,
however we can live with the current document.
John V. – In maintenance prescribed fire, is there a loophole for agricultural production to
misuse this classification using the terminology “ecologically functional and fire resilient
condition”? Is there any way to tighten the definition? I can live with the intent of document as
is, but am looking for some additional tightening so that agricultural burning is not in
maintenance prescribed fire.
Scott K. – I would support a good definition of “maintenance,” especially with regard to using
the condition classes to establish the classification. I also support what John V. said about
tightening this up.
Discussion of the one substantive comment to address before getting to consensus.
Escaped Prescribed Fire, page 17
John K. – Page 17, 2nd paragraph, last sentence & 3rd paragraph
“Therefore, an escaped prescribed fire will be treated as a wildfire under
suppression and classified according to the same criteria (i.e., as “natural”).
The classification of an escaped prescribed fire as a wildfire under suppression is
consistent with EPA’s Natural Events Policy. Under the Natural Events Policy,
high particulate matter concentrations attributable to unwanted wildfires can be
treated as due to a natural event.”
IV-46
John K. - I appreciate the rationale, but treating escaped prescribed fire as suggested is wholly
inconsistent with EPA’s internal policy. In discussions with headquarters, it was suggested to
treat escaped prescribed fire according to its original classification instead. See Interim Air
Quality Policy on Wildland and Prescribed Fires, Page 25/26, VIII, A., 2., Fires Managed for
Resource Benefits, 3rd paragraph, last 2 sentences. Basically escaped prescribed fires cannot be
treated as a wildfire natural event
Pete L. – The term wildland fire includes fires managed for resource benefits other than
prescribed fire. Per the definitions used in the Interim Policy, this section does not apply to
“prescribed fire”.
Darla P. – Explanation of language in Natural Events Policy (page 6).
Diane R. – The intent of this section in the Interim Policy is to include both “wildland fire
managed for resource benefits” and “prescribed fire”.
John K. – Fires managed for resource benefits does include prescribed fire. We also need to look
at the dates of the policies (Interim Policy – 1998, Natural Events Policy – 1996). The Natural
Events Policy is actually a state Policy where the wildfire itself led to the violation. EPA doesn’t
actually approve a state’s natural events action plan. If the state doesn’t follow the Policy, then
EPA would not support the data flagging.
Darla P. – What about Cerro Grande, was it considered a “Natural Event” upon escape?
Diane R. – I suggest a formal EPA review of this section before can move forward
John V. – The whole purpose of this document is to contribute to the goal of achieving
reasonable progress. We need to consider what can actually be controlled. If we have good faith
that land managers will not let prescribed fires escape intentionally, I don’t see a big difference
between escaped prescribed fire and human-caused wildfire under suppression.
John K - I am willing to have more dialogue with headquarters on this, but I still see a conflict
with the Interim Policy.
Pete L. – I propose in the Recommended Policy to reiterate that the treatment of escaped
prescribed fire under this classification is only for addressing visibility (similar to the statement
in the beginning of the Recommended Policy).
Diane R. – That would be good.
John K. – That will not take care of our concern.
Pete L. – I have another suggestion based on previous deliberations. Keep the 1st paragraph; add
a 2nd paragraph to state that the EPA policy addresses these situations (Interim Policy) and that
states and tribes must take that policy into account in determining the classification for escaped
prescribed fire. Remove the last 2 paragraphs in this section.
IV-47
Scott K. – Is there a conflict with EPA’s Interim Policy in Appendix B as well?
Note: Darla P. and Pete L. as well as other conference call participants reviewed Appendix B to
make sure that it was not in conflict with the Natural Events Policy.
Pete L. – The terminology used in Appendix B is unwanted wildfire or wildfire under
suppression. Therefore, there is no conflict.
John V. – Can we leave the middle paragraph except for the last sentence?
John K. – The 2nd paragraph is OK until last portion of last sentence that reads “…and classified
according to the same criteria.”
Jim L. – Treatment of an escaped prescribed fire as a wildfire under suppression is what is being
done on the ground.
All OK - Keep the 1st paragraph and 2nd paragraph until the last sentence. Delete from the last
sentence the following phrase: “…and classified according to the same criteria.” Delete the last
paragraph in this section and insert a new 3rd paragraph to state that EPA policy addresses these
situations (Interim Policy).
Pete L. – I want to re-survey for substantive consensus items from those that joined the call
late… As no additional items were brought up, the Recommended Policy for Categorizing Fire
Emissions has achieved consensus approval by the FEJF. Now let’s move on to other editorial
changes that people would like to see made to the Recommended Policy.
Discussion of Other Changes
[Ed. Note: The discussion of other changes is formatted with each major point being aligned on
the left margin. When a major point was discussed, the discussion is indented underneath the
major point.]
Pat S. – I have a question about why the 1st quote on page 10 does not include wildfire in the
parenthetical statement.
“All types of fire (prescribed fire and agricultural burning) must be addressed
equitably as part of the visibility protection strategy.”
Pete L. – That is a quote and cannot be changed, see footnote 23 on page 10.
Pat S. – Page 15, Wildfire Suppressed by Management Action, 1st paragraph, 1st sentence “and/or
natural resources”. That kind of wildfire may be in conflict with discussions of fire as being an
integral part of the ecosystem, etc. If damage to natural resources is the sole reason for the fire,
the ecosystem out-of whack, and if prescribed fire it would be anthropogenic not natural. Please
delete “and/or natural resources” from that sentence.
Pete L. – “Natural resources” may be a T&E species.
IV-48
Jim L. – It may also represent watershed aspects. I would like to see it kept in.
Darla P. – What about footnoting examples of natural resources?
Pat S. – I will need to take something back to my folks that commented on this. Human
value is not an ecological value.
Jim L. – Suggested Resolution - Strike “natural” but leave “resources.”
All – OK
Larry B. – Are there plans to include an Executive Summary at the beginning?
Jim L. – I also suggest an Executive Summary be included.
Diane R. – It sounds like a good idea.
All – Yes, add an Executive Summary. Larry B. & Jim L. will e-mail suggestions for the
Executive Summary to Darla.
Larry B. – In Appendix B, it should be written in that EPA be the lead in the workgroup with
assistance from the WRAP.
Pete L. – How can WRAP direct EPA to take action? I don’t think this is possible.
Diane R. – How about suggesting EPA take a prominent role?
Pete L. – Suggested Resolution – Add the words “with involvement of EPA” in
Appendix B.
All - OK
Kevin M. – I support all of Bill Grantham’s comments that Darla received a copy of.
Darla P. – Yes, I did receive Bill Grantham’s comments.
Pete L. – We’ll review those comments and take them into consideration.
Kevin M. - One of Bill Grantham’s comments echoes Diane’s concern regarding the
Classification Program Management title.
"Classification Program Management" is an awkward and un-informative term.
It is really fire (or smoke) that is being managed, right?, not a "classification
program." Perhaps "Management of Classified Fires"?
IV-49
Pete L. – The NBTT Management & Content Team struggled with this wording. Bill’s
suggestion really doesn’t include all of the aspects being addressed, as Classification
Program Management is more than just the management of fires. Therefore, the
document will continue to use the term Classification Program Management.
Kevin M. - Bill Grantham’s substantive comment is in regard to more specificity on economics.
I have a basic substantive comment, which is that I'm concerned that the
consideration of "economic" factors may remove the teeth from the requirement
to control emissions to the maximum extent feasible. I suppose though that this
represents the consensus of the group and can't be changed. Perhaps it could be
clarified. Does "economic" refer just to the costs of controlling natural fires
(helicopters, firefighters, etc), or does it include costs and benefits of allowing the
fire to burn? I think that air quality considerations should not be subordinate to
the economic interest of some parties in allowing anthropogenic fires to burn
(e.g., to create opportunites for "salvage" logging).
Pete L. – The GCVTC and RHR do not contain guidance to this degree of specificity.
The FEJF will be developing guidance and will take this comment into consideration.
[Ed. Note: The NBTT has included the concern regarding the scope of economic factors
in the Task List to the FEJF, under the task for the development of feasibility guidance.]
Pete L. – Regarding one of Bill Grantham’s comments, is it OK to just use “tribe” and strike
“tribal council”?
I think references to "and/or tribal council" should be eliminated. Simply use the
term "tribe" as synonomous with the tribal government, whatever form it may take
for a particular tribe. What else could "tribe" mean in this context? (One would
not say "the state and/or the state government").
Kevin M. – The use of “tribal government” instead of “tribe and/or tribal council” would
be OK.
All - OK
Kevin M. – I have a problem with the last paragraph in the Native American Cultural Burning
Section, particularly the wording “oversight by the applicable air quality regulatory authority”.
This is OK if the tribe has regulatory authority, but if not, this is a problem. A clarifying sentence
is needed that it is possible that the tribes may be the regulatory authority. It also needs to
reiterate that the tribe has primacy to determine the classification.
Darla P. – What if we change the word “oversight”?
John V. – If the process is codified into SIPs/TIPs, EPA can over-file the plan submitted
so there is de facto EPA oversight.
IV-50
Kevin M. – Suggested Resolution - Change language to “designated tribal air quality
authority or EPA”.
All - OK
Scott K. – “Unwanted wildfire” is a redundant term.
Pete L. – There was a concern of members of the NBTT Management and Content Team,
so that is why it is written that way.
Scott K. – It doesn’t create a problem and can be left as is.
All – OK, leave as is.
Scott K. – page 15, footnote 36 – “Pine needles” are not ladder fuels. “Tall brush” could be used
instead.
Pete L. – How about stating undergrowth as well as pine needs by changing the
ordering?
Scott K. – OK
All - OK
Scott K. – I thought that all emissions were to be under some type of Smoke Management
Program. The Recommended Policy states that they will be managed but not how, in a
BSMP/ESMP?
Pete L. – The exact mechanism has yet to be determined.
Scott K. – To prevent the “get out of jail free” card, under those times that they can be
managed they should be part of a SMP.
Pete L. – There is nothing in the document that limits the regulatory agency from using
an SMP. Your concern will be reviewed, but we don’t know where/if it will be stated in
the document as that could limit state/tribal flexibility.
[Ed. Note: The annotated sections of the Recommended Policy were reviewed under
Classification Program Management in consideration of the above concern. As a result
of that review and in consideration of the discussion noted above, no changes were made
to the Recommended Policy.]
Scott K. – When and where will maintenance burning occur? See footnote 35.
Pete L. – Would an additional example help? If so, would you be willing to write it?
IV-51
Scott K. – I don’t know.
Pete L. – It is recognized that prescribed fire is highly dependent on the ecosystem and
there may have to be multiple applications of fire to get to ecosystem maintenance.
Diane R. – Frances and I suggest the development of implementation guidance for
determining when land is in the maintenance state.
Pete L. – Consistency will be difficult even within a given state. That is why the
document is written as is.
Diane R. – What about establishing a process instead of specifics? What about areas
without an established fire regime?
John V. – The science is evolving and this is what makes it hard to be very specific.
Diane R. – How are states to provide oversight without some guidance?
John V. – Could the fire return interval be used to evaluate this?
Pat S. – This is site specific and there will be a problem with coming up with any, even
“general”, guidance.
Pete L. – The NBTT can pass this on to the ESMP Task Team to discuss and consider
developing some guidance for determining when land is in the maintenance state.
Nothing will be added in the Policy.
All - OK
Diane R. – The term “wildfires managed for resource benefits or objectives” is confusing.
Darla P. – We have had stakeholder input regarding the use of this fire type on lands
other than Federal wildlands. Hence, the term “wildfires managed for resource
objectives”.
Diane R. – Could you use “fire managed for resource benefit” instead of “wildfire
managed…”?
Darla P. – Your concern will be reviewed, and we’ll take the suggested wording into
consideration.
[Ed. Note: The term “wildfire managed for resource objectives” and an associated
definition were added to the glossary in Appendix A to alleviate the apparent confusion.]
Diane R. – In the Anthropogenic Emissions Source Classification, page 19, add “and any
downwind Federal Class I areas in non-WRAP region states.”
IV-52
Pete L. – I am worried about stepping on another Regional Planning Organization’s
terrain with our definitions. Your concern will be reviewed, but we don’t know if the
language will be changed in the document.
[Ed. Note: In consideration of the discussion noted above, no changes were made to the
Recommended Policy.]
Diane R. – On page 11 & 12 there are some quotes from Section 309. You need to insert
statements that those apply to only 309 states.
Darla P. – The footnote already specifies that those are from Section 309.
Diane R. - Perhaps state that they “apply only to Transport Region States” in the footnote
for the quote as well.
Pete L. – We’ll take adding some wording to the footnote into consideration when
revising the Recommended Policy.
[Ed. Note: In consideration of the discussion noted above, the titles of §51.308 and
§51.309 were added to every footnote referencing §51.308 or §51.309 of the Regional
Haze Rule.]
Pat S. - Page 14, footnote 35 is not a good example.
Pat S. – Change to “Periodic burning to improve forage quality on rangelands for
livestock or wildlife.”
All - OK
Diane R. – Page 11, “programs and techniques” what and where does that come out of Regional
Haze Rule?
Pete L. – We’ll look at that and see if it can be clarified.
[Ed. Note: In consideration of the discussion noted above, a footnote was added
referencing §51.308(d)(3)(v)(E) and §51.309(d)(6) of the Regional Haze Rule.]
Pete L. – Does anyone else have any other concerns or changes that need to be made?
Dave J. – My concerns, which I expressed as part of the NBTT Management & Content
Team, have been taken care of.
IV-53
NEXT STEPS
Pete L. - Darla and Pete will make changes this afternoon to the Recommended Policy.
- The revised version of the Recommended Policy will be forwarded on to IOC/TOC.
- Pete and Darla will be making the presentation to the IOC/TOC on September 5, 2001
for the Recommended Policy.
- The Recommended Policy will go forward marked that it has consensus approval from
the FEJF.
Darla P. - There will be an update on the IOC/TOC meeting at the September 27/28 FEJF
meeting in Park City. Decommissioning of the NBTT will take place at that meeting as well.
IV-54
Recommended Policy Approval Process
FEJF Submission to IOC/TOC - August 30, 2001
Recommended Policy for Categorizing Fire Emissions, August 30, 2001
IV-55
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IV-56
RECOMMENDED POLICY FOR
CATEGORIZING FIRE EMISSIONS
APPROVED BY CONSENSUS:
FIRE EMISSIONS JOINT FORUM - AUGUST 30, 2001
PREPARED BY:
NATURAL BACKGROUND TASK TEAM OF THE FIRE EMISSIONS JOINT FORUM
AUGUST 30, 2001
IV-57
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IV-58
TABLE OF CONTENTS
Page
1.
2.
3.
4.
INTRODUCTION
1
1.1.
Background
1
1.2.
Context
1.2.1. Current Condition and Future Fire Emissions
1.2.2. Natural Background Conditions
1.2.3. The Classification of Fire
2
2
4
5
1.3.
Purpose
6
1.4.
Scope and Applicability
6
CLASSIFICATION POLICY
7
2.1.
Classification Program Management
8
2.2.
Classification Criteria
8
CLASSIFICATION POLICY ANNOTATION
9
3.1.
Classification Program Management
3.1.1. Management to Minimize Visibility Impacts
3.1.2. Control Emissions from “Anthropogenic” Sources
3.1.3. Tracking Fire Emissions
9
10
11
12
3.2.
Classification Criteria
3.2.1. Prescribed Fire
3.2.2. Wildfire
3.2.3. Native American Cultural Burning
12
13
15
18
APPENDICES
19
Appendix A. Glossary
19
Appendix B. Recommendation for the Flagging of Visibility Data
Affected by Wildfires Under Suppression
25
Appendix C. Website References
27
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IV-60
1. INTRODUCTION
1.1.
BACKGROUND
In 1990, Congress amended the Clean Air Act, and as part of these amendments created the
Grand Canyon Visibility Transport Commission1 (GCVTC). The GCVTC was charged with
assessing the current scientific information on visibility impacts and making recommendations
for addressing regional haze in the western United States. The GCVTC signed and submitted
more than 70 Recommendations to the Environmental Protection Agency (EPA) in a report dated
June 1996 that indicated that visibility impairment was caused by a wide variety of sources and
pollutants, and that a comprehensive strategy was needed to remedy regional haze.
The Western Regional Air Partnership (WRAP) was established in 1997 as the successor
organization to the GCVTC. The WRAP is a voluntary organization comprised of western
governors, tribal leaders and Federal agencies,2 and is charged with implementing the GCVTC
Recommendations, as well as addressing broader air quality issues, such as the Regional Haze
Rule (Rule). The WRAP is designed as a stakeholder-based organization, which uses consensus
for development of policy and technical tools. WRAP participants include state air quality
agencies, tribes, Federal/state/private land managers, the EPA, environmental groups, industry,
academia and other interested parties.
Following the issuance of the GCVTC Recommendations, the EPA issued the Regional Haze
Rule3 in July 1999 to improve visibility in 156 national parks and wilderness areas across the
country. The Rule outlines the requirements for states and tribes to address regional haze in
Federal Class I areas. EPA incorporated all of the GCVTC Recommendations into Section 309
of the Rule, which may be used by some of the WRAP states. The remaining WRAP states must
utilize the nationally applicable Section 308 provisions of the Rule.
“The State must identify all anthropogenic sources of visibility impairment considered by
the State in developing its long-term strategy. The State should consider major and minor
stationary sources, mobile sources, and area sources.”4
EPA recognizes the WRAP as the Regional Planning Organization that is developing the
necessary policy and technical tools to implement the Regional Haze Rule in the WRAP region5.
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 InterTribal Fish Commission, and the Environmental Protection Agency.
2 The WRAP members include the governors of twelve western states (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, Jicarilla Apache 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.
3 Published in the Federal Register on July 1, 1999 (64 FR 35714).
4 64 FR 35767, Regional haze program requirements §51.308(d)(3)(iv).
5 The states of AZ, CA, CO, ID, MT, ND, NM, OR, SD, UT, WA, WY and 247 tribes.
August 30, 2001
1
1.2.
CONTEXT
1.2.1. Current Condition and Future Fire Emissions
The GCVTC recognized fire (wildfire, prescribed fire and agricultural burning) as playing a
major role in ecosystem health in the West, and at the same time, contributing to regional haze.
“Emissions from fire (wildfire and prescribed fire) are an important contributor to
visibility-impairing aerosols,…Agricultural burning emissions and their effects have
[also] been identified as a concern of the GCVTC…”6
Throughout the WRAP region, fire is occurring as part of the natural landscape. Prescribed fire
is used for a wide variety of purposes on both wildlands and agricultural land in the region. In
addition, fire has been an integral part of tribal communities in their practice of religion and
traditional cultural activities. Tribal communities also utilize prescribed fire on wildlands and for
agricultural purposes.
All sources of fire can have an effect on air quality and visibility. Although there is uncertainty
as to the amount and apportionment of emissions from these sources vis-à-vis regional haze, it is
agreed that fire and its emissions contribute to regional haze.
The use of fire, as well as alternative treatments, is intended to provide more effective fire
suppression, predictable fire effects and management of air pollutant emissions.
“Prescribed fire promotes better fire control, predictable fire effects and allows for
management of emissions as compared to wildfire.”7
Despite the use of alternative treatments, it is recognized that prescribed fire use and resulting
emissions will increase on Federal, state, tribal and private land. These emissions will contribute
to regional haze. However, it is anticipated that the implementation of the Regional Haze Rule
can accommodate the increased use of fire on wildlands as well as the maintenance and
opportunity for continued use of fire in agricultural management.
Wildland
The GCVTC Recommendations indicated that wildfire and prescribed fire emissions could
potentially overwhelm the visibility effects of all other sources on an episodic basis, due to the
unnatural condition of vegetative fuel build-up, projected increased use of prescribed fire and the
current likelihood of catastrophic wildfire. This is true across all land ownership types.
6 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”), page 47.
7 GCVTC Report, page 47.
August 30, 2001
2
“In fact, land managers propose aggressive prescribed fire programs aimed at correcting
the buildup of biomass due to decades of suppression. Therefore, prescribed fire and
wildfire levels are projected to increase significantly during the studied period [19952040]. The Commission recommends the implementation of programs to minimize
emissions and visibility impacts from prescribed fire, as well as to educate the public.”8
EPA’s Interim Air Quality Policy on Wildland and Prescribed Fires was “…prepared in
response to plans by some Federal, Tribal and State wildland owners/managers to significantly
increase the use of wildland and prescribed fires to achieve resource benefits in the wildlands.”9
Under the EPA Policy, it was acknowledged that “Many wildland ecosystems are considered to
be unhealthy as a result of past management strategies…. Wildland owners/managers plan to
significantly increase their use of fires to correct these unhealthy conditions and to reduce the
risk of wildfires to public and firefighter safety.”10
Recognition of the current ecological state of the wildlands and increased wildfire severity has
led to the development of the National Fire Plan, which has begun to be addressed through recent
Federal appropriations11. It represents a long-term commitment based on cooperation and
communication among Federal agencies, states, local governments, tribes, and concerned
publics. The Federal wildland fire management agencies have worked in close consultation with
states, governors, and interested partners to prepare a collaborative ten-year strategy12 for
implementation of the National Fire Plan.
This ten-year strategy is predicated on a commitment to the reduction of hazardous fuel loads,
with current priority in the urban-interface area. Addressing the wildland fire and hazardous fuels
situation, as well as the needs to restore and maintain forest and rangeland ecosystem health and
to ensure human safety, will necessitate a range of fuel management options. The fuel
management options include mechanical, chemical, biological, and prescribed fire treatments.
The GCVTC emphasized the need for alternatives to fire in order to address regional haze
concerns and equity among the many sources of visibility impairment. The Preamble to the Rule
cites the GCVTC Recommendation of “full consideration of alternatives to fire.”13
8 GCVTC Report, page iii.
9 U.S. EPA, Office of Air Quality Planning and Standards, Interim Air Quality Policy on Wildland and Prescribed
Fires, April 23, 1998, page 1.
10 U.S. EPA, Office of Air Quality Planning and Standards, Interim Air Quality Policy on Wildland and Prescribed
Fires, April 23, 1998, page 1.
11 2001 Interior and Related Agencies Appropriations Act (Public Law 106-291), Making Appropriations for the
Department of Interior and related agencies for the fiscal year ending September 30, 2001, and for other purposes.
12 A Collaborative Approach for Reducing Wildland Fire Risks to Communities and the Environment, 10-Year
Comprehensive Strategy, August 2001.
13 64 FR 35736.
August 30, 2001
3
Agricultural Land
The Air Quality Policy on Agricultural Burning prepared by the Agricultural Air Quality Task
Force (AAQTF) asserts that “Fire has been an integral part of agricultural management as long
as man has systematically grown crops. Modern technologically based agriculture still utilizes
burning and for some crops it is the only economical means available to deal with residue.”14
Agricultural burning is utilized for a variety of purposes, the most common of which is to reduce
pre- and post-harvest vegetation that interferes with harvest, tillage or subsequent seedbed
preparation. Burning is also used for pest and weed control, as well as to reduce fire hazard from
weed infestation and clogging of ditches and irrigation canals. Tribal communities also utilize
fire for agricultural management, including weed abatement and ditch and canal clearing.
“The burning of vegetative matter associated with agricultural land management
produces a range of particulate emissions and ozone precursors. Therefore, it has the
potential to impact visibility in mandatory Class I Federal areas.”15
One of the goals of the AAQTF Policy is “to protect public health and welfare by mitigating the
impacts of air pollution emissions on air quality and visibility.”16 Toward this end, the AAQTF
Policy encourages alternatives to burning, as well as “…identifying burning methods and
determining alternative treatment strategies that can effectively reduce emissions….”17
The use of fire by agriculture is well documented. However, the extent of the fire use is not well
known in some areas, and is the cause of uncertainty as to the contribution of agricultural
burning sources on regional haze. Accordingly, the AAQTF Policy states that “…the
contribution from agriculture, specifically the impact of burning practices on regional air quality,
must be accurately assessed in relative proportion to the region’s total emissions.”18
Acknowledging this uncertainty, both the GCVTC and the Rule include agricultural burning as a
contributor to regional haze that needs to be addressed.
1.2.2. Natural Background Conditions
The Regional Haze Rule outlines the requirements for addressing regional haze in Federal Class
I park and wilderness areas, a critical element of which is the establishment of natural
background condition values. When established, these values will provide the basis by which a
state or tribe may demonstrate reasonable progress toward attaining the 2064 natural conditions
goal, as required in the Rule under both Sections 308 and 309.
There are a number of sources that EPA has identified as potential contributors to natural
background conditions, one of which is fire. The determination of natural background conditions
14 Agricultural Air Quality Task Force, Air Quality Policy on Agricultural Burning, Recommendation to the U.S.
Department of Agriculture, November 10, 1999 (hereafter “AAQTF Air Quality Policy on Agricultural Burning”),
Section IV, A.
15 AAQTF Air Quality Policy on Agricultural Burning, Section IV, E.
16 AAQTF Air Quality Policy on Agricultural Burning, Section II.
17 AAQTF Air Quality Policy on Agricultural Burning, Section VI, B, 2.
18 AAQTF Air Quality Policy on Agricultural Burning, Section VII.
August 30, 2001
4
may take into account impacts from potential natural sources of visibility impairing pollutants
such as natural vegetative hydrocarbon emissions (e.g., terpines from trees), oceanic sulfates,
natural wind suspended dust, fire, and sulfate and nitrate from volcanoes.
Due to climatic variations that affect the role of fire on the landscape, natural background
conditions are anticipated to fluctuate. The use of tree ring analysis has scientifically
demonstrated this phenomenon. For example, an increase of fire scars is indicative of higher fire
occurrence during times of drought. To this end, climatic changes will have a direct effect on the
variability of natural background conditions as influenced by fire.
The Regional Haze Rule Preamble stipulates that fire of all kinds contributes to regional haze
and that fire can have both natural and human-caused sources. The Preamble further states that
some fire that is human ignited may be included in a state’s or tribe’s determination of natural
background conditions.
“EPA believes that States [and Tribes] must take into account the degree to which fire
emissions cause or contribute to ‘manmade’ visibility impairment and its contribution to
natural background conditions.”19
To address the implementation of specific sections of the Rule, the WRAP has established
several committees and forums. The Ambient Air Monitoring & Reporting Forum (AMRF) is
working to develop guidance on the determination of natural background, taking into
consideration emissions that can result in a natural reduction of visibility. The Fire Emissions
Joint Forum (FEJF) is addressing both policy and technical issues concerning smoke effects that
are caused by wildland and agricultural fire on public, tribal and private lands.
The AMRF will analyze the Interagency Monitoring of Protected Visual Environments
(IMPROVE) visibility monitoring data to establish a baseline, current conditions, and track
reasonable progress toward the 2064 natural conditions goal, as required in the Rule. Organic
carbon aerosol, as monitored by IMPROVE, is a significant contributor to regional haze in the
WRAP region. The current monitoring technology is unable to identify the source of organic
carbon aerosol monitored at Federal Class I areas, of which fire has been acknowledged as a
major source. As technology and science develops, with regard to the ability to differentiate fire
impacts as compared to other sources for the purposes of tracking reasonable progress toward the
2064 natural conditions goal, the needs and methods of tracking are anticipated to change.
1.2.3. The Classification of Fire
Due to the limitations of the current monitoring technology, the AMRF requested that the FEJF
work on determining the classification of fire emissions as either “natural” or “anthropogenic”.
This classification will be an important component for fire’s inclusion in natural background
condition values and ultimately, the tracking of reasonable progress. The Natural Background
Task Team (NBTT) was created by the FEJF to assist in this effort.
19 64 FR 35735.
August 30, 2001
5
This Policy was developed through a broad, multi-stakeholder-based public review process that
included two workshops designed to gather both technical and policy input. The review process
included direct input from the FEJF, WRAP, and other parties. The NBTT has submitted
progress reports as well as work products to the FEJF for input and approval. The Policy is a
work product of the FEJF for the WRAP.
1.3.
PURPOSE
“The EPA also recognizes that fire of all kinds (wildfire, prescribed fire, etc.) contributes
to regional haze, and that there is a complex relationship between what is considered a
natural source of fire versus a human-caused source of fire.”20
This Policy, developed under the WRAP, will aid states and tribes in determining which fire
emissions will be considered as part of the natural background conditions in Federal Class I
areas. The remaining fire emissions will be considered “anthropogenic” and, as such, subject to
reasonable progress requirements of the Rule. This Policy clarifies the relationship between what
would be defined as a “natural” fire emissions source and what would be defined as an
“anthropogenic” fire emissions source, thereby addressing the complex relationship EPA
acknowledges in the Preamble to the Rule.
Under this Policy, fire emissions sources are, for the most part, classified as “anthropogenic”.
These sources will be controlled to the maximum extent feasible, which is in keeping with the
Rule’s primary objective of the development of long-term strategies for reducing emissions of
visibility impairing pollutants. Additionally, the “anthropogenic” classification recognizes that
there is potential to control the emissions from most fires, as acknowledged in the GCVTC
Recommendations, the Regional Haze Rule, and the stakeholder participation process.
Some fire emissions sources have been classified as “natural”, and, like “anthropogenic” sources,
will be managed to minimize potential air quality impacts. The rationale for “natural”
classifications is clearly stated in the annotated sections, and reflects the reasoning of the
GCVTC, the Rule, stakeholder input, as well as current smoke management capabilities.
Furthermore, both the management of “natural” source emissions, and the management and
control of “anthropogenic” source emissions represent key points of convergence among
stakeholders that are fundamental to the development of this Policy.
1.4.
SCOPE AND APPLICABILITY
This Policy exclusively addresses the effects of fire emissions in terms of visibility and the
requirements of the Regional Haze Rule. It does not address potential natural sources of
visibility reducing pollutants such as natural vegetative hydrocarbon emissions (e.g., terpines
from trees), oceanic sulfates, natural wind suspended dust, and sulfate and nitrate from
volcanoes. Air pollutant emissions from fires may also impact public health and cause nuisance
smoke intrusions. This Policy may strengthen processes and current systems in place that
address these smoke concerns; however, this specific interaction is being addressed through
further recommendations by the FEJF.
20 64 FR 35735.
August 30, 2001
6
“All types of fire (prescribed fire and agricultural burning) must be addressed equitably
as part of a visibility protection strategy.”21
This Policy applies to both wildland and agricultural lands regardless of ownership (i.e., Federal,
state, tribal, public, private), cause of ignition (e.g., lightning, arson, accidental human, land
management practices) or purpose of the fire (e.g., vegetative residue disposal, hazard reduction,
maintain ecosystem health). It is the intent that this Policy be applied equitably across all land
types and sources.
This Policy does not apply to other open burning activities on residential, commercial, or
industrial property (e.g., backyard burning, garbage incineration, residential wood combustion,
construction debris). This Policy does not apply to Native American cultural non-vegetative
burning for traditional, religious or ceremonial purposes (e.g., cremation, sweat lodge fires).
This Policy applies to impacts on Federal Class I areas in the WRAP region. Emissions from all
fire (wildland and agricultural) are to be accounted for in both Sections 308 and 309 of the Rule.
Stakeholder input advocated a consistent consideration of fire utilizing either Section 308 or 309
of the Rule. This input was a guiding principle for the development of this Policy. States and
tribes in the WRAP region are anticipated to incorporate this Policy into the technical support
documentation for a State or Tribal Implementation Plan (SIP/TIP) submitted to EPA in order to
meet the requirements of the Rule.
The categorization of fire emissions, as established by the Policy, will facilitate the establishment
of natural background condition values and ultimately, the tracking of reasonable progress for a
SIP or TIP. As the SIPs/TIPs will be revisited and revised, per the schedule specified in the
Rule, there will be opportunities to refine this Policy to reflect scientific advances and/or policy
changes.
2. CLASSIFICATION POLICY
The Classification Policy is made up of six statements, three of which address the program
management of classification, and three that address the criteria for the classification of fire
emission sources. The Classification Criteria statements of the Policy determine the “natural”
and “anthropogenic” sources of fire that contribute to regional haze, as stated in the Preamble to
the Rule. The Classification Program Management statements express the requirements that
enable classification to be effective and equitable. The Program Management statements adhere
to the findings and Recommendations of the GCVTC related to fire and fire emissions, as well as
the reasoning expressed in the Rule.
The Classification Program Management statements express requirements that need to exist but
do not attempt to describe how they will be brought about (e.g., the development of requirements
for a tracking system or smoke management program). That work is currently underway in the
FEJF as well as other WRAP Forums.
21 GCVTC Report, page 47.
August 30, 2001
7
The classification of fire emissions is predicated on the distinction between a “natural” emissions
source classification and an “anthropogenic” emissions source classification, the definitions of
which follow.
Natural Emissions Source Classification (“natural”) - A categorization that designates
which fire emissions can result in a natural reduction of visibility for each Federal Class I
area in the WRAP region. This classification includes natural and human-caused
ignitions.
Anthropogenic Emissions Source Classification (“anthropogenic”) - A categorization that
designates which fire emissions contribute to visibility impairment in a Federal Class I
area. “Anthropogenic” emissions must be controlled to achieve progress toward the 2064
natural conditions goal for each Federal Class I area in the WRAP region. This
classification includes natural and human-caused ignitions.
The following Classification Program Management and Classification Criteria statements apply
to both wildland and agricultural lands regardless of ownership, cause of ignition, or purpose of
the fire within the WRAP region.
2.1.
CLASSIFICATION PROGRAM MANAGEMENT
D. All fires must be managed to minimize visibility impacts.
E. All emissions from fires classified as an “anthropogenic” source will be controlled to the
maximum extent feasible subject to economic, safety, technical and environmental
considerations.
F. Emissions from all fire will be tracked.
2.2.
CLASSIFICATION CRITERIA
D. Prescribed Fire is an “anthropogenic” source, except where it is utilized to maintain an
ecosystem that is currently in an ecologically functional and fire resilient condition, in which
case it is classified as a “natural” source.
E. Wildfire that is suppressed by management action is a “natural” source. Wildfire, when
suppression is limited for safety, economic, or resource limitations, remains a “natural”
source. Wildfires managed for resource objectives are classified the same as prescribed fires.
F. Native American cultural burning for traditional, religious, and ceremonial purposes is a
“natural” source.
August 30, 2001
8
3. CLASSIFICATION POLICY ANNOTATION
3.1.
CLASSIFICATION PROGRAM MANAGEMENT
The following sections provide clarifying and supporting information regarding each of the three
Classification Program Management statements from Section 2 above. The three Program
Management statements apply to both wildland and agricultural lands regardless of ownership,
cause of ignition, or purpose of the fire within the WRAP region.
The Classification Program Management statements express the management elements that
enable classification of fire emissions sources to be effective and equitable. The Program
Management statements adhere to the findings and Recommendations of the GCVTC related to
fire and fire emissions, as well as to the reasoning expressed in the Rule.
The Rule requires that states, “…must consider, at a minimum, the following factors in
developing its long-term strategy: (E) Smoke management techniques for agricultural and
forestry management purposes including plans as currently exist within the State for these
purposes;”22
However, there are currently vast differences in smoke management programs, use of emissions
reduction practices, and approaches to addressing the visibility effects of fire across the WRAP
region. These differences may include state legislative requirements or those of tribal
government that exist in the implementation of some of the program management elements.
Generally, most current smoke management programs address only public health and nuisance
concerns, and do not address all the potential visibility-impacting fire emissions sources, nor do
they have procedures to address minimization of visibility impacts.
In recognition of this, the FEJF is working to insure that the policy and program management
recommendations that the Forum develops are implemented through the WRAP in a progressive
manner. The first step for implementation of this Policy is to develop emissions tracking,
followed by the management of fires for the minimization of visibility impacts, and then
followed by potential implementation of Enhanced Smoke Management Programs (ESMP). The
timeframe for implementation of this Policy will be affected by a state’s or tribe’s current
approach to address smoke effects.
22 64 FR 35767, Regional haze program requirements §51.308(d)(3)(v)(E).
August 30, 2001
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3.1.1. Management to Minimize Visibility Impacts
Statement: All fires must be managed to minimize visibility impacts.
“All types of fire (prescribed fire and agricultural burning) must be addressed equitably
as part of the visibility protection strategy.”23
“The [implementation] plan must provide for: (i) 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….”24
This policy statement addresses the pressing need that all fires, regardless of subsequent
classification as “natural” or “anthropogenic”, must be managed to minimize their impacts on
visibility in Federal Class I areas, in addition to public health and nuisance concerns. This
concept is recognized in both the GCVTC Recommendations and in the Regional Haze Rule.
This policy statement was also supported by both stakeholder input and by the WRAP as critical
to achieving equity among fire emissions sources and other types of air pollution sources.
Some stakeholders, however, did express concern that air quality considerations would prove
difficult to apply to wildfires under suppression, since they are managed with firefighter and
public safety and protection of property and resources as primary criteria for strategic decisionmaking. It should be noted that consideration of air quality is already required on Federal lands25
during the evaluation of alternate fire management strategies and, under this Policy, will need to
be considered regardless of land ownership. However, air quality considerations are just one of
several important criteria that are weighed according to positive, neutral, or negative effects and
evaluated to select the appropriate management response to the wildfire.
It should be emphasized that the ability to control the emissions from wildfires under suppression
can be limited. Therefore, these emissions cannot be incorporated into the demonstration of
reasonable progress toward the 2064 natural conditions goal, and as a result, are classified as
“natural”.
Management of all fire emissions to minimize visibility impacts must include, but is not limited
to, concepts such as the timing of ignitions for better dispersion and consideration of downwind
air quality and visibility. It may also include the use of best management practices, such as the
use of alternatives, biomass utilization, and other emission reduction techniques. Responsibility
for the utilization of fire emissions management techniques resides with the person(s) or entity
that initiates a fire or manages the land where fire occurs. Due to economic, safety, technical and
environmental considerations, the use of some of the management techniques may not be
feasible. The FEJF is developing recommendations for managing fire emissions sources with the
goal of minimizing visibility impacts.
23 GCVTC Report, page 47.
24 64 FR 35771, Requirements related to the Grand Canyon Visibility Transport Commission §51.309(d)(6)(i).
25 Wildland Fire Situation Analysis (WFSA).
August 30, 2001
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3.1.2. Control Emissions from “Anthropogenic” Sources
Statement: All emissions from fires classified as an “anthropogenic” source will be
controlled to the maximum extent feasible, subject to economic, safety, technical and
environmental considerations.
The Anthropogenic Emissions Source Classification is a categorization that designates which fire
emissions may contribute to visibility impairment and therefore, must demonstrate reasonable
progress toward the 2064 natural conditions goal for each Federal Class I area in the WRAP
Region. This classification includes natural and human-caused ignitions.
The “anthropogenic” classification recognizes the fact that there is potential for most fires to
have emission controls (e.g., use of alternatives or emission reduction practices), in addition to
being managed to minimize visibility impacts as discussed above. Per the GCVTC
Recommendations, economic, safety, technical and environmental considerations are part of the
application of emission controls for the implementation of this Policy statement. Due to these
considerations, the control of emissions from some fire types may not be feasible, which will be
determined by the land manager in collaboration with the applicable air quality regulatory
authority. The FEJF is developing guidance for feasibility (i.e., economic, safety, technical and
environmental considerations) determinations.
“The [implementation] plan must provide for: (v) Establishment of annual emission goals
for fire, excluding wildfire, that will minimize emission increases from fire to the
maximum extent feasible and that are established in cooperation with States, tribes,
Federal land management agencies, and private entities.”26
The control of these anthropogenic sources to ensure visibility goals are attained will be
accomplished by the establishment of annual emissions goals and, if applicable, by using an
Enhanced Smoke Management Program (ESMP), as stated in the Regional Haze Rule. The FEJF
is developing recommendations for the WRAP for the ESMP and how an annual emissions goal
may be created.
The application of emissions reduction techniques and use of alternatives to burning subject to
economic, safety, technical and environmental feasibility criteria would be utilized in order to
meet the control objectives for fire emissions sources classified as “anthropogenic”. These
programs and techniques are further supported by the Regional Haze Rule.27 The FEJF is
assessing the availability and feasibility of alternatives to burning for both wildlands and
agricultural lands.
26 64 FR 35771, Requirements related to the Grand Canyon Visibility Transport Commission §51.309(d)(6)(v).
27 64 FR 35767, Regional haze program requirements §51.308(d)(3)(v)(E).
64 FR 35771, Requirements related to the Grand Canyon Visibility Transport Commission §51.309(d)(6).
August 30, 2001
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3.1.3. Tracking Fire Emissions
Statement: Emissions from all fire will be tracked.
In order to determine fire’s contribution to natural background visibility conditions and
anthropogenic visibility impairment, all fire emissions sources, regardless of ownership or land
use type, need to be tracked across the WRAP region. The GCVTC Recommendations,
committed to by the western Governors in 1996, and the subsequent 1999 Regional Haze Rule,
both establish the need and requirement for the tracking of emissions for all fire emissions
sources.
“Implement an emissions tracking system for all fire activities.”28
“The [implementation] plan must provide for: (ii) A statewide inventory and emission
tracking system (spatial and temporal) of VOC, NOx, elemental and organic carbon, and
fire particle emissions from fire….”29
Emissions from all fires will be tracked for two purposes, to classify the fire as “natural” or
“anthropogenic”, and, if “anthropogenic”, to facilitate the demonstration of reasonable progress
toward the 2064 natural conditions goal. The use of alternatives and emission reduction practices
needs to be in a fire emissions tracking system for the demonstration of reasonable progress and
annual emissions goal accounting process. The FEJF will be developing recommendations on the
parameters that will need to be tracked and for what source size.
3.2.
CLASSIFICATION CRITERIA
The following sections provide clarifying and supporting information regarding each of the three
Classification Criteria statements from Section 2 above. The three Criteria statements apply to
both wildland and agricultural lands regardless of ownership, cause of ignition, or purpose of the
fire within the WRAP region.
For the most part, fire emissions sources are classified “anthropogenic”. The “anthropogenic”
classification recognizes that there is potential to control the emissions from most fires, as
acknowledged in the GCVTC Recommendations, the Regional Haze Rule, and the stakeholder
participation process. Some fire emissions sources have been classified as “natural”, and, like
“anthropogenic” sources, will be managed to minimize potential air quality impacts. The
rationale for “natural” classifications is clearly stated in the following annotated sections, and
reflects the reasoning of the GCVTC, the Rule, stakeholder input, as well as current smoke
management capabilities.
For the categorization of fire emissions to function appropriately, the person(s) or entity that
initiates a fire or manages the land where fire occurs is responsible for determining the
classification using this Policy, with oversight by the applicable air quality regulatory authority.
28 GCVTC Report, page 48.
29 64 FR 35771, Requirements related to the Grand Canyon Visibility Transport Commission §51.309(d)(6)(ii).
August 30, 2001
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3.2.1. Prescribed Fire
Statement: Prescribed Fire is an “anthropogenic” source, except where it is utilized
to maintain an ecosystem that is currently in an ecologically functional and fire
resilient condition, in which case it is classified as a “natural” source.
A prescribed fire is any fire ignited by a planned management action to meet specific objectives
on agricultural land or wildland, regardless of land ownership. Prescribed fires may have various
purposes including, but not limited to, vegetative residue disposal, pest and disease control, yield
improvement, ecosystem restoration, ecosystem maintenance, and hazardous fuel reduction.
Often, prescribed fire will meet multiple objectives. It is the intent of this Policy that the fire’s
classification will be determined based on the primary and predominant purpose for the fire.
This portion of the Policy also applies to wildfires managed for resource objectives, as addressed
by Classification Criteria statement B.
Ecosystem Maintenance
“…EPA believes States should be permitted to consider some amount of fire in the
calculation [of natural background] to reflect the fact that some prescribed fire effects
serve merely to offset what would be expected to occur naturally.”30
The primary distinction in classifying prescribed fire is between ecosystem restoration and
maintenance. Only prescribed fire used to maintain an ecosystem is classified as “natural”. All
other prescribed fire, including restoration of ecosystems, is classified as “anthropogenic”. This
distinction was based on stakeholder input as a key to agreement on the development of this
Policy, and reflects the reasoning of both the Regional Haze Rule Preamble and the GCVTC
Recommendations.
“Fire has played a major role in the development and maintenance of most ecosystems in
the West. The long-term future of the West is dependent on healthy ecosystems that are
capable of sustaining natural processes and human uses. ... Fire is an essential component
of most natural ecosystems, and perpetuation of fire at a level required to maintain
ecosystem processes is necessary.”31
30 64 FR 37535-35736.
31 GCVTC Report, page 47.
August 30, 2001
13
Ecosystem maintenance prescribed fires are beneficial to natural ecosystems that are resilient to
the application of fire.32 Further, these areas are free from excess fuel generated through past
land management decisions. Where fire is used to mimic the natural process, that fire is
classified “natural”, which recognizes that these fires have the opportunity for smoke
management. Additionally, stakeholder input recognized that imitating the natural process with
prescribed fires for ecosystem maintenance produces emissions comparable to those that would
occur naturally. This fire type predominantly occurs on wildland and may also occur on lands in
the USDA Conservation Reserve Program.
It should be noted that the science of determining a fully functional and fire resilient ecosystem
is continually evolving. It is the intent of this Policy to accommodate future changes in the
understanding and subsequent determination of the broad range of ecosystems.
A “natural” classification may only be assigned to a prescribed fire when the person(s) or entity
that initiates the prescribed fire determines that the fire is in an area identified as being in an
ecologically functional and fire resilient condition.33 Further, the “natural” classification will
only hold if maintenance of the area’s ecosystem is the primary and predominant purpose of the
burn. This classification will be made with oversight by the applicable air quality regulatory
authority.
Ecosystem Restoration & Prescribed Fire for Other Purposes
“The EPA recognizes the natural role of fire in forest ecosystems, and the fact that forest
fuels have built up over many years due to past management practices designed to protect
public health and safety through fire suppression. Research has shown that these practices
have led to an increased risk of catastrophic wildfire as well as reduced forest health. In
response to this situation, the Federal land management agencies, as well as some States
and private landowners, have recommended the increased use of prescribed fire in order
to return certain forest ecosystems to a more natural fire cycle and to reduce the risk of
adverse health and environmental impacts due to catastrophic wildfire.”34
Ecosystem restoration is the re-establishment of natural vegetation and may be accomplished
through the reduction of unwanted and/or unnatural levels of biomass, which may have
accumulated due to management action (e.g., long-term wildland fire suppression or hazardous
fuel treatment). Multiple prescribed fires and mechanical treatments may be necessary to restore
an ecosystem to an ecologically functional and fire resilient condition. Ecosystem restoration
may also be used to control undesirable plant species.35 All burning for ecosystem restoration
purposes is classified as “anthropogenic”.
32 For example, in a big sage and grass ecosystem, diversity of species and age class is required for the fire to be
classified as maintenance burn.
33 Currently, there is an assessment of condition classes for wildlands at the national programmatic level, as defined
in the National Fire Plan and the Cohesive Strategies for the USDA-Forest Service and Department of Interior. More
refined planning, to determine both fire’s role and application, will be done at the land-use planning level or sitespecific level. The programmatic assessment will help land managers at the local level in defining those ecosystems
that are in a condition where burning can be classified as “natural”.
34 64 FR 35735.
35 For example, in the Great Basin, prescribed fire used in conjunction with an application of herbicide followed by
August 30, 2001
14
Prescribed fire may be utilized for purposes other than ecosystem restoration and maintenance. It
may be conducted for the purpose of vegetative residue disposal (e.g., timber slash or wheat
stubble burning). Prescribed fire may be used to increase or maintain agricultural and
silvicultural output or forage values.36 Fires may also be utilized to control weeds, pests, and
diseases, and improve yield (e.g., grass and rice field burning). Hazard reduction burning may be
conducted in areas of accumulated wildland fuels to reduce the risk of wildfire.37 Prescribed fires
that are initiated for special interests such as wildlife, recreation, range, water, or other resources
also fit into this other prescribed fire category.38
Key to the categorization of other prescribed fire (except ecosystem maintenance) as an
“anthropogenic” source, is the recognition that there is potential to control the emissions from
most fires, in addition to smoke management. Stakeholders additionally recognized that these
fires, in most cases, could produce emissions greater than what could be anticipated to occur
naturally.
3.2.2. Wildfire
Statement: Wildfire that is suppressed by management action is a “natural” source.
Wildfire, when suppression is limited for safety, economic, or suppression resource
limitations, remains a “natural” source. Wildfires managed for resource objectives
are classified the same as prescribed fires.
A wildfire is any unwanted, non-structural fire that can occur on wildlands or agricultural lands.
Unwanted wildfires can be ignited by both natural causes such as lightning, or human causes
such as accidental human ignitions, escaped prescribed fires, or arson. Examples of accidental
human ignitions include fireworks, cigarettes, escaped campfires, vehicle fires, and fires from
farm machinery. Arson is defined as the intentional start of a fire with the intent to either
maliciously or fraudulently damage property of one’s own or that of another.
Wildfires may be suppressed by management action, or they may be managed for resource
objectives through the rejection of the suppression option or application of limited suppression.
reseeding is proving to be successful in reducing the spread of cheatgrass (an invasive Mediterranean annual grass),
which burns at a much higher frequency than the natural vegetation.
36 For example, periodic burning is utilized to improve forage quality on rangelands for livestock or wildlife.
37 For example, in the wildland/urban interface a prescribed fire in Ponderosa Pine may be ignited during the fall to
consume an over-accumulation of undergrowth that, if left untreated, would provide a “ladder” for fire to reach the
crowns of the trees.
38 Several examples follow: 1) To protect a watershed, prescribed fire can be used to create a mosaic of age classes
in many vegetation types each having a different flammability, reducing the likelihood that an entire watershed will
all burn at the same time. 2) Brush or forest fuels may be burned to improve a scenic vista. 3) A prescribed fire may
be utilized to improve forage and/or habitat that will increase hunting opportunities.
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Suppressed by Management Action
Wildfires that are under suppression are unwanted, non-structural fires that are being actively
suppressed due to threats to public health and safety, firefighter safety, or damage to property
and/or resources (e.g., South Canyon wildfire of 1994 in Colorado or Oakland Hills wildfire of
1991 in California). The term “management action” denotes the overriding intent to suppress
(i.e., control) the unwanted wildfire due to the considerations expressed above.
The ability to control the emissions from wildfires under suppression is limited, which was the
underlying principle for the inclusion of this source in the “natural” classification. Further, the
fact that, in most instances, everything possible is being done to suppress the fire safely and
economically also supported a “natural” source classification.
In the evaluation of alternative wildfire management strategies, several constraints are
considered in selecting the appropriate management action. These constraints may include
firefighter and public safety, risk to property, available firefighting resources, and others, such as
air quality considerations. In some instances, suppression efforts for a wildfire may be limited
due to safety, economic or suppression resource limitations (e.g., equipment or personnel), as
was the case in Montana during the wildfires of 2000 when the need exceeded the available
resources. In these cases, the wildfire is classified as “natural”.
On Federal lands39, one of the constraints already under consideration during the evaluation of
alternate fire management strategies is air quality. Air quality will need to be considered on all
lands, regardless of ownership. However, air quality considerations are just one of several
important criteria, such as firefighter and public safety and protection of property and resources,
that are weighed according to positive, neutral, or negative effects, and evaluated to select the
appropriate management response to the wildfire.
The potential is high for significant visibility impacts from episodic wildfires under suppression,
as demonstrated by recent wildfire seasons (i.e., 1996 and 2000). During the development of this
Policy, stakeholders expressed concern that the visibility improvements resulting from emissions
reduction programs for industrial, mobile, and other anthropogenic sources may be masked by
visibility impacts from wildfires under suppression. This Policy contains a recommendation in
Appendix B that a workgroup be formed to study the effects from unwanted wildfire events and
consider the development of an approach similar to that of EPA’s Natural Events Policy for
visibility data.
Managed for Resource Objectives
The key distinction between wildfires suppressed by management action and wildfires managed
for resource objectives is the conscious management decision to allow these incidents to grow
toward the achievement of specific resource benefits.
39 Wildland Fire Situation Analysis (WFSA).
August 30, 2001
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Wildland Fire Managed for Resource Benefits, Prescribed Natural Fire, and Wildland Fire Use
are all terms that have current use in regulations and policies, and are considered to be
synonymous. These terms refer to the management of wildland fires to accomplish specific, prestated resource management objectives in predefined geographic areas, under pre-determined
conditions (e.g., weather, firefighting resources available, etc.) as outlined in an approved fire
management plan or as applied on non-Federal land in the field without a plan.40
At present, these types of fires occur primarily on federally managed lands. It is possible that in
the future, state, tribal, municipal, or private landowners may choose to utilize the same
management response, with or without a plan in place.
The underlying principle guiding the classification of these fires is the potential for emissions
management and/or control, which is the same as that of prescribed fires. The classification in
these instances, just like prescribed fire, is based on the ecological condition of the land.
Therefore, a wildfire managed for resource objectives will be treated as a prescribed fire and
classified according to the same criteria.
Escaped Prescribed Fire
It is estimated that more than 99 percent of the prescribed fires in the WRAP region are
accomplished with few or no control problems, i.e., do not escape. An escaped prescribed fire is
any fire ignited by management actions on wildland or agricultural land to meet specific
objectives, that goes out of prescription (e.g., fire intensity greater than specified in a pre-set fire
plan, pre-set wind speeds exceeded, fire jumps pre-established boundaries, etc.) in a predefined
geographic area. For example, the Cerro Grande fire of 2000 in New Mexico was an escaped
prescribed fire. An escaped prescribed fire can no longer accomplish the land and resource
management objective of the prescribed fire when it goes out of prescription.
The few prescribed fires that do escape become wildfires, and require appropriate suppression
action by the land manager. The underlying principle guiding the classification of these fires is
the recognition that the ability to control the emissions from escaped prescribed fires is limited,
which is the same as that of wildfires under suppression. Therefore, an escaped prescribed fire
will be treated as a wildfire under suppression.
The EPA Interim Air Quality Policy on Wildland and Prescribed Fires should be consulted
for these escaped prescribed fire incidents.
40 For example, a wildfire that starts in a wilderness area, where the ecosystem is currently in an ecologically
functional and fire resilient condition and there is little or no threat to life or property, can be allowed to play its
natural role as outlined in an approved fire management plan.
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3.2.3. Native American Cultural Burning
Statement: Native American cultural burning for traditional, religious, and
ceremonial purposes is a “natural” source.
This Classification Criteria statement applies to vegetative burning conducted by Native
Americans for traditional, religious and ceremonial purposes. The purposes of burning may
include, but are not limited to, burning grasslands and forestlands for basket materials (e.g.,
hazel, bear grass, tule, and iris), medicinal and ceremonial plants, and subsistence plants (e.g.,
acorns, huckleberry, and pine nuts). Where fire is used for traditional, religious or ceremonial
purposes, that fire is classified as “natural”, which recognizes that these fires have the
opportunity for smoke management. Individual tribal governments will establish the vegetative
burning that falls into this categorization.
This Policy makes a distinction between traditional, religious and ceremonial vegetative burning
purposes and other non-vegetative burning activities. This Policy does not apply to Native
American cultural non-vegetative burning for traditional, religious or ceremonial purposes (e.g.,
cremation, sweat lodge fires). Individual tribal governments may identify these purposes of
burning by resolution, rule or ordinance for traditional, ceremonial or religious use. Native
American cultural non-vegetative burns will not be tracked or considered in the establishment of
either natural background conditions nor toward the reasonable progress requirements of the
Regional Haze Rule.
A “natural” classification may be assigned to a Native American cultural burn when the
person(s) or entity that initiates the vegetative burn determines, with oversight by the designated
tribal air quality regulatory authority or EPA, that the fire has been established by the tribal
government for a traditional, religious, or ceremonial purpose. All other Native American
vegetative burning is prescribed fire and will be classified accordingly. The categorization
distinction within Native American fire (i.e., vegetative burning for traditional, religious, and
ceremonial purposes vs. prescribed fire) was based on recognition of certain traditions specific to
the Native American culture.
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4. APPENDICES
APPENDIX A.
GLOSSARY
This glossary is intended to provide readers with several operating definitions to facilitate a
consistent review of the Policy. However, this glossary is not intended to be a complete list of all
terms and acronyms.
2064 Natural Conditions Goal - The ultimate goal of the regional haze program is the absence of
visibility impairment due to human-caused emissions.
AAQTF - Agricultural Air Quality Task Force. A task force to address agricultural air quality
issues established by the Chief of the Natural Resources Conservation Service.
Accidental Human Ignition - An unintentional random event. (E.g., Fire ignited by a cigarette
butt, an escaped campfire, or a combine.)
Agricultural Fire/Burning* - Any fire ignited by management actions to meet specific objectives
(i.e., managed to achieve resource benefits) on agricultural land.
Agricultural Land* - Agricultural land includes croplands, pasture, and other lands on which
crops or livestock are produced (PL 104-127, Section 1240A). Rangeland will be included
with wildland for the purposes of the Fire Emissions Joint Forum work.
AMRF - Ambient Air Monitoring and Reporting Forum. The Ambient Air Monitoring and
Reporting Forum was established to make recommendations to the Western Regional Air
Partnership with regard to appropriate approaches for collection, use, and reporting of
ambient air quality and meteorological monitoring data as needed to further the overall
goals of the Western Regional Air Partnership.
Anthropogenic Emissions Source Classification (“anthropogenic”) - A categorization that
designates which fire emissions contribute to visibility impairment in a Federal Class I
area. “Anthropogenic” emissions must be controlled to achieve progress toward the 2064
natural conditions goal for each Federal Class I area in the WRAP region. This
classification includes natural and human-caused ignitions.
Arson - The intentional, malicious or fraudulent ignition of a fire or explosion that damages
property of the arsonist or another. (E.g., A fire intentionally ignited to accrue ill-gotten
gains, such as from an insurance settlement, or a fire intentionally ignited as retribution
against a land manager.)
* Operating Definitions from Section 1.1 of the WRAP FEJF Workplan dated February 25, 1999.
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Control of Fire - The controllability of a fire is dictated by a variety of considerations such as fire
fighter and public safety, risk to property and resources, fire fighting resources available,
land management objectives, and environmental, social, economic, and political
constraints. The environmental and social constraints include, among other things, how
air quality and/or visibility will be affected at sensitive receptors. Control of fire is
analogous to full suppression by management action.
Control of Fire Emissions - Actions may be taken to control fire emissions by utilizing best
management practices such as the use of alternatives, biomass utilization, and other
emission reduction techniques.
Ecosystem Maintenance - 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.
Ecosystem Restoration - The re-establishment of natural vegetation that may be accomplished
through the reduction of unwanted and/or unnatural levels of biomass, which may have
accumulated due to management action. Prescribed fires, wildfires managed for resource
benefits and mechanical treatments may be utilized to restore an ecosystem to an
ecologically functional and fire resilient condition.
EPA - United States Environmental Protection Agency
Escaped Prescribed Fire - Any fire ignited by management actions on wildland or agricultural
land to meet specific objectives that goes out of prescription (e.g., fire intensity greater
than specified in a pre-set fire plan, pre-set wind speeds exceeded, fire jumps preestablished boundaries, etc.) in a predefined geographic area.
Federal Class I area - In 1977, Congress identified 156 national parks, wilderness areas,
international parks and other areas that were to receive the most stringent protection from
increases in air pollution. It also set a visibility goal for these areas to protect them from
future human-caused haze, and to eliminate existing human-caused haze, and required
reasonable progress toward that goal.
FEJF - Fire Emissions Joint Forum. The Fire Emissions Joint Forum’s mission is to address both
policy and technical issues while developing programs and tools relating to prescribed
fire and air quality for the Western Regional Air Partnership and related Western
Regional Air Partnership forums.
Fire* - When this term appears, it refers inclusively to wildfire, prescribed natural fire/wildland
fire managed for resource benefits, prescribed fire, rangeland fire, and agricultural fire.
* Operating Definitions from Section 1.1 of the WRAP FEJF Workplan dated February 25, 1999.
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GCVTC - Grand Canyon Visibility Transport Commission. The GCVTC was authorized under
Section 169B(f) of the Clean Air Act and 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. The Commission was established to recommend methods to preserve
and improve visibility on the Colorado Plateau, and submitted Recommendations to EPA
in June 1996.
Hazard Reduction - Burning of accumulated wildland fuels to reduce the risk of wildfire. (E.g.,
Wildland/urban interface burning or burning in areas of especially combustible fuels.)
IMPROVE - Interagency Monitoring of Protected Visual Environments. A cooperative visibility
monitoring effort, using a common set of standards across the United States, between the
EPA, Federal land management agencies, and state air agencies.
Land Managers* - When this term appears, it refers inclusively to Federal, state, tribal, and
private land managers.
Manage Fire Emissions - Actions may be taken to manage fire emissions to minimize impacts on
visibility, public health, and nuisance concerns. Some management actions include
concepts such as the timing of ignitions for better dispersion and consideration of
downwind air quality and visibility. It may also include consideration of factors related to
the area to be burned such as the fuel moisture condition and other physical parameters.
Manage fire emissions is analogous to smoke management.
NAAQS – National Ambient Air Quality Standards
Natural Background Condition - An estimate of the visibility conditions at each Federal Class I
area that would exist in the absence of human-caused impairment.
Natural Emissions Source Classification (“natural”) - A categorization that designates which fire
emissions can result in a natural reduction of visibility for each Federal Class I area in the
WRAP region. This classification includes natural and human-caused ignitions.
Natural Ignition - Fire/Burn ignited due to a natural (i.e., non-human-caused) event. (E.g., Fire
ignited by lightning or volcanic eruption.)
NBTT - Natural Background Task Team. A task team of the Fire Emissions Joint Forum
working on determining the classification of fire emissions as either “natural” or
“anthropogenic”. Team members include Forum and non-Forum members with special
expertise.
* Operating Definitions from Section 1.1 of the WRAP FEJF Workplan dated February 25, 1999.
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Organic Carbon - Complex carbon-containing compounds often emitted by plants and from
many human activities.
Pasture Land - Grazing lands comprised of introduced or domesticated native forage species that
are used primarily for the production of livestock. They receive periodic renovation
and/or cultural treatments such as tillage, fertilization, mowing, weed control, and may be
irrigated. They are not in rotation with crops (Natural Resources Conservation Service
National Range and Pasture Handbook, 1997.)
Prescribed Fire* - Any fire ignited by management actions to meet specific objectives (i.e.,
managed to achieve resource benefits).
Rangeland - Land on which the historic climax plant community is predominantly grasses, grasslike plants, forbs, or shrubs. Includes lands re-vegetated naturally or artificially when
routine management of that vegetation is accomplished mainly through manipulation of
ecological principles. Rangeland includes natural grasslands, savannas, shrublands, most
deserts, tundra, alpine communities, coastal marshes and wet meadows (Natural
Resources Conservation Service National Range and Pasture Handbook, 1997.)
Regional Planning Organization - An organization that will first evaluate technical information
on regional haze and related issues to better understand how their states and tribes impact
national park and wilderness areas (Federal Class I areas) across the country. The
organization will then pursue the development of regional strategies to reduce emissions
of particulate matter and other pollutants leading to regional haze. The five Regional
Planning Organizations that receive funding from EPA to address regional haze and
related issues are: Central States Regional Air Partnership (CENRAP) for the central
states, Midwest Regional Planning Organization for the mid-western states, Ozone
Transport Commission (OTC) for the northeastern states, Southeast States Air Resource
Managers (SESARM) for the southeastern states, and Western Regional Air Partnership
(WRAP) for the western states.
Rule - Regional Haze Rule. Regulations published in the Federal Register on July 1, 1999 (64 FR
35714) that require states to establish goals for improving visibility and to develop longterm strategies for reducing emissions of pollutants that cause visibility impairment.
Silviculture - The theory and practice of controlling forest establishment, composition, and
growth. The art of producing and tending a forest.
SIP - State Implementation Plan. Plans devised by states to carry out their responsibilities under
the Clean Air Act. SIPs must be approved by the U.S. Environmental Protection Agency
and include public review.
Smoke Effects* - The effects on visibility (both plume blight and regional haze), public
nuisance, and the health-based NAAQS due to emissions from fire.
* Operating Definitions from Section 1.1 of the WRAP FEJF Workplan dated February 25, 1999.
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Smoke Management Program (SMP) - The objectives of a basic or enhanced smoke management
program are to ensure: 1) no health-based NAAQS are exceeded; 2) nuisance smoke is
mitigated; and 3) smoke impacts on visibility are minimized in Class I areas and meet the
Grand Canyon Visibility Transport Commission Recommendations.
TIP - Tribal Implementation Plan. Plans devised by tribes to carry out their responsibilities under
the Clean Air Act. TIPs must be approved by the U.S. Environmental Protection Agency
and include public review.
Vegetative Residue Disposal - Burning of land management related fuel or vegetation that is the
by-product of a commercial operation. (E.g., Burning of wheat stubble, orchard prunings,
orchard or vineyard removals, leftover Christmas trees, timber slash or landing residues.)
Weed/Pest/Disease Management - Burning with the pre- and post-harvest objective of reducing
and/or eliminating competing weeds or other non-target vegetation during a standard crop
rotation. Burning with the pre- and post-harvest objective of controlling and/or reducing
the incidence of pests and disease impacting a crop. (E.g., Weed – goat crass, star thistle
control, cheatgrass, dodder; Pest – hessian fly, lygus bugs, weevils; Disease –
cepholosporium stripe rust, fire blight, tristeza virus.)
Wildfire* - Any unwanted, non-structural fire.
Wildfire Managed for Resource Objectives – The management of naturally ignited fires,
regardless of land type or ownership, to accomplish specific, pre-stated resource
management objectives in predefined geographic areas with or without a plan in place.
This term is considered to be analogous with the terms Wildland Fire Managed for
Resource Benefits and Prescribed Natural Fire that are used in regulations and policies
regarding Federal wildlands.
Wildland* - An area where development is generally limited to roads, railroads, power lines, and
widely scattered structures. The land is not cultivated (i.e., the soil is disturbed less
frequently than once in 10 years), is not fallow, and is not in the USDA Conservation
Reserve Program (CRP). The land may be neglected altogether or managed for such
purposes as wood or forage production, wildlife, recreation, wetlands, or protective plant
cover (EPA Interim Air Quality Policy on Wildlands and Prescribed Fires). The land is
not “agricultural land” as operationally defined above. Silvicultural land and rangelands
(per the FEJF charge), woodlots, and private timberlands will be included with wildlands
for the purposes of the FEJF work.
Wildland Fire - All types of fire (see definition of fire above), except fire on agricultural land.
* Operating Definitions from Section 1.1 of the WRAP FEJF Workplan dated February 25, 1999.
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Wildland Fire Managed for Resource Benefits/Prescribed Natural Fire* - These terms both have
current use in regulations and policies. They are considered to be synonymous and are
used interchangeably in this workplan. These terms refer to the management of naturally
ignited fires to accomplish specific, pre-stated resource management objectives in
predefined geographic areas outlined in the fire management plan.
WRAP region - The WRAP region includes 247 tribes and the states of Arizona, California,
Colorado, Idaho, Montana, North Dakota, New Mexico, Oregon, South Dakota, Utah,
Washington, and Wyoming.
WRAP - Western Regional Air Partnership. The WRAP is a collaborative effort of tribal
governments, state governments and Federal agencies to promote and monitor
implementation of Recommendations from the Grand Canyon Visibility Transport
Commission. The WRAP may also address other common western regional air quality
issues as raised by its membership. The activities of the WRAP are conducted by a
network of committees and forums, composed of WRAP members and stakeholders who
represent a wide range of social, cultural, economic, geographic and technical
viewpoints. The WRAP members include the governors of twelve western states (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. The National Tribal
Environmental Council and the Western Governors’ Association administer the WRAP.
Yield Improvement - Burning that improves growing conditions for subsequent crops (i.e., by
adding nutrients or available water to the soil) or burning that stimulates new growth.
(E.g., Field burning on seed production fields.)
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APPENDIX B.
RECOMMENDATION FOR THE FLAGGING OF VISIBILITY
DATA AFFECTED BY WILDFIRES UNDER SUPPRESSION
The potential is high for significant visibility impacts from episodic wildfires under suppression,
classified as “natural”, as demonstrated by recent wildfire seasons (i.e., 1996 and 2000).
Significant visibility impacts may be caused by an individual unwanted wildfire event that can
last for months at a time, and may be compounded when combined with impacts from other
unwanted wildfire events across the landscape.
The emissions and subsequent visibility effects of wildfire are highly variable both spatially and
temporally. Wildfire activity can range dramatically from year to year in the same state, as
demonstrated in Wyoming where approximately 1.5 million acres were burned by wildfire in
198841 and less than 9 thousand acres were burned in 199342. Further support of this variability,
which will dramatically affect visibility, can be found in Graph B-1 that depicts the high, low,
and median values of acres burned by wildfire for the respective year.
Depending on the frequency and magnitude of the unwanted wildfire events, the calculated
baseline, current, and natural background visibility conditions may not represent an accurate
portrayal of the visibility conditions at a given Federal Class I area in the WRAP region.
Stakeholders have expressed concern that the visibility improvements resulting from emissions
reduction programs for industrial, mobile, and other anthropogenic sources may be masked by
visibility impacts from wildfires under suppression. Concomitantly, the demonstration of
reasonable progress may be dominated by visibility impacts to the natural background condition
from these unwanted wildfires.
“The contribution from fires can be substantial over short-term periods, but fires occur
relatively infrequently and thus have a lower contribution to long-term averages….than
sources for which emissions are more continuous.”43
Unwanted wildfire events that occur relatively infrequently may have a lower contribution to
long-term averages, such as baseline and current conditions. However, if unwanted wildfire
events have a significant contribution to visibility impacts for three of the five years used to
calculate the baseline conditions, the baseline conditions portrayed would be artificially high.
This also holds true if unwanted wildfire events occur at a greater frequency and magnitude
during the five years utilized to establish current conditions, against which, states are required to
demonstrate reasonable progress toward the 2064 natural conditions goal. Thus, the frequency
and magnitude of unwanted wildfires has a potential to conceal visibility improvements from
other source types, particularly for the 20 percent most-impaired days.
41 USDA – Forest Service, Fire and Aviation Management, 1984 – 1990 Wildland Fire Statistics, January 1992.
42 USDA – Forest Service, Fire and Aviation Management, 1991 – 1997 Wildland Fire Statistics, September 1998.
43 64 FR 35736.
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Based on the variability and the magnitude of wildfire emissions, the FEJF recommends that in
conjunction with the AMRF and with involvement of EPA, a workgroup be formed to study the
effects from unwanted wildfire events on the establishment of baseline, current, and natural
background visibility conditions, as well as on the demonstration of reasonable progress. The
development of an approach similar to the Natural Events Policy44 for wildfires under
suppression should be considered by the aforementioned workgroup, to ensure that visibility
improvements from other source types are not masked by visibility impacts from unwanted
wildfire events.
Graph B-1. Wildfire Variability – Acres Burned per Year45
Variance in Wildland Acres Burned for Western States
(1984 - 1997)
1,600,000
1,537,302
(1988)
Median
1,400,000
1,200,000
Acres
1,000,000
840,399
(1987)
800,000
740,161
(1996)
600,000
820,400
(1985)
658,714
(1988)
553,110
(1996)
390,431
(1994)
400,000
307,675
(1994)
251,555
(1995)
200,000
15,203
(1997)
0
AZ
42,354
(1991)
CA
7,275
(1992)
CO
184,477
(1985)
137,758
(1988)
104,966
(1996)
4,958
(1993)
ID
8,701
(1987)
MT
4,480
(1995)
ND
37,307
(1984)
NM
32,280
(1997)
NV
12,688
(1993)
OR
4,979
(1986)
SD
6,271
(1995)
WA
8,911
(1993)
WY
44 The monitored data for visibility could be flagged using an approach parallel to the Natural Events Policy for
flagging and exempting monitored data exceeding the particulate matter health standard caused by a natural event.
The flagged IMPROVE data could potentially be exempted from the calculation of baseline, current and natural
background visibility conditions, as well as the determination of reasonable progress. This could occur when the
data monitored by the IMPROVE network appears to have a significant effect (e.g., => 1 deciview) from wildfires
under suppression.
45 USDA – Forest Service, Fire and Aviation Management, 1984 – 1990 Wildland Fire Statistics, January 1992.
USDA – Forest Service, Fire and Aviation Management, 1991 – 1997 Wildland Fire Statistics, September 1998.
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APPENDIX C.
WEBSITE REFERENCES
This appendix is intended to provide readers with several website addresses that were used to
locate supporting information for the development of this Policy.
— Western Regional Air Partnership (WRAP) website
(http://www.wrapair.org)
— WRAP Fire Emissions Joint Forum (FEJF) website
(http://www.airsci.com/splprj.htm)
— U.S. Environmental Protection Agency’s Visibility Improvement Program website
(http://www.epa.gov/oar/vis)
— Agricultural Air Quality Task Force website
(http://www.nhq.nrcs.usda.gov/faca/aaqtf.html)
— National Fire Plan, Interagency website
(http://www.fireplan.gov)
— GCVTC Recommendations for Improving Western Vistas, June 10, 1996
(http://www.nmia.com/gcvtc)
(http://www.wrapair.org) Click on the GCVTC link
The report was used as the basis for developing Section 51.309 of the Regional Haze Rule.
— Regional Haze Rule, 40 CFR Part 51, July 1, 1999
(http://www.epa.gov/ttn/oarpg/t1/fr_notices/rhfedreg.pdf)
— The EPA Interim Air Quality Policy on Wildland and Prescribed Burning, April 23, 1998
(http://www.epa.gov/ttn/oarpg/t1/memoranda/firefnl.pdf)
This document describes the components of a state/tribal basic smoke management program.
— White Papers associated with the Interim Policy:
(http://www.westar.org/projects_fp.html)
1. Background on the Role of Fire
2. What Wildland Fire Conditions Minimize Emissions and Hazardous Air Pollutants and
Can Land Management Goals Still Be Met?
3. Air Monitoring for Wildland Fire Operations
4. Emissions Inventories for SIP Development
5. Estimating Natural Emissions from Wildland and Prescribed Fire
— The EPA Natural Events Policy for Particulate Matter, June 6, 1996
(http://www.epa.gov/ttn/caaa/t1/memoranda/nepol.pdf)
This document outlines how states should address “natural events” that produce high levels
of particulate matter.
August 30, 2001
27
— Agricultural Air Quality Task Force
Air Quality Policy on Agricultural Burning, November 10, 1999
(http://www.nhq.nrcs.usda.gov/faca/Policies/Burning%20Policy.htm)
Production Agriculture Voluntary (Incentive Based) Air Quality Compliance Program,
November 10, 1999
(http://www.nhq.nrcs.usda.gov/faca/Policies/Voluntary.htm)
FR Vol. 65, No. 181, September 18, 2000 (56308-56310).
(http://www.epa.gov/fedrgstr/EPA-AIR/2000/September/Day-18/a23948.htm)
The task force recommendations and public comment will be used by the EPA to develop a
policy for agricultural burning.
— A Collaborative Approach for Reducing Wildland Fire Risks to Communities and the
Environment, 10-Year Comprehensive Strategy
(http://www.westgov.org/wga/initiatives/fire/)
— EPA Prescribed Burning Background Document and Technical Information Document for
Prescribed Burning Best Available Control measures, EPA-450/2-92-003, September, 1992
(http://www.epa.gov/ttncaaa1/t1bid.html)
This document provides RACM and BACM for prescribed burning (includes measures for
agricultural burning).
August 30, 2001
28
Recommended Policy Approval Process
IOC Submission to WRAP – October 31, 2001
IOC Transmittal Letter to the WRAP
Recommended Policy for Categorizing Fire Emissions, October 25, 2001
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IOC TRANSMITTAL LETTER TO THE WRAP
TO ACCOMPANY THE FIRE EMISSIONS JOINT FORUM
"RECOMMENDED POLICY FOR CATEGORIZING FIRE EMISSIONS"
October 31, 2001
Dear WRAP Board:
At the recent September 5th meeting of the WRAP Initiatives Oversight
Committee (IOC) in Seattle, Washington, the Fire Emissions Joint Forum (FEJF)
made a presentation on the final "Recommended Policy for Categorizing Fire
Emissions". The IOC wishes to thank Pete Lahm, Darla Potter, and Carl
Gossard for making this presentation, and greatly appreciates all the effort
and hard work of the Natural Background Task Team (NBTT) in developing this
policy. The IOC endorses this consensus policy, and stresses the importance
for states and tribes to adopt the entire Policy not just the Classification
Criteria section of the Policy. However, there are several key provisions and
recommendations in the policy that need further clarification, as discussed
below.
The Recommended Policy for Categorizing Fire Emissions was developed to
assist states and tribes in distinguishing between which fire emissions are
anthropogenic and those that are natural. Under the Regional Haze Rule, all
anthropogenic emissions need to be controlled to reduce visibility impacts in
Class I areas, in order to meet the reasonable progress requirements of the
Rule. Natural emissions are considered part of the "natural background
conditions", and as such are not subject to the reasonable progress
requirements.
The Policy is consistent with the Regional Haze Rule, and defines “natural”
fire emissions as those that “…can result in a natural reduction of
visibility…” and “anthropogenic” fire emissions as those that “contribute to
visibility impairment … [and] must be controlled to achieve progress toward
the 2064 natural conditions goal…” The policy contains two main sections;
Classification Program Management (Section 3.1) and Classification Criteria
(Section 3.2). Concise overviews of these sections are included in the
executive summary of the policy document (pp i & ii).
At the September 5th IOC meeting, there was much discussion of these elements
of the Recommended Policy. The IOC endorses the policy, however the group
identified certain areas where further clarification was needed from the FEJF
in its future work. The IOC is aware that the FEJF is currently developing a
series of policy and technical tools necessary to implement the Grand Canyon
Visibility Transport Commission Recommendations and meet the requirements of
the Regional Haze Rule. The FEJF needs to ensure that the following items are
considered and clarified during the development of those policy and technical
tools:
1.
The distinction between the concepts of "managed" and "controlled" fire
emissions, as it relates to fire classified as “natural” and “anthropogenic”.
The IOC believes future FEJF guidance needs to further clarify these terms,
and describe how they apply in future FEJF recommended policies.
2.
The distinction between “ecosystem maintenance” and “ecosystem
restoration” burning and how they relate to “natural” and “anthropogenic”
classifications.
IV-91
3.
The coordination with states and tribes on decisions by land managers
to classify prescribed burning as either restoration or maintenance. The IOC
is concerned about consistency in making this determination from state to
state. FEJF guidance under development should include possible approaches
states and tribes could follow to ensure close coordination and consistency
in making this determination.
4.
The establishment of an inter-forum workgroup as recommended in
Appendix B of the Policy and consideration of additional ways for excluding
wildfire impacts besides just traditional "flagging" of the monitoring data.
Appendix B recommends a workgroup be formed to study how wildfire impacts in
visibility monitoring data could affect the ability to demonstrate reasonable
progress with the Regional Haze Rule. It further recommends that the
workgroup consider the flagging of wildfire impacts in monitoring data in
order to exclude it from reasonable progress assessments, similar to the
approach in the PM10 Natural Events Policy for health standard violations
from wildfire and natural dust events. The IOC believes it is imperative to
establish an efficient procedure to account for natural emissions in setting
initial baselines and assessing progress in reducing anthropogenic pollution.
The IOC supports a process established by stakeholders that avoids case-bycase flagging of "episodes" similar to the Natural Events Policy. Instead,
a regional protocol should be developed and integrated into the monitoring
and reporting system that will reasonably quantify the natural impacts
temporally and spatially. Such a system should be flexible enough to
accommodate future technological advances in emissions and visibility
measurements and assessments.
5.
The effects of fire and air quality decisions on cultural resources.
This concern needs to be addressed in future FEJF policy and technical tools,
especially smoke management program development. In addition, the FEJF
feasibility determination guidance cited in the policy should consider the
addition of “cultural resources” as a feasibility factor for the use of
alternatives to burning and implementation of smoke management programs.
6.
The development of recommendations for smoke management programs and
smoke effects at non-mandatory Class I areas, Class I areas not originally
designated as mandatory Class I areas by Congress. There are only a few of
these in the country, and most are on tribal lands.
7.
The development of recommendations for the establishment of annual
emission goals for fire (as required under Regional Haze Rule Section 309),
including all prescribed fire. Section 309(6)(v) of the Regional Haze Rule
requires annual emission goals for fire, excluding wildfire. Although annual
emission goals under Section 309 extend to 2018, the IOC believes annual
emission goals will be needed to 2064 to attain natural conditions.
8.
The development of future policy and technical tools, to provide a
clear stepwise progression for the Classification Program Management elements
of the Policy. The progression for state or tribal programs from little or
no regulatory control to emissions tracking to management of fires for the
minimization of visibility impacts, and then implementation of Enhanced Smoke
Management Programs should be explicitly addressed.
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RECOMMENDED POLICY FOR
CATEGORIZING FIRE EMISSIONS
APPROVED BY CONSENSUS:
FIRE EMISSIONS JOINT FORUM - AUGUST 30, 2001
PREPARED BY:
NATURAL BACKGROUND TASK TEAM OF THE FIRE EMISSIONS JOINT FORUM
OCTOBER 25, 2001
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[Ed. Note: This document has been formatted
for 2-sided printing (i.e., duplex printing).]
IV-94
EXECUTIVE SUMMARY
The Western Regional Air Partnership (WRAP), as the successor to the Grand Canyon Visibility
Transport Commission (GCVTC), is charged with implementing the GCVTC Recommendations
as well as addressing broader air quality issues, such as the Regional Haze Rule. The Regional
Haze Rule (Rule), issued by the Environmental Protection Agency (EPA) in July 1999, outlines
the requirements for states and tribes to address regional haze in Federal Class I areas, and sets
the goal of reaching natural background conditions in Federal Class I areas by 2064. EPA
recognizes the WRAP as the Regional Planning Organization that is developing the guidance and
means to implement the Rule in the WRAP region.
There are a number of sources that the EPA has identified as potential contributors to natural
background conditions, one of which is fire. The Regional Haze Rule Preamble stipulates that
fire of all kinds contributes to regional haze and that fire can have both natural and humancaused sources. The Preamble further states that some fire that is human ignited may be included
in a state’s or tribe’s determination of natural background conditions.
The WRAP Fire Emissions Joint Forum (FEJF) was established to develop policy and technical
tools to address smoke effects caused by wildland and agricultural fire on public, tribal, and
private lands. Due to the limitations of the current visibility monitoring technology to determine
fire impacts, the FEJF was charged with addressing fire emissions’ contribution to natural
background conditions. The FEJF formed the Natural Background Task Team (NBTT) to
develop a methodology to categorize fire emissions as either “natural” or “anthropogenic”; thus
providing the basis for fire’s inclusion in natural background condition values and ultimately, the
tracking of reasonable progress.
This Policy has been developed over an 18-month period by the NBTT; a group made up of
state, tribal, and federal agency representatives, as well as those from industry, agriculture,
academia, and environmental organizations. During this process, the NBTT solicited public input
regarding both technical and policy issues. The resulting Recommended Policy for Categorizing
Fire Emissions was granted consensus approval by the FEJF on August 30, 2001.
The Policy is comprised of two main sections: Classification Criteria and Classification Program
Management. The Classification Criteria section determines the “natural” and “anthropogenic”
sources of fire that contribute to regional haze, as stated in the Preamble to the Rule. The
Program Management section expresses the prerequisites that enable classification to be
effective and equitable. Although the Program Management section addresses prerequisites that
need to exist, it does not describe how they will be brought about. This work is currently
underway in the FEJF as well as in other WRAP Forums.
The Classification Criteria clarify the relationship between what would be defined as a “natural”
fire emissions source and what would be defined as an “anthropogenic” fire emissions source,
thereby addressing the complex relationship EPA acknowledges in the Preamble to the Rule.
Under the Policy, most fire emissions sources are classified “anthropogenic”, which is in keeping
with the Rule’s primary objective of the development of long-term strategies for reducing
i
emissions of visibility impairing pollutants. However, some fire emissions sources are classified
as “natural” in recognition of fire’s inherent occurrence as part of the landscape.
The Program Management section supports the classification process by iterating that all types of
fires must be managed to minimize visibility impacts in order to assure equity among the
different fire source types and other air pollution sources. In cases where a fire is classified as
“anthropogenic”, its emissions will be controlled in order to demonstrate reasonable progress
toward the 2064 natural conditions goal. The Program Management section also recognizes that
to determine fire emissions’ contribution to visibility impacts, emissions from all fires will be
tracked. This across-the-board tracking is also necessary to allow the classification process to
function uniformly across the WRAP region.
Upon final approval by the WRAP, the Policy will provide states and tribes an equitable and
practical method for determining which fire emissions will be considered part of the natural
background conditions in Federal Class I areas. In so doing, the Policy will enable states and
tribes to address natural reductions of visibility from fire as well as identify those fire emissions
that need to be controlled to achieve progress toward the 2064 natural conditions goal. The FEJF
is developing policy and technical tools that will support this Policy and its implementation, such
as guidance on Enhanced Smoke Management Plan elements, recommendations for creation of
an annual emissions goal, availability and feasibility of alternatives to burning, recommendations
for managing fire emissions sources, guidance for feasibility determinations, a methodology for
tracking fire emissions, and a stepwise progression for the Program Management elements of the
Policy.
ii
TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY
i
1.
INTRODUCTION
1
1.1.
Background
1
1.2.
Context
1.2.1. Current Condition and Future Fire Emissions
1.2.2. Natural Background Conditions
1.2.3. The Classification of Fire
2
2
4
5
1.3.
Purpose
6
1.4.
Scope and Applicability
6
2.
3.
4.
CLASSIFICATION POLICY
7
2.1.
Classification Program Management
8
2.2.
Classification Criteria
8
CLASSIFICATION POLICY ANNOTATION
9
3.1.
Classification Program Management
3.1.1. Management to Minimize Visibility Impacts
3.1.2. Control Emissions from “Anthropogenic” Sources
3.1.3. Tracking Fire Emissions
9
10
11
12
3.2.
Classification Criteria
3.2.1. Prescribed Fire
3.2.2. Wildfire
3.2.3. Native American Cultural Burning
12
13
15
18
APPENDICES
19
Appendix A. Glossary
19
Appendix B. Recommendation for the Formation of an Inter-Forum Workgroup 25
Appendix C. Website References
27
iii
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iv
1. INTRODUCTION
1.1.
BACKGROUND
In 1990, Congress amended the Clean Air Act, and as part of these amendments created the
Grand Canyon Visibility Transport Commission1 (GCVTC). The GCVTC was charged with
assessing the current scientific information on visibility impacts and making recommendations
for addressing regional haze in the western United States. The GCVTC signed and submitted
more than 70 Recommendations to the Environmental Protection Agency (EPA) in a report dated
June 1996 that indicated that visibility impairment was caused by a wide variety of sources and
pollutants, and that a comprehensive strategy was needed to remedy regional haze.
The Western Regional Air Partnership (WRAP) was established in 1997 as the successor
organization to the GCVTC. The WRAP is a voluntary organization comprised of western
governors, tribal leaders and Federal agencies,2 and is charged with implementing the GCVTC
Recommendations, as well as addressing broader air quality issues, such as the Regional Haze
Rule (Rule). The WRAP is designed as a stakeholder-based organization, which uses consensus
for development of policy and technical tools. WRAP participants include state air quality
agencies, tribes, Federal/state/private land managers, the EPA, environmental groups, industry,
academia and other interested parties.
Following the issuance of the GCVTC Recommendations, the EPA issued the Regional Haze
Rule3 in July 1999 to improve visibility in 156 national parks and wilderness areas across the
country. The Rule outlines the requirements for states and tribes to address regional haze in
Federal Class I areas. EPA incorporated all of the GCVTC Recommendations into Section 309
of the Rule, which may be used by some of the WRAP states. The remaining WRAP states must
utilize the nationally applicable Section 308 provisions of the Rule.
“The State must identify all anthropogenic sources of visibility impairment considered by
the State in developing its long-term strategy. The State should consider major and minor
stationary sources, mobile sources, and area sources.”4
EPA recognizes the WRAP as the Regional Planning Organization that is developing the
necessary policy and technical tools to implement the Regional Haze Rule in the WRAP region5.
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 InterTribal Fish Commission, and the Environmental Protection Agency.
2 The WRAP members include the governors of twelve western states (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.
3 Published in the Federal Register on July 1, 1999 (64 FR 35714).
4 64 FR 35767, Regional haze program requirements §51.308(d)(3)(iv).
5 The states of AZ, CA, CO, ID, MT, ND, NM, OR, SD, UT, WA, WY and 247 tribes.
1
1.2.
CONTEXT
1.2.1. Current Condition and Future Fire Emissions
The GCVTC recognized fire (wildfire, prescribed fire and agricultural burning) as playing a
major role in ecosystem health in the West, and at the same time, contributing to regional haze.
“Emissions from fire (wildfire and prescribed fire) are an important contributor to
visibility-impairing aerosols,…Agricultural burning emissions and their effects have
[also] been identified as a concern of the GCVTC…”6
Throughout the WRAP region, fire is occurring as part of the natural landscape. Prescribed fire
is used for a wide variety of purposes on both wildlands and agricultural land in the region. In
addition, fire has been an integral part of tribal communities in their practice of religion and
traditional cultural activities. Tribal communities also utilize prescribed fire on wildlands and for
agricultural purposes.
All sources of fire can have an effect on air quality and visibility. Although there is uncertainty
as to the amount and apportionment of emissions from these sources vis-à-vis regional haze, it is
agreed that fire and its emissions contribute to regional haze.
The use of fire, as well as alternative treatments, is intended to provide more effective fire
suppression, predictable fire effects and management of air pollutant emissions.
“Prescribed fire promotes better fire control, predictable fire effects and allows for
management of emissions as compared to wildfire.”7
Despite the use of alternative treatments, it is recognized that prescribed fire use and resulting
emissions will increase on Federal, state, tribal and private land. These emissions will contribute
to regional haze. However, it is anticipated that the implementation of the Regional Haze Rule
can accommodate the increased use of fire on wildlands as well as the maintenance and
opportunity for continued use of fire in agricultural management.
Wildland
The GCVTC Recommendations indicated that wildfire and prescribed fire emissions could
potentially overwhelm the visibility effects of all other sources on an episodic basis, due to the
unnatural condition of vegetative fuel build-up, projected increased use of prescribed fire and the
current likelihood of catastrophic wildfire. This is true across all land ownership types.
6 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”), page 47.
7 GCVTC Report, page 47.
2
“In fact, land managers propose aggressive prescribed fire programs aimed at correcting
the buildup of biomass due to decades of suppression. Therefore, prescribed fire and
wildfire levels are projected to increase significantly during the studied period [19952040]. The Commission recommends the implementation of programs to minimize
emissions and visibility impacts from prescribed fire, as well as to educate the public.”8
EPA’s Interim Air Quality Policy on Wildland and Prescribed Fires was “…prepared in
response to plans by some Federal, Tribal and State wildland owners/managers to significantly
increase the use of wildland and prescribed fires to achieve resource benefits in the wildlands.”9
Under the EPA Policy, it was acknowledged that “Many wildland ecosystems are considered to
be unhealthy as a result of past management strategies…. Wildland owners/managers plan to
significantly increase their use of fires to correct these unhealthy conditions and to reduce the
risk of wildfires to public and firefighter safety.”10
Recognition of the current ecological state of the wildlands and increased wildfire severity has
led to the development of the National Fire Plan, which has begun to be addressed through recent
Federal appropriations11. It represents a long-term commitment based on cooperation and
communication among Federal agencies, states, local governments, tribes, and concerned
publics. The Federal wildland fire management agencies have worked in close consultation with
states, governors, and interested partners to prepare a collaborative ten-year strategy12 for
implementation of the National Fire Plan.
This ten-year strategy is predicated on a commitment to the reduction of hazardous fuel loads,
with current priority in the urban-interface area. Addressing the wildland fire and hazardous fuels
situation, as well as the needs to restore and maintain forest and rangeland ecosystem health and
to ensure human safety, will necessitate a range of fuel management options. The fuel
management options include mechanical, chemical, biological, and prescribed fire treatments.
The GCVTC emphasized the need for alternatives to fire in order to address regional haze
concerns and equity among the many sources of visibility impairment. The Preamble to the Rule
cites the GCVTC Recommendation of “full consideration of alternatives to fire.”13
8 GCVTC Report, page iii.
9 U.S. EPA, Office of Air Quality Planning and Standards, Interim Air Quality Policy on Wildland and Prescribed
Fires, April 23, 1998, page 1.
10 U.S. EPA, Office of Air Quality Planning and Standards, Interim Air Quality Policy on Wildland and Prescribed
Fires, April 23, 1998, page 1.
11 2001 Interior and Related Agencies Appropriations Act (Public Law 106-291), Making Appropriations for the
Department of Interior and related agencies for the fiscal year ending September 30, 2001, and for other purposes.
12 A Collaborative Approach for Reducing Wildland Fire Risks to Communities and the Environment, 10-Year
Comprehensive Strategy, August 2001.
13 64 FR 35736.
3
Agricultural Land
The Air Quality Policy on Agricultural Burning prepared by the Agricultural Air Quality Task
Force (AAQTF) asserts that “Fire has been an integral part of agricultural management as long
as man has systematically grown crops. Modern technologically based agriculture still utilizes
burning and for some crops it is the only economical means available to deal with residue.”14
Agricultural burning is utilized for a variety of purposes, the most common of which is to reduce
pre- and post-harvest vegetation that interferes with harvest, tillage or subsequent seedbed
preparation. Burning is also used for pest and weed control, as well as to reduce fire hazard from
weed infestation and clogging of ditches and irrigation canals. Tribal communities also utilize
fire for agricultural management, including weed abatement and ditch and canal clearing.
“The burning of vegetative matter associated with agricultural land management
produces a range of particulate emissions and ozone precursors. Therefore, it has the
potential to impact visibility in mandatory Class I Federal areas.”15
One of the goals of the AAQTF Policy is “to protect public health and welfare by mitigating the
impacts of air pollution emissions on air quality and visibility.”16 Toward this end, the AAQTF
Policy encourages alternatives to burning, as well as “…identifying burning methods and
determining alternative treatment strategies that can effectively reduce emissions….”17
The use of fire by agriculture is well documented. However, the extent of the fire use is not well
known in some areas, and is the cause of uncertainty as to the contribution of agricultural
burning sources on regional haze. Accordingly, the AAQTF Policy states that “…the
contribution from agriculture, specifically the impact of burning practices on regional air quality,
must be accurately assessed in relative proportion to the region’s total emissions.”18
Acknowledging this uncertainty, both the GCVTC and the Rule include agricultural burning as a
contributor to regional haze that needs to be addressed.
1.2.2. Natural Background Conditions
The Regional Haze Rule outlines the requirements for addressing regional haze in Federal Class
I park and wilderness areas, a critical element of which is the establishment of natural
background condition values. When established, these values will provide the basis by which a
state or tribe may demonstrate reasonable progress toward attaining the 2064 natural conditions
goal, as required in the Rule under both Sections 308 and 309.
14 Agricultural Air Quality Task Force, Air Quality Policy on Agricultural Burning, Recommendation to the U.S.
Department of Agriculture, November 10, 1999 (hereafter “AAQTF Air Quality Policy on Agricultural Burning”),
Section IV, A.
15 AAQTF Air Quality Policy on Agricultural Burning, Section IV, E.
16 AAQTF Air Quality Policy on Agricultural Burning, Section II.
17 AAQTF Air Quality Policy on Agricultural Burning, Section VI, B, 2.
18 AAQTF Air Quality Policy on Agricultural Burning, Section VII.
4
There are a number of sources that EPA has identified as potential contributors to natural
background conditions, one of which is fire. The determination of natural background conditions
may take into account impacts from potential natural sources of visibility impairing pollutants
such as natural vegetative hydrocarbon emissions (e.g., terpines from trees), oceanic sulfates,
natural wind suspended dust, fire, and sulfate and nitrate from volcanoes.
Due to climatic variations that affect the role of fire on the landscape, natural background
conditions are anticipated to fluctuate. The use of tree ring analysis has scientifically
demonstrated this phenomenon. For example, an increase of fire scars is indicative of higher fire
occurrence during times of drought. To this end, climatic changes will have a direct effect on the
variability of natural background conditions as influenced by fire.
The Regional Haze Rule Preamble stipulates that fire of all kinds contributes to regional haze
and that fire can have both natural and human-caused sources. The Preamble further states that
some fire that is human ignited may be included in a state’s or tribe’s determination of natural
background conditions.
“EPA believes that States [and Tribes] must take into account the degree to which fire
emissions cause or contribute to ‘manmade’ visibility impairment and its contribution to
natural background conditions.”19
To address the implementation of specific sections of the Rule, the WRAP has established
several committees and forums. The Ambient Air Monitoring & Reporting Forum (AMRF) is
working to develop guidance on the determination of natural background, taking into
consideration emissions that can result in a natural reduction of visibility. The Fire Emissions
Joint Forum (FEJF) is addressing both policy and technical issues concerning smoke effects that
are caused by wildland and agricultural fire on public, tribal and private lands.
The AMRF will analyze the Interagency Monitoring of Protected Visual Environments
(IMPROVE) visibility monitoring data to establish a baseline, current conditions, and track
reasonable progress toward the 2064 natural conditions goal, as required in the Rule. Organic
carbon aerosol, as monitored by IMPROVE, is a significant contributor to regional haze in the
WRAP region. The current monitoring technology is unable to identify the source of organic
carbon aerosol monitored at Federal Class I areas, of which fire has been acknowledged as a
major source. As technology and science develops, with regard to the ability to differentiate fire
impacts as compared to other sources for the purposes of tracking reasonable progress toward the
2064 natural conditions goal, the needs and methods of tracking are anticipated to change.
1.2.3. The Classification of Fire
Due to the limitations of the current monitoring technology, the AMRF requested that the FEJF
work on determining the classification of fire emissions as either “natural” or “anthropogenic”.
This classification will be an important component for fire’s inclusion in natural background
condition values and ultimately, the tracking of reasonable progress. The Natural Background
Task Team (NBTT) was created by the FEJF to assist in this effort.
19 64 FR 35735.
5
This Policy was developed through a broad, multi-stakeholder-based public review process that
included two workshops designed to gather both technical and policy input. The review process
included direct input from the FEJF, WRAP, and other parties. The NBTT has submitted
progress reports as well as work products to the FEJF for input and approval. The Policy is a
work product of the FEJF for the WRAP.
1.3.
PURPOSE
“The EPA also recognizes that fire of all kinds (wildfire, prescribed fire, etc.) contributes
to regional haze, and that there is a complex relationship between what is considered a
natural source of fire versus a human-caused source of fire.”20
This Policy, developed under the WRAP, will aid states and tribes in determining which fire
emissions will be considered as part of the natural background conditions in Federal Class I
areas. The remaining fire emissions will be considered “anthropogenic” and, as such, subject to
reasonable progress requirements of the Rule. This Policy clarifies the relationship between what
would be defined as a “natural” fire emissions source and what would be defined as an
“anthropogenic” fire emissions source, thereby addressing the complex relationship EPA
acknowledges in the Preamble to the Rule.
Under this Policy, fire emissions sources are, for the most part, classified as “anthropogenic”.
These sources will be controlled to the maximum extent feasible, which is in keeping with the
Rule’s primary objective of the development of long-term strategies for reducing emissions of
visibility impairing pollutants. Additionally, the “anthropogenic” classification recognizes that
there is potential to control the emissions from most fires, as acknowledged in the GCVTC
Recommendations, the Regional Haze Rule, and the stakeholder participation process.
Some fire emissions sources have been classified as “natural”, and, like “anthropogenic” sources,
will be managed to minimize potential air quality impacts. The rationale for “natural”
classifications is clearly stated in the annotated sections, and reflects the reasoning of the
GCVTC, the Rule, stakeholder input, as well as current smoke management capabilities.
Furthermore, both the management of “natural” source emissions, and the management and
control of “anthropogenic” source emissions represent key points of convergence among
stakeholders that are fundamental to the development of this Policy.
1.4.
SCOPE AND APPLICABILITY
This Policy exclusively addresses the effects of fire emissions in terms of visibility and the
requirements of the Regional Haze Rule. It does not address potential natural sources of
visibility reducing pollutants such as natural vegetative hydrocarbon emissions (e.g., terpines
from trees), oceanic sulfates, natural wind suspended dust, and sulfate and nitrate from
volcanoes. Air pollutant emissions from fires may also impact public health and cause nuisance
smoke intrusions. This Policy may strengthen processes and current systems in place that
address these smoke concerns; however, this specific interaction is being addressed through
further recommendations by the FEJF.
20 64 FR 35735.
6
“All types of fire (prescribed fire and agricultural burning) must be addressed equitably
as part of a visibility protection strategy.”21
This Policy applies to both wildland and agricultural lands regardless of ownership (i.e., Federal,
state, tribal, public, private), cause of ignition (e.g., lightning, arson, accidental human, land
management practices) or purpose of the fire (e.g., vegetative residue disposal, hazard reduction,
maintain ecosystem health). It is the intent that this Policy be applied equitably across all land
types and sources.
This Policy does not apply to other open burning activities on residential, commercial, or
industrial property (e.g., backyard burning, garbage incineration, residential wood combustion,
construction debris). This Policy does not apply to Native American cultural non-vegetative
burning for traditional, religious or ceremonial purposes (e.g., cremation, sweat lodge fires).
This Policy applies to impacts on Federal Class I areas in the WRAP region. Emissions from all
fire (wildland and agricultural) are to be accounted for in both Sections 308 and 309 of the Rule.
Stakeholder input advocated a consistent consideration of fire utilizing either Section 308 or 309
of the Rule. This input was a guiding principle for the development of this Policy. States and
tribes in the WRAP region are anticipated to incorporate this Policy into the technical support
documentation for a State or Tribal Implementation Plan (SIP/TIP) submitted to EPA in order to
meet the requirements of the Rule.
The categorization of fire emissions, as established by the Policy, will facilitate the establishment
of natural background condition values and ultimately, the tracking of reasonable progress for a
SIP or TIP. As the SIPs/TIPs will be revisited and revised, per the schedule specified in the
Rule, there will be opportunities to refine this Policy to reflect scientific advances and/or policy
changes.
2. CLASSIFICATION POLICY
The Classification Policy is made up of six statements, three of which address the program
management of classification, and three that address the criteria for the classification of fire
emission sources. The Classification Criteria statements of the Policy determine the “natural”
and “anthropogenic” sources of fire that contribute to regional haze, as stated in the Preamble to
the Rule. The Classification Program Management statements express the requirements that
enable classification to be effective and equitable. The Program Management statements adhere
to the findings and Recommendations of the GCVTC related to fire and fire emissions, as well as
the reasoning expressed in the Rule.
The Classification Program Management statements express requirements that need to exist but
do not attempt to describe how they will be brought about (e.g., the development of requirements
for a tracking system or smoke management program). That work is currently underway in the
FEJF as well as other WRAP Forums.
21 GCVTC Report, page 47.
7
The classification of fire emissions is predicated on the distinction between a “natural” emissions
source classification and an “anthropogenic” emissions source classification, the definitions of
which follow.
Natural Emissions Source Classification (“natural”) - A categorization that designates
which fire emissions can result in a natural reduction of visibility for each Federal Class I
area in the WRAP region. This classification includes natural and human-caused
ignitions.
Anthropogenic Emissions Source Classification (“anthropogenic”) - A categorization that
designates which fire emissions contribute to visibility impairment in a Federal Class I
area. “Anthropogenic” emissions must be controlled to achieve progress toward the 2064
natural conditions goal for each Federal Class I area in the WRAP region. This
classification includes natural and human-caused ignitions.
The following Classification Program Management and Classification Criteria statements apply
to both wildland and agricultural lands regardless of ownership, cause of ignition, or purpose of
the fire within the WRAP region.
2.1.
CLASSIFICATION PROGRAM MANAGEMENT
G. All fires must be managed to minimize visibility impacts.
H. All emissions from fires classified as an “anthropogenic” source will be controlled to the
maximum extent feasible subject to economic, safety, technical and environmental
considerations.
I. Emissions from all fire will be tracked.
2.2.
CLASSIFICATION CRITERIA
G. Prescribed Fire is an “anthropogenic” source, except where it is utilized to maintain an
ecosystem that is currently in an ecologically functional and fire resilient condition, in which
case it is classified as a “natural” source.
H. Wildfire that is suppressed by management action is a “natural” source. Wildfire, when
suppression is limited for safety, economic, or resource limitations, remains a “natural”
source. Wildfires managed for resource objectives are classified the same as prescribed fires.
I. Native American cultural burning for traditional, religious, and ceremonial purposes is a
“natural” source.
8
3. CLASSIFICATION POLICY ANNOTATION
3.1.
CLASSIFICATION PROGRAM MANAGEMENT
The following sections provide clarifying and supporting information regarding each of the three
Classification Program Management statements from Section 2 above. The three Program
Management statements apply to both wildland and agricultural lands regardless of ownership,
cause of ignition, or purpose of the fire within the WRAP region.
The Classification Program Management statements express the management elements that
enable classification of fire emissions sources to be effective and equitable. The Program
Management statements adhere to the findings and Recommendations of the GCVTC related to
fire and fire emissions, as well as to the reasoning expressed in the Rule.
The Rule requires that states, “…must consider, at a minimum, the following factors in
developing its long-term strategy: (E) Smoke management techniques for agricultural and
forestry management purposes including plans as currently exist within the State for these
purposes;”22
However, there are currently vast differences in smoke management programs, use of emissions
reduction practices, and approaches to addressing the visibility effects of fire across the WRAP
region. These differences may include state legislative requirements or those of tribal
government that exist in the implementation of some of the program management elements.
Generally, most current smoke management programs address only public health and nuisance
concerns, and do not address all the potential visibility-impacting fire emissions sources, nor do
they have procedures to address minimization of visibility impacts.
In recognition of this, the FEJF is working to insure that the policy and program management
recommendations that the Forum develops are implemented through the WRAP in a progressive
manner. The first step for implementation of this Policy is to develop emissions tracking,
followed by the management of fires for the minimization of visibility impacts, and then
followed by potential implementation of Enhanced Smoke Management Programs (ESMP). The
timeframe for implementation of this Policy will be affected by a state’s or tribe’s current
approach to address smoke effects.
22 64 FR 35767, Regional haze program requirements §51.308(d)(3)(v)(E).
9
3.1.1. Management to Minimize Visibility Impacts
Statement: All fires must be managed to minimize visibility impacts.
“All types of fire (prescribed fire and agricultural burning) must be addressed equitably
as part of the visibility protection strategy.”23
“The [implementation] plan must provide for: (i) 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….”24
This Policy statement addresses the pressing need that all fires, regardless of subsequent
classification as “natural” or “anthropogenic”, must be managed to minimize their impacts on
visibility in Federal Class I areas, in addition to public health and nuisance concerns. This
concept is recognized in both the GCVTC Recommendations and in the Regional Haze Rule.
This Policy statement was also supported by both stakeholder input and by the WRAP as critical
to achieving equity among fire emissions sources and other types of air pollution sources.
Some stakeholders, however, did express concern that air quality considerations would prove
difficult to apply to wildfires under suppression, since they are managed with firefighter and
public safety and protection of property and resources as primary criteria for strategic decisionmaking. It should be noted that consideration of air quality is already required on Federal lands25
during the evaluation of alternate fire management strategies and, under this Policy, will need to
be considered regardless of land ownership. However, air quality considerations are just one of
several important criteria that are weighed according to positive, neutral, or negative effects and
evaluated to select the appropriate management response to the wildfire.
It should be emphasized that the ability to control the emissions from wildfires under suppression
can be limited. Therefore, these emissions cannot be incorporated into the demonstration of
reasonable progress toward the 2064 natural conditions goal, and as a result, are classified as
“natural”.
Management of all fire emissions to minimize visibility impacts must include, but is not limited
to, concepts such as the timing of ignitions for better dispersion and consideration of downwind
air quality and visibility. It may also include the use of best management practices, such as the
use of alternatives, biomass utilization, and other emission reduction techniques. Responsibility
for the utilization of fire emissions management techniques resides with the person(s) or entity
that initiates a fire or manages the land where fire occurs. Due to economic, safety, technical and
environmental considerations, the use of some of the management techniques may not be
feasible. The FEJF is developing recommendations for managing fire emissions sources with the
goal of minimizing visibility impacts.
23 GCVTC Report, page 47.
24 64 FR 35771, Requirements related to the Grand Canyon Visibility Transport Commission §51.309(d)(6)(i).
25 Wildland Fire Situation Analysis (WFSA).
10
3.1.2. Control Emissions from “Anthropogenic” Sources
Statement: All emissions from fires classified as an “anthropogenic” source will be
controlled to the maximum extent feasible, subject to economic, safety, technical and
environmental considerations.
The Anthropogenic Emissions Source Classification is a categorization that designates which fire
emissions may contribute to visibility impairment and therefore, must demonstrate reasonable
progress toward the 2064 natural conditions goal for each Federal Class I area in the WRAP
Region. This classification includes natural and human-caused ignitions.
The “anthropogenic” classification recognizes the fact that there is potential for most fires to
have emission controls (e.g., use of alternatives or emission reduction practices), in addition to
being managed to minimize visibility impacts as discussed above. Per the GCVTC
Recommendations, economic, safety, technical and environmental considerations are part of the
application of emission controls for the implementation of this Policy statement. Due to these
considerations, the control of emissions from some fire types may not be feasible, which will be
determined by the land manager in collaboration with the applicable air quality regulatory
authority. The FEJF is developing guidance for feasibility (i.e., economic, safety, technical and
environmental considerations) determinations.
“The [implementation] plan must provide for: (v) Establishment of annual emission goals
for fire, excluding wildfire, that will minimize emission increases from fire to the
maximum extent feasible and that are established in cooperation with States, tribes,
Federal land management agencies, and private entities.”26
The control of these anthropogenic sources to ensure visibility goals are attained will be
accomplished by the establishment of annual emissions goals and, if applicable, by using an
Enhanced Smoke Management Program (ESMP), as stated in the Regional Haze Rule. The FEJF
is developing recommendations for the WRAP for the ESMP and how an annual emissions goal
may be created.
The application of emissions reduction techniques and use of alternatives to burning subject to
economic, safety, technical and environmental feasibility criteria would be utilized in order to
meet the control objectives for fire emissions sources classified as “anthropogenic”. These
programs and techniques are further supported by the Regional Haze Rule.27 The FEJF is
assessing the availability and feasibility of alternatives to burning for both wildlands and
agricultural lands.
26 64 FR 35771, Requirements related to the Grand Canyon Visibility Transport Commission §51.309(d)(6)(v).
27 64 FR 35767, Regional haze program requirements §51.308(d)(3)(v)(E).
64 FR 35771, Requirements related to the Grand Canyon Visibility Transport Commission §51.309(d)(6).
11
3.1.3. Tracking Fire Emissions
Statement: Emissions from all fire will be tracked.
In order to determine fire’s contribution to natural background visibility conditions and
anthropogenic visibility impairment, all fire emissions sources, regardless of ownership or land
use type, need to be tracked across the WRAP region. The GCVTC Recommendations,
committed to by the western Governors in 1996, and the subsequent 1999 Regional Haze Rule,
both establish the need and requirement for the tracking of emissions for all fire emissions
sources.
“Implement an emissions tracking system for all fire activities.”28
“The [implementation] plan must provide for: (ii) A statewide inventory and emission
tracking system (spatial and temporal) of VOC, NOx, elemental and organic carbon, and
fire particle emissions from fire….”29
Emissions from all fires will be tracked for two purposes, to classify the fire as “natural” or
“anthropogenic”, and, if “anthropogenic”, to facilitate the demonstration of reasonable progress
toward the 2064 natural conditions goal. The use of alternatives and emission reduction practices
needs to be in a fire emissions tracking system for the demonstration of reasonable progress and
annual emissions goal accounting process. The FEJF will be developing recommendations on the
parameters that will need to be tracked and for what source size.
3.2.
CLASSIFICATION CRITERIA
The following sections provide clarifying and supporting information regarding each of the three
Classification Criteria statements from Section 2 above. The three Criteria statements apply to
both wildland and agricultural lands regardless of ownership, cause of ignition, or purpose of the
fire within the WRAP region.
For the most part, fire emissions sources are classified “anthropogenic”. The “anthropogenic”
classification recognizes that there is potential to control the emissions from most fires, as
acknowledged in the GCVTC Recommendations, the Regional Haze Rule, and the stakeholder
participation process. Some fire emissions sources have been classified as “natural”, and, like
“anthropogenic” sources, will be managed to minimize potential air quality impacts. The
rationale for “natural” classifications is clearly stated in the following annotated sections, and
reflects the reasoning of the GCVTC, the Rule, stakeholder input, as well as current smoke
management capabilities.
For the categorization of fire emissions to function appropriately, the person(s) or entity that
initiates a fire or manages the land where fire occurs is responsible for determining the
classification using this Policy, with oversight by the applicable air quality regulatory authority.
28 GCVTC Report, page 48.
29 64 FR 35771, Requirements related to the Grand Canyon Visibility Transport Commission §51.309(d)(6)(ii).
12
3.2.1. Prescribed Fire
Statement: Prescribed Fire is an “anthropogenic” source, except where it is utilized
to maintain an ecosystem that is currently in an ecologically functional and fire
resilient condition, in which case it is classified as a “natural” source.
A prescribed fire is any fire ignited by a planned management action to meet specific objectives
on agricultural land or wildland, regardless of land ownership. Prescribed fires may have various
purposes including, but not limited to, vegetative residue disposal, pest and disease control, yield
improvement, ecosystem restoration, ecosystem maintenance, and hazardous fuel reduction.
Often, prescribed fire will meet multiple objectives. It is the intent of this Policy that the fire’s
classification will be determined based on the primary and predominant purpose for the fire.
This portion of the Policy also applies to wildfires managed for resource objectives, as addressed
by Classification Criteria statement B.
Ecosystem Maintenance
“…EPA believes States should be permitted to consider some amount of fire in the
calculation [of natural background] to reflect the fact that some prescribed fire effects
serve merely to offset what would be expected to occur naturally.”30
The primary distinction in classifying prescribed fire is between ecosystem restoration and
maintenance. Only prescribed fire used to maintain an ecosystem is classified as “natural”. All
other prescribed fire, including restoration of ecosystems, is classified as “anthropogenic”. This
distinction was based on stakeholder input as a key to agreement on the development of this
Policy, and reflects the reasoning of both the Regional Haze Rule Preamble and the GCVTC
Recommendations.
“Fire has played a major role in the development and maintenance of most ecosystems in
the West. The long-term future of the West is dependent on healthy ecosystems that are
capable of sustaining natural processes and human uses. ... Fire is an essential component
of most natural ecosystems, and perpetuation of fire at a level required to maintain
ecosystem processes is necessary.”31
30 64 FR 37535-35736.
31 GCVTC Report, page 47.
13
Ecosystem maintenance prescribed fires are beneficial to natural ecosystems that are resilient to
the application of fire.32 Further, these areas are free from excess fuel generated through past
land management decisions. Where fire is used to mimic the natural process, that fire is
classified “natural”, which recognizes that these fires have the opportunity for smoke
management. Additionally, stakeholder input recognized that imitating the natural process with
prescribed fires for ecosystem maintenance produces emissions comparable to those that would
occur naturally. This fire type predominantly occurs on wildland and may also occur on lands in
the USDA Conservation Reserve Program.
It should be noted that the science of determining a fully functional and fire resilient ecosystem
is continually evolving. It is the intent of this Policy to accommodate future changes in the
understanding and subsequent determination of the broad range of ecosystems.
A “natural” classification may only be assigned to a prescribed fire when the person(s) or entity
that initiates the prescribed fire determines that the fire is in an area identified as being in an
ecologically functional and fire resilient condition.33 Further, the “natural” classification will
only hold if maintenance of the area’s ecosystem is the primary and predominant purpose of the
burn. This classification will be made with oversight by the applicable air quality regulatory
authority.
Ecosystem Restoration & Prescribed Fire for Other Purposes
“The EPA recognizes the natural role of fire in forest ecosystems, and the fact that forest
fuels have built up over many years due to past management practices designed to protect
public health and safety through fire suppression. Research has shown that these practices
have led to an increased risk of catastrophic wildfire as well as reduced forest health. In
response to this situation, the Federal land management agencies, as well as some States
and private landowners, have recommended the increased use of prescribed fire in order
to return certain forest ecosystems to a more natural fire cycle and to reduce the risk of
adverse health and environmental impacts due to catastrophic wildfire.”34
Ecosystem restoration is the re-establishment of natural vegetation and may be accomplished
through the reduction of unwanted and/or unnatural levels of biomass, which may have
accumulated due to management action (e.g., long-term wildland fire suppression or hazardous
fuel treatment). Multiple prescribed fires and mechanical treatments may be necessary to restore
an ecosystem to an ecologically functional and fire resilient condition. Ecosystem restoration
may also be used to control undesirable plant species.35 All burning for ecosystem restoration
purposes is classified as “anthropogenic”.
32 For example, in a big sage and grass ecosystem, diversity of species and age class is required for the fire to be
classified as maintenance burn.
33 Currently, there is an assessment of condition classes for wildlands at the national programmatic level, as defined
in the National Fire Plan and the Cohesive Strategies for the USDA-Forest Service and Department of Interior. More
refined planning, to determine both fire’s role and application, will be done at the land-use planning level or sitespecific level. The programmatic assessment will help land managers at the local level in defining those ecosystems
that are in a condition where burning can be classified as “natural”.
34 64 FR 35735.
35 For example, in the Great Basin, prescribed fire used in conjunction with an application of herbicide followed by
14
Prescribed fire may be utilized for purposes other than ecosystem restoration and maintenance. It
may be conducted for the purpose of vegetative residue disposal (e.g., timber slash or wheat
stubble burning). Prescribed fire may be used to increase or maintain agricultural and
silvicultural output or forage values.36 Fires may also be utilized to control weeds, pests, and
diseases, and improve yield (e.g., grass and rice field burning). Hazard reduction burning may be
conducted in areas of accumulated wildland fuels to reduce the risk of wildfire.37 Prescribed fires
that are initiated for special interests such as wildlife, recreation, range, water, or other resources
also fit into this other prescribed fire category.38
Key to the categorization of other prescribed fire (except ecosystem maintenance) as an
“anthropogenic” source, is the recognition that there is potential to control the emissions from
most fires, in addition to smoke management. Stakeholders additionally recognized that these
fires, in most cases, could produce emissions greater than what could be anticipated to occur
naturally.
3.2.2. Wildfire
Statement: Wildfire that is suppressed by management action is a “natural” source.
Wildfire, when suppression is limited for safety, economic, or suppression resource
limitations, remains a “natural” source. Wildfires managed for resource objectives
are classified the same as prescribed fires.
A wildfire is any unwanted, non-structural fire that can occur on wildlands, where there may be
few scattered structures, or agricultural lands. Unwanted wildfires can be ignited by both natural
causes such as lightning or human causes such as accidental human ignitions, escaped prescribed
fires, or arson. Examples of accidental human ignitions include fireworks, cigarettes, escaped
campfires, vehicle fires, and fires from farm machinery. Arson is defined as the intentional start
of a fire with the intent to either maliciously or fraudulently damage property of one’s own or
that of another.
Wildfires may be suppressed by management action, or they may be managed for resource
objectives through the rejection of the suppression option or application of limited suppression.
reseeding is proving to be successful in reducing the spread of cheatgrass (an invasive Mediterranean annual grass),
which burns at a much higher frequency than the natural vegetation.
36 For example, periodic burning is utilized to improve forage quality on rangelands for livestock or wildlife.
37 For example, in the wildland/urban interface a prescribed fire in Ponderosa Pine may be ignited during the fall to
consume an over-accumulation of undergrowth that, if left untreated, would provide a “ladder” for fire to reach the
crowns of the trees.
38 Several examples follow: 1) To protect a watershed, prescribed fire can be used to create a mosaic of age classes
in many vegetation types each having a different flammability, reducing the likelihood that an entire watershed will
all burn at the same time. 2) Brush or forest fuels may be burned to improve a scenic vista. 3) A prescribed fire may
be utilized to improve forage and/or habitat that will increase hunting opportunities.
15
Suppressed by Management Action
Wildfires that are under suppression are unwanted, non-structural fires that are being actively
suppressed due to threats to public health and safety, firefighter safety, or damage to property
and/or resources (e.g., South Canyon wildfire of 1994 in Colorado or Oakland Hills wildfire of
1991 in California). The term “management action” denotes the overriding intent to suppress
(i.e., control) the unwanted wildfire due to the considerations expressed above.
The ability to control the emissions from wildfires under suppression is limited, which was the
underlying principle for the inclusion of this source in the “natural” classification. Further, the
fact that, in most instances, everything possible is being done to suppress the fire safely and
economically also supported a “natural” source classification.
In the evaluation of alternative wildfire management strategies, several constraints are
considered in selecting the appropriate management action. These constraints may include
firefighter and public safety, risk to property, available firefighting resources, and others, such as
air quality considerations. In some instances, suppression efforts for a wildfire may be limited
due to safety, economic or suppression resource limitations (e.g., equipment or personnel), as
was the case in Montana during the wildfires of 2000 when the need exceeded the available
resources. In these cases, the wildfire is classified as “natural”.
On Federal lands39, one of the constraints already under consideration during the evaluation of
alternate fire management strategies is air quality. Air quality will need to be considered on all
lands, regardless of ownership. However, air quality considerations are just one of several
important criteria, such as firefighter and public safety and protection of property and resources,
that are weighed according to positive, neutral, or negative effects, and evaluated to select the
appropriate management response to the wildfire.
The potential is high for significant visibility impacts from episodic wildfires under suppression,
as demonstrated by recent wildfire seasons (i.e., 1996 and 2000). During the development of this
Policy, stakeholders expressed concern that the visibility improvements resulting from emissions
reduction programs for industrial, mobile, and other anthropogenic sources may be masked by
visibility impacts from wildfires under suppression. This Policy contains a recommendation in
Appendix B that a workgroup be formed to study the effects from unwanted wildfire events and
consider the development of an approach similar to that of EPA’s Natural Events Policy for
visibility data.
Managed for Resource Objectives
The key distinction between wildfires suppressed by management action and wildfires managed
for resource objectives is the conscious management decision to allow these incidents to grow
toward the achievement of specific resource benefits.
39 Wildland Fire Situation Analysis (WFSA).
16
Wildland Fire Managed for Resource Benefits, Prescribed Natural Fire, and Wildland Fire Use
are all terms that have current use in regulations and policies, and are considered to be
synonymous. These terms refer to the management of wildland fires to accomplish specific, prestated resource management objectives in predefined geographic areas, under pre-determined
conditions (e.g., weather, firefighting resources available, etc.) as outlined in an approved fire
management plan or as applied on non-Federal land in the field without a plan.40
At present, these types of fires occur primarily on federally managed lands. It is possible that in
the future, state, tribal, municipal, or private landowners may choose to utilize the same
management response, with or without a plan in place.
The underlying principle guiding the classification of these fires is the potential for emissions
management and/or control, which is the same as that of prescribed fires. The classification in
these instances, just like prescribed fire, is based on the ecological condition of the land.
Therefore, a wildfire managed for resource objectives will be treated as a prescribed fire and
classified according to the same criteria.
Escaped Prescribed Fire
It is estimated that more than 99 percent of the prescribed fires in the WRAP region are
accomplished with few or no control problems, i.e., do not escape. An escaped prescribed fire is
any fire ignited by management actions on wildland or agricultural land to meet specific
objectives, that goes out of prescription (e.g., fire intensity greater than specified in a pre-set fire
plan, pre-set wind speeds exceeded, fire jumps pre-established boundaries, etc.) in a predefined
geographic area. For example, the Cerro Grande fire of 2000 in New Mexico was an escaped
prescribed fire. An escaped prescribed fire can no longer accomplish the land and resource
management objective of the prescribed fire when it goes out of prescription.
The few prescribed fires that do escape become wildfires, and require appropriate suppression
action by the land manager. The underlying principle guiding the classification of these fires is
the recognition that the ability to control the emissions from escaped prescribed fires is limited,
which is the same as that of wildfires under suppression. Therefore, an escaped prescribed fire
will be treated as a wildfire under suppression.
The EPA Interim Air Quality Policy on Wildland and Prescribed Fires should be consulted for
these escaped prescribed fire incidents.
40 For example, a wildfire that starts in a wilderness area, where the ecosystem is currently in an ecologically
functional and fire resilient condition and there is little or no threat to life or property, can be allowed to play its
natural role as outlined in an approved fire management plan.
17
3.2.3. Native American Cultural Burning
Statement: Native American cultural burning for traditional, religious, and
ceremonial purposes is a “natural” source.
This Classification Criteria statement applies to vegetative burning conducted by Native
Americans for traditional, religious and ceremonial purposes. The purposes of burning may
include, but are not limited to, burning grasslands and forestlands for basket materials (e.g.,
hazel, bear grass, tule, and iris), medicinal and ceremonial plants, and subsistence plants (e.g.,
acorns, huckleberry, and pine nuts). Where fire is used for traditional, religious or ceremonial
purposes, that fire is classified as “natural”, which recognizes that these fires have the
opportunity for smoke management. Individual tribal governments may establish the vegetative
burning that falls into this categorization.
This Policy makes a distinction between traditional, religious and ceremonial vegetative burning
purposes and other non-vegetative burning activities. This Policy does not apply to Native
American cultural non-vegetative burning for traditional, religious or ceremonial purposes (e.g.,
cremation, sweat lodge fires). Individual tribal governments may identify these purposes of
burning by resolution, rule or ordinance for traditional, ceremonial or religious use. Native
American cultural non-vegetative burns will not be tracked or considered in the establishment of
either natural background conditions nor toward the reasonable progress requirements of the
Regional Haze Rule.
A “natural” classification may be assigned to a Native American cultural burn when the
person(s) or entity that initiates the vegetative burn determines, with oversight by the designated
tribal air quality regulatory authority or EPA, that the fire has been established by the tribal
government for a traditional, religious, or ceremonial purpose. All other Native American
vegetative burning is prescribed fire and will be classified accordingly. The categorization
distinction within Native American fire (i.e., vegetative burning for traditional, religious, and
ceremonial purposes vs. prescribed fire) was based on recognition of certain traditions specific to
the Native American culture.
18
4. APPENDICES
APPENDIX A.
GLOSSARY
This glossary is intended to provide readers with several operating definitions to facilitate a
consistent review of this Policy. However, this glossary is not intended to be a complete list of
all terms and acronyms.
2064 Natural Conditions Goal - The ultimate goal of the regional haze program is the absence of
visibility impairment due to human-caused emissions.
AAQTF - Agricultural Air Quality Task Force. A task force to address agricultural air quality
issues established by the Chief of the Natural Resources Conservation Service.
Accidental Human Ignition - An unintentional random event. (E.g., Fire ignited by a cigarette
butt, an escaped campfire, or a combine.)
Agricultural Fire/Burning* - Any fire ignited by management actions to meet specific objectives
(i.e., managed to achieve resource benefits) on agricultural land.
Agricultural Land* - Agricultural land includes croplands, pasture, and other lands on which
crops or livestock are produced (PL 104-127, Section 1240A). Rangeland will be included
with wildland for the purposes of the Fire Emissions Joint Forum work.
AMRF - Ambient Air Monitoring and Reporting Forum. The Ambient Air Monitoring and
Reporting Forum was established to make recommendations to the Western Regional Air
Partnership with regard to appropriate approaches for collection, use, and reporting of
ambient air quality and meteorological monitoring data as needed to further the overall
goals of the Western Regional Air Partnership.
Anthropogenic Emissions Source Classification (“anthropogenic”) - A categorization that
designates which fire emissions contribute to visibility impairment in a Federal Class I
area. “Anthropogenic” emissions must be controlled to achieve progress toward the 2064
natural conditions goal for each Federal Class I area in the WRAP region. This
classification includes natural and human-caused ignitions.
Arson - The intentional, malicious or fraudulent ignition of a fire or explosion that damages
property of the arsonist or another. (E.g., A fire intentionally ignited to accrue ill-gotten
gains, such as from an insurance settlement, or a fire intentionally ignited as retribution
against a land manager.)
* Operating Definitions from Section 1.1 of the WRAP FEJF Workplan dated February 25, 1999.
19
Control of Fire - The controllability of a fire is dictated by a variety of considerations such as fire
fighter and public safety, risk to property and resources, fire fighting resources available,
land management objectives, and environmental, social, economic, and political
constraints. The environmental and social constraints include, among other things, how
air quality and/or visibility will be affected at sensitive receptors. Control of fire is
analogous to full suppression by management action.
Control of Fire Emissions - Actions may be taken to control fire emissions by utilizing best
management practices such as the use of alternatives, biomass utilization, and other
emission reduction techniques.
Ecosystem Maintenance - 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.
Ecosystem Restoration - The re-establishment of natural vegetation that may be accomplished
through the reduction of unwanted and/or unnatural levels of biomass, which may have
accumulated due to management action. Prescribed fires, wildfires managed for resource
benefits and mechanical treatments may be utilized to restore an ecosystem to an
ecologically functional and fire resilient condition.
EPA - United States Environmental Protection Agency
Escaped Prescribed Fire - Any fire ignited by management actions on wildland or agricultural
land to meet specific objectives that goes out of prescription (e.g., fire intensity greater
than specified in a pre-set fire plan, pre-set wind speeds exceeded, fire jumps preestablished boundaries, etc.) in a predefined geographic area.
Federal Class I area - In 1977, Congress identified 156 national parks, wilderness areas,
international parks and other areas that were to receive the most stringent protection from
increases in air pollution. It also set a visibility goal for these areas to protect them from
future human-caused haze, and to eliminate existing human-caused haze, and required
reasonable progress toward that goal.
FEJF - Fire Emissions Joint Forum. The Fire Emissions Joint Forum’s mission is to address both
policy and technical issues while developing programs and tools relating to prescribed
fire and air quality for the Western Regional Air Partnership and related Western
Regional Air Partnership forums.
Fire* - When this term appears, it refers inclusively to wildfire, prescribed natural fire/wildland
fire managed for resource benefits, prescribed fire, rangeland fire, and agricultural fire.
* Operating Definitions from Section 1.1 of the WRAP FEJF Workplan dated February 25, 1999.
20
GCVTC - Grand Canyon Visibility Transport Commission. The GCVTC was authorized under
Section 169B(f) of the Clean Air Act and 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. The Commission was established to recommend methods to preserve
and improve visibility on the Colorado Plateau, and submitted Recommendations to EPA
in June 1996.
Hazard Reduction - Burning of accumulated wildland fuels to reduce the risk of wildfire. (E.g.,
Wildland/urban interface burning or burning in areas of especially combustible fuels.)
IMPROVE - Interagency Monitoring of Protected Visual Environments. A cooperative visibility
monitoring effort, using a common set of standards across the United States, between the
EPA, Federal land management agencies, and state air agencies.
Land Managers* - When this term appears, it refers inclusively to Federal, state, tribal, and
private land managers.
Manage Fire Emissions - Actions may be taken to manage fire emissions to minimize impacts on
visibility, public health, and nuisance concerns. Some management actions include
concepts such as the timing of ignitions for better dispersion and consideration of
downwind air quality and visibility. It may also include consideration of factors related to
the area to be burned such as the fuel moisture condition and other physical parameters.
Manage fire emissions is analogous to smoke management.
NAAQS – National Ambient Air Quality Standards
Natural Background Condition - An estimate of the visibility conditions at each Federal Class I
area that would exist in the absence of human-caused impairment.
Natural Emissions Source Classification (“natural”) - A categorization that designates which fire
emissions can result in a natural reduction of visibility for each Federal Class I area in the
WRAP region. This classification includes natural and human-caused ignitions.
Natural Ignition - Fire/Burn ignited due to a natural (i.e., non-human-caused) event. (E.g., Fire
ignited by lightning or volcanic eruption.)
NBTT - Natural Background Task Team. A task team of the Fire Emissions Joint Forum
working on determining the classification of fire emissions as either “natural” or
“anthropogenic”. Team members include Forum and non-Forum members with special
expertise.
* Operating Definitions from Section 1.1 of the WRAP FEJF Workplan dated February 25, 1999.
21
Non-Vegetative Burning - Burning of fuel that is not composed of vegetation (i.e., plants or plant
growth). (E.g., Cremation or sweat lodge fires.)
Organic Carbon - Complex carbon-containing compounds often emitted by plants and from
many human activities.
Pasture Land - Grazing lands comprised of introduced or domesticated native forage species that
are used primarily for the production of livestock. They receive periodic renovation
and/or cultural treatments such as tillage, fertilization, mowing, weed control, and may be
irrigated. They are not in rotation with crops (Natural Resources Conservation Service
National Range and Pasture Handbook, 1997.)
Prescribed Fire* - Any fire ignited by management actions to meet specific objectives (i.e.,
managed to achieve resource benefits).
Rangeland - Land on which the historic climax plant community is predominantly grasses, grasslike plants, forbs, or shrubs. Includes lands re-vegetated naturally or artificially when
routine management of that vegetation is accomplished mainly through manipulation of
ecological principles. Rangeland includes natural grasslands, savannas, shrublands, most
deserts, tundra, alpine communities, coastal marshes and wet meadows (Natural
Resources Conservation Service National Range and Pasture Handbook, 1997.)
Regional Planning Organization - An organization that will first evaluate technical information
on regional haze and related issues to better understand how their states and tribes impact
national park and wilderness areas (Federal Class I areas) across the country. The
organization will then pursue the development of regional strategies to reduce emissions
of particulate matter and other pollutants leading to regional haze. The five Regional
Planning Organizations that receive funding from EPA to address regional haze and
related issues are: Central States Regional Air Partnership (CENRAP) for the central
states, Midwest Regional Planning Organization for the mid-western states, Ozone
Transport Commission (OTC) for the northeastern states, Southeast States Air Resource
Managers (SESARM) for the southeastern states, and Western Regional Air Partnership
(WRAP) for the western states.
Rule - Regional Haze Rule. Regulations published in the Federal Register on July 1, 1999 (64 FR
35714) that require states to establish goals for improving visibility and to develop longterm strategies for reducing emissions of pollutants that cause visibility impairment.
Silviculture - The theory and practice of controlling forest establishment, composition, and
growth. The art of producing and tending a forest.
SIP - State Implementation Plan. Plans devised by states to carry out their responsibilities under
the Clean Air Act. SIPs must be approved by the U.S. Environmental Protection Agency
and include public review.
* Operating Definitions from Section 1.1 of the WRAP FEJF Workplan dated February 25, 1999.
22
Smoke Effects* - The effects on visibility (both plume blight and regional haze), public
nuisance, and the health-based NAAQS due to emissions from fire.
Smoke Management Program (SMP) - The objectives of a basic or enhanced smoke management
program are to ensure: 1) no health-based NAAQS are exceeded; 2) nuisance smoke is
mitigated; and 3) smoke impacts on visibility are minimized in Class I areas and meet the
Grand Canyon Visibility Transport Commission Recommendations.
TIP - Tribal Implementation Plan. Plans devised by tribes to carry out their responsibilities under
the Clean Air Act. TIPs must be approved by the U.S. Environmental Protection Agency
and include public review.
Vegetative Burning - Burning of vegetation (i.e., plants or plant growth). (E.g., Burning of
grasslands or forestlands.)
Vegetative Residue Disposal - Burning of land management related fuel or vegetation that is the
by-product of a commercial operation. (E.g., Burning of wheat stubble, orchard prunings,
orchard or vineyard removals, leftover Christmas trees, timber slash or landing residues.)
Weed/Pest/Disease Management - Burning with the pre- and post-harvest objective of reducing
and/or eliminating competing weeds or other non-target vegetation during a standard crop
rotation. Burning with the pre- and post-harvest objective of controlling and/or reducing
the incidence of pests and disease impacting a crop. (E.g., Weed – goat crass, star thistle
control, cheatgrass, dodder; Pest – hessian fly, lygus bugs, weevils; Disease –
cepholosporium stripe rust, fire blight, tristeza virus.)
Wildfire* - Any unwanted, non-structural fire.
Wildfire Managed for Resource Objectives – The management of naturally ignited fires,
regardless of land type or ownership, to accomplish specific, pre-stated resource
management objectives in predefined geographic areas with or without a plan in place.
This term is considered to be analogous with the terms Wildland Fire Managed for
Resource Benefits and Prescribed Natural Fire that are used in regulations and policies
regarding Federal wildlands.
Wildland* - An area where development is generally limited to roads, railroads, power lines, and
widely scattered structures. The land is not cultivated (i.e., the soil is disturbed less
frequently than once in 10 years), is not fallow, and is not in the USDA Conservation
Reserve Program (CRP). The land may be neglected altogether or managed for such
purposes as wood or forage production, wildlife, recreation, wetlands, or protective plant
cover (EPA Interim Air Quality Policy on Wildlands and Prescribed Fires). The land is
not “agricultural land” as operationally defined above. Silvicultural land and rangelands
(per the FEJF charge), woodlots, and private timberlands will be included with wildlands
for the purposes of the FEJF work.
* Operating Definitions from Section 1.1 of the WRAP FEJF Workplan dated February 25, 1999.
23
Wildland Fire - All types of fire (see definition of fire above), except fire on agricultural land.
Wildland Fire Managed for Resource Benefits/Prescribed Natural Fire* - These terms both have
current use in regulations and policies. They are considered to be synonymous and are
used interchangeably in this workplan. These terms refer to the management of naturally
ignited fires to accomplish specific, pre-stated resource management objectives in
predefined geographic areas outlined in the fire management plan.
WRAP region - The WRAP region includes 247 tribes and the states of Arizona, California,
Colorado, Idaho, Montana, North Dakota, New Mexico, Oregon, South Dakota, Utah,
Washington, and Wyoming.
WRAP - Western Regional Air Partnership. The WRAP is a collaborative effort of tribal
governments, state governments and Federal agencies to promote and monitor
implementation of Recommendations from the Grand Canyon Visibility Transport
Commission. The WRAP may also address other common western regional air quality
issues as raised by its membership. The activities of the WRAP are conducted by a
network of committees and forums, composed of WRAP members and stakeholders who
represent a wide range of social, cultural, economic, geographic and technical
viewpoints. The WRAP members include the governors of twelve western states (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. The National Tribal
Environmental Council and the Western Governors’ Association administer the WRAP.
Yield Improvement - Burning that improves growing conditions for subsequent crops (i.e., by
adding nutrients or available water to the soil) or burning that stimulates new growth.
(E.g., Field burning on seed production fields.)
* Operating Definitions from Section 1.1 of the WRAP FEJF Workplan dated February 25, 1999.
24
APPENDIX B.
RECOMMENDATION FOR THE FORMATION OF AN
INTER-FORUM WORKGROUP
The potential is high for significant visibility impacts from episodic wildfires under suppression,
classified as “natural”, as demonstrated by recent wildfire seasons (i.e., 1996 and 2000).
Significant visibility impacts may be caused by an individual unwanted wildfire event that can
last for months at a time, and may be compounded when combined with impacts from other
unwanted wildfire events across the landscape.
The emissions and subsequent visibility effects of wildfire are highly variable both spatially and
temporally. Wildfire activity can range dramatically from year to year in the same state, as
demonstrated in Wyoming where approximately 1.5 million acres were burned by wildfire in
198841 and less than 9 thousand acres were burned in 199342. Further support of this variability,
which will dramatically affect visibility, can be found in Graph B-1 that depicts the high, low,
and median values of acres burned by wildfire for the respective year.
Depending on the frequency and magnitude of the unwanted wildfire events, the calculated
baseline, current, and natural background visibility conditions may not represent an accurate
portrayal of the visibility conditions at a given Federal Class I area in the WRAP region.
Stakeholders have expressed concern that the visibility improvements resulting from emissions
reduction programs for industrial, mobile, and other anthropogenic sources may be masked by
visibility impacts from wildfires under suppression. Concomitantly, the demonstration of
reasonable progress may be dominated by visibility impacts to the natural background condition
from these unwanted wildfires.
“The contribution from fires can be substantial over short-term periods, but fires occur
relatively infrequently and thus have a lower contribution to long-term averages….than
sources for which emissions are more continuous.”43
Unwanted wildfire events that occur relatively infrequently may have a lower contribution to
long-term averages, such as baseline and current conditions. However, if unwanted wildfire
events have a significant contribution to visibility impacts for three of the five years used to
calculate the baseline conditions, the baseline conditions portrayed would be artificially high.
This also holds true if unwanted wildfire events occur at a greater frequency and magnitude
during the five years utilized to establish current conditions, against which, states are required to
demonstrate reasonable progress toward the 2064 natural conditions goal. Thus, the frequency
and magnitude of unwanted wildfires has a potential to conceal visibility improvements from
other source types, particularly for the 20 percent most-impaired days.
41 USDA – Forest Service, Fire and Aviation Management, 1984 – 1990 Wildland Fire Statistics, January 1992.
42 USDA – Forest Service, Fire and Aviation Management, 1991 – 1997 Wildland Fire Statistics, September 1998.
43 64 FR 35736.
25
Based on the variability and the magnitude of wildfire emissions, the FEJF recommends that in
conjunction with the AMRF and with involvement of EPA, a workgroup be formed to study the
effects from unwanted wildfire events on the establishment of baseline, current, and natural
background visibility conditions, as well as on the demonstration of reasonable progress. The
development of an approach similar to the Natural Events Policy44 for wildfires under
suppression should be considered by the aforementioned workgroup, to ensure that visibility
improvements from other source types are not masked by visibility impacts from unwanted
wildfire events.
Graph B-1. Wildfire Variability – Acres Burned per Year45
Variance in Wildland Acres Burned for Western States
(1984 - 1997)
1,600,000
1,537,302
(1988)
Median
1,400,000
Acres Burned
1,200,000
1,000,000
840,399
(1987)
800,000
740,161
(1996)
600,000
820,400
(1985)
658,711
(1988)
553,110
(1996)
390,431
(1994)
400,000
200,000
0
544,261
(1996)
307,675
(1994)
251,555
(1995)
15,203
(1997)
AZ
42,354
(1991)
CA
104,966
(1996)
7,275
(1992)
CO
184,477
(1985)
137,757
(1988)
4,958
(1993)
ID
8,701
(1987)
MT
4,480
(1995)
ND
37,307
(1984)
NM
32,280
(1997)
NV
12,688
(1993)
OR
4,976
(1986)
SD
8,911
(1991)
UT
6,271
(1995)
8,911
(1993)
WA WY
44 The monitored data for visibility could be flagged using an approach parallel to the Natural Events Policy for
flagging and exempting monitored data exceeding the particulate matter health standard caused by a natural event.
The flagged IMPROVE data could potentially be exempted from the calculation of baseline, current and natural
background visibility conditions, as well as the determination of reasonable progress. This could occur when the
data monitored by the IMPROVE network appears to have a significant effect (e.g., => 1 deciview) from wildfires
under suppression.
45 USDA – Forest Service, Fire and Aviation Management, 1984 – 1990 Wildland Fire Statistics, January 1992.
USDA – Forest Service, Fire and Aviation Management, 1991 – 1997 Wildland Fire Statistics, September 1998.
26
APPENDIX C.
WEBSITE REFERENCES
This appendix is intended to provide readers with several website addresses that were used to
locate supporting information for the development of this Policy.
— Western Regional Air Partnership (WRAP) website
(http://www.wrapair.org)
— WRAP Fire Emissions Joint Forum (FEJF) website
(http://www.airsci.com/splprj.htm)
— U.S. Environmental Protection Agency’s Visibility Improvement Program website
(http://www.epa.gov/oar/vis)
— Agricultural Air Quality Task Force website
(http://www.nhq.nrcs.usda.gov/faca/aaqtf.html)
— National Fire Plan, Interagency website
(http://www.fireplan.gov)
— GCVTC Recommendations for Improving Western Vistas, June 10, 1996
(http://www.nmia.com/gcvtc)
(http://www.wrapair.org) Click on the GCVTC link
The report was used as the basis for developing Section 51.309 of the Regional Haze Rule.
— Regional Haze Rule, 40 CFR Part 51, July 1, 1999
(http://www.epa.gov/ttn/oarpg/t1/fr_notices/rhfedreg.pdf)
— The EPA Interim Air Quality Policy on Wildland and Prescribed Burning, April 23, 1998
(http://www.epa.gov/ttn/oarpg/t1/memoranda/firefnl.pdf)
This document describes the components of a state/tribal basic smoke management program.
— White Papers associated with the Interim Policy:
(http://www.westar.org/projects_fp.html)
1. Background on the Role of Fire
2. What Wildland Fire Conditions Minimize Emissions and Hazardous Air Pollutants and
Can Land Management Goals Still Be Met?
3. Air Monitoring for Wildland Fire Operations
4. Emissions Inventories for SIP Development
5. Estimating Natural Emissions from Wildland and Prescribed Fire
— The EPA Natural Events Policy for Particulate Matter, June 6, 1996
(http://www.epa.gov/ttn/caaa/t1/memoranda/nepol.pdf)
This document outlines how states should address “natural events” that produce high levels
of particulate matter.
27
— Agricultural Air Quality Task Force
Air Quality Policy on Agricultural Burning, November 10, 1999
(http://www.nhq.nrcs.usda.gov/faca/Policies/Burning%20Policy.htm)
Production Agriculture Voluntary (Incentive Based) Air Quality Compliance Program,
November 10, 1999
(http://www.nhq.nrcs.usda.gov/faca/Policies/Voluntary.htm)
FR Vol. 65, No. 181, September 18, 2000 (56308-56310).
(http://www.epa.gov/fedrgstr/EPA-AIR/2000/September/Day-18/a23948.htm)
The task force recommendations and public comment will be used by the EPA to develop a
policy for agricultural burning.
— A Collaborative Approach for Reducing Wildland Fire Risks to Communities and the
Environment, 10-Year Comprehensive Strategy
(http://www.westgov.org/wga/initiatives/fire/)
— EPA Prescribed Burning Background Document and Technical Information Document for
Prescribed Burning Best Available Control measures, EPA-450/2-92-003, September, 1992
(http://www.epa.gov/ttncaaa1/t1bid.html)
This document provides RACM and BACM for prescribed burning (includes measures for
agricultural burning).
28
APPENDIX V.
BACKGROUND MATERIALS
FEJF Storyline
Facts about WRAP
WRAP/FEJF Organizational Charts
FEJF & NBTT Rosters
Website References
[Ed note: This document has been formatted
for 2-sided printing (i.e., duplex printing).]
FIRE EMISSIONS JOINT FORUM
A Forum of the
Western Regional Air Partnership
“Working to Balance Human and Ecosystem Health”
Contents of this FEJF Storyline
What is the Fire Emissions Joint Forum (FEJF)?
What is the mission of the FEJF?
Who’s on the FEJF and what interests are represented?
Who will benefit from FEJF’s work?
What are FEJF’s tasks?
Grand Canyon Commission’s recommendations regarding fire
What have other agencies done regarding fire and air quality?
What is the role of fire in ecosystems and agriculture and what are its effects on air quality
and public health?
What is the Fire Emissions Joint Forum (FEJF)?
The FEJF is a group formed under the auspices of the Western Regional Air Partnership
(WRAP), which was established to implement the recommendations of the Grand Canyon Visibility
Transport Commission (GCVTC report, June 1996) and to address western regional air quality issues.
The WRAP is a broad stakeholder-based partnership charged with developing visibility protection
programs, specifically for Federally-protected Class 1 park and wilderness areas. WRAP members
include Western governors or their designees, state air quality agencies, federal/state/private land
managers, tribes, the Enviromental Protection Agency, environmental groups, industry, academia, and
others. Several stakeholder forums have been established, including the FEJF, to assist the WRAP in
carrying out its tasks.
The FEJF is a consensus-based group working to develop solutions to the problem of fire
effects on air quality and visibility. Most of the WRAP forums are either technical or policy in nature,
but the FEJF is both and therefore is called a “joint” forum. The FEJF is guided by the
recommendations contained in the GCVTC Final Report (1996), and the requirements of EPA’s
Regional Haze Rule (July 1999), concerning smoke effects from wildland and agricultural burning
activities on public and private lands in the western states. This storyline outlines the mission of the
FEJF, its membership, activities, and timelines, and in general terms, the role of fire and its effects on air
quality in the West. For additional information, please see the links, “The Grand Canyon Visibility
Transport Commission - Recommendations for Improving Western Vistas, June 10, 1996" and the
FEJF Workplan and other documents located on the WRAP website.
What is the mission of FEJF?
1990 Clean Air Act Amendments
The FEJF’s mission is to develop programs and
1991 GCVTC formed
tools relating to prescribed fire and air quality for the
1996 GCVTC Report to EPA
WRAP and related WRAP forums. The principal client
1996-7 WRAP formed
of the FEJF is the WRAP. FEJF’s workproducts will be
1999 Regional Haze Rule
presented to the WRAP as recommendations for WRAP
approval. WRAP member states, tribes, and land
managers are then expected to utilize the FEJF
workproducts in developing or augmenting their respective programs. These workproducts include
model smoke management and public education/outreach programs and emissions assessment tools.
The FEJF is creating an important opportunity for experts and interested parties to come
together to solve real problems . The goal of the FEJF is to find ways to successfully meet the
challenge of accomplishing both fire and land management goals with respect to prescribed burning, and
clean air goals. The FEJF is a logical group to address these complex issues and its members
understand and appreciate the importance of finding ways to accomplish both sets of goals in a
collaborative way. Creating the workproducts recommended by the GCVTC is a task that requires our
best efforts in terms of creating a vision for the future and then utilizing our scientific knowledge,
creativity, and consensus skills to help create it. Although thousands of people in the West are involved
in fire and air quality work, the eighteen representative members of the Forum and others who
participate, are committed to developing the best possible technical analyses and model programs for
all the stakeholders to use in the coming years.
Who’s on the FEJF and what interests are represented?
Stakeholders representing key interests who contribute to the Forum come from federal/
state/tribal air and land management agencies; private landowners, including agricultural interests;
industry; environmental advocacy groups; and academia. Other stakeholders and interested people are
welcome to attend and participate in the FEJF meetings and task teams. The FEJF works by
consensus in developing and forwarding its recommendations to the full WRAP.
The FEJF will focus on western states (AZ, CA, CO, ID, MT, ND, NM, NV, OR, SD, UT,
WA, and WY) although information from other states and/or neighbor countries (i.e., Canada, Mexico,
Alaska, Hawaii) may also be used for developing the work products as appropriate.
Who will benefit from FEJF’s work?
The primary users of the workproducts of the FEJF will be air regulatory agencies, land
managers, tribes, and advisers (or providers of technical assistance) to these groups. These products
for the primary users are likely to be technical and comprehensive in nature (eg, analytical tools for
estimating fire emissions and alternatives to burning) and will provide necessary tools and information
for air quality planning, smoke management programs and fire management programs. These groups
will select and use the FEJF workproducts that they need for their own programs. Other users will
likely include local governments, industry,
forestry, range and agricultural interests, and nongovernmental organizations such as health
organizations and environmental groups.
What are FEJF’s tasks?
The key pollutants being addressed as
contaminants in smoke from fire, as determined
by the WRAP Emissions Forum, are particulate
matter (PM2.5 and PM10 - particle sizes
expressed in microns), elemental and organic
carbon, volatile organic compounds (VOC),
sulfur oxides (SOx), nitrogen oxides (NOx),
nitrates, and carbon monoxide (CO). These
Visibility Monitoring Site
pollutants will be addressed in terms of their
effect on visibility impairment and regional haze, nuisance effects, and the health-based national ambient
air quality standards (NAAQS), as appropriate.
The FEJF has organized into teams to develop consensus-based workproducts that address
key areas related to fire and air quality. These areas correspond to the GCVTC recommendations and
Regional Haze Rule requirements. Team members include Forum and non-Forum members with special
expertise. The timeline for completion of the work outlined below is early 2001. The key areas are:
1. Smoke Management Programs (SMPs)
The FEJF will: 1) assess the progress of current prescribed fire programs to address smoke effects; 2)
assess existing smoke management programs and establish a clearinghouse of existing programs; 3)
develop requirements for model basic and enhanced SMPs; and, 4) develop and recommend
cooperative funding mechanisms for cross-jurisdictional agencies to use for funding SMPs.
2. Fire Emissions/Assessment
The FEJF will: 1) gather and review pertinent information on methodologies used to estimate fire
emissions; 2) present information at one (or more) workshops in order to obtain input from participants
and evaluate existing information/methodologies related to fire emissions assessment; and to identify
additional technical and institutional needs; 3) develop an Emissions Tracking System (ETS), and a
process for states and tribes to adopt and implement an ETS; and, 4) develop annual emissions goals
for all fire programs, where appropriate, for incorporation into SMPs.
3. Alternatives to Burning
The use of alternatives to burning on wildlands and agricultural lands may result in fewer atmospheric
emissions. The FEJF will: 1) develop criteria (including economic and social considerations) for the use
of non-burning alternatives to fire; 2) identify non-statutory (for example, bureaucratic, social,
economic) administrative barriers to the use of non-burning alternatives; 3) develop accountability
mechanisms for use of alternative practices; and, 4) develop implementation plans.
4. Public Education and Outreach
Education and outreach is a critical aspect of smoke management programs, especially for the public
and for all of the key stakeholders. The FEJF will: 1) coordinate with and assist other FEJF teams on
developing public outreach materials for their workproducts; 2) compile public education/outreach
materials from stakeholder groups and agencies, synthesize these materials, and recommend model
program elements for others to use; 3) create a clearinghouse of existing and new information related
to FEJF topics on the FEJF/WRAP website; and, 4) create appropriate means for public involvement
in the FEJF process - this will include public workshops, mail outs and website posting of draft FEJF
workproducts for comment, and notifying interested parties of FEJF activities.
5. Natural Conditions
Natural visibility conditions will need to be defined for each Federal Class 1 park and wilderness area
under the Regional Haze Rule. Natural conditions are defined as the level of visibility for the 20 percent
most-impaired and 20 percent least-impaired days, that would exist if there were no man-made
impairment. Wildland and prescribed fire, including agricultural burning, is both human caused and
naturally caused. The FEJF will work with its membership, other scientists and professionals involved
in this issue, and other Forums to seek a common understanding of what constitutes natural conditions
with regard to fire and air quality at Class 1 areas.
GCVTC’s recommendations regarding fire
The GCVTC recommended eight specific measures be developed to address the potential
impacts of fire on air quality. These measures are to be developed in a stakeholder process similar to
that used by the GCVTC, now incorporated into the FEJF, and are to be adopted by these
stakeholders in developing their future smoke management programs and plans. Following is a
summary of the recommendations:
1. Plan for the visibility impacts of
smoke
2. Implement an emissions tracking
system
for all fire activities
3. Improve integrated assessment of
emissions
4. Enhance smoke management
programs
5. Develop cooperative funding
mechanisms
6. Promote public education programs
7. Establish annual emission goals for
fire
programs
8. Remove administrative barriers to
the use
of alternatives to
burning
What have other agencies done to address fire and air quality?
At the Federal level, land and fire management agency directors under the Departments of
Interior and Agriculture and EPA developed and adopted the Federal Wildland Fire Management
Policy and Program Review in 1995
. This federal fire policy recognized that an increase in
prescribed fire was needed on public lands to: reduce the threat of wildfires after almost a century of
fire suppression, reduce the risk to firefighter safety, and “allow fire to function as nearly as possible, in
its natural role in maintaining healthy wildland ecosystems”.
In response to this change in Federal fire policy, and in conjunction with the promulgation of
new national ambient air quality standards for particulate matter and ozone, and the 1999 national
Regional Haze Rule in the works, EPA facilitated the development of the “Interim Air Quality
Policy on Wildland and Prescribed Burning (1998)”
. This was a also a stakeholder process,
which resulted in policy guidelines similar to the GCVTC’s recommendations on addressing smoke
management issues. This policy outlined a framework for public and tribal air and land managers and
private landowners to follow in developing smoke management programs. EPA plans to amend the
interim policy to address agricultural burning and regional haze. The elements of this policy are
incorporated into EPA’s 1999 Regional Haze Rule which requires states to adopt these measures into
their existing or new smoke management programs as part of future state planning for regional haze.
These policies and the Regional Haze Rule guide the work of the FEJF with regard to
wildland/silvicultural burning and smoke managment development. In addition the US Department of
Agriculture and EPA are completing another stakeholder effort to develop similar guidelines for
agricultural burning. These guidelines will also assist FEJF’s efforts in developing smoke management
recommendations for agricultural sources.
What is the role of fire in ecosystems and agriculture and what are its
effects on air quality and public health?
The GCVTC recognized that smoke from wildfire and prescribed burn activities can have a
significant impact on visibility and regional haze, public health and public nuisance. The GCVTC also
recognized the important role fire plays in maintaining the health of ecosystems and as a land
management tool in many agricultural operations. The GCVTC report states,
“Fire has played a major role in the development and maintenance of most ecosystems in the
West. The long-term future of the West is dependent on healthy ecosystems that are capable
of sustaining natural processes and human uses.
An increase of accumulated fuels in the West has occurred because of past land management
practices, including decades of fire suppression. Evident ecosystem changes include increasing
tree densities, disrupted nutrient cycling, and altered forest structure. As a result, wildfires are
becoming larger in size, unnaturally destructive, and more dangerous and costly to control. In
1994, wildfire burned 3.1 million acres in the West and cost $1 billion in direct suppression
costs while causing firefighter deaths and serious human health impacts. (Since this report was
issued, the acreage and costs of wildfires have been rising). Rectifying this problem will take
years and is a basic responsibility of wise land stewardship. Fire is an essential component of
most natural systems, and perpetuation of fire at a level required to maintain ecosystem
processes is necessary. The natural role of fire in the wildland/urban interface must also be
addressed to protect life and property. A substitute for fire and its natural role has not been
found in many ecosystems. The objective of future prescribed fire programs is to cooperatively
meet land management, human health, and visibility objectives.”
Land management agencies participating on the GCVTC estimated 3 millon acres of prescribed
burning are planned by the year 2015 and 6 million acres by the year 2040. These estimates are rough
because prescribed fire programs are greatly
dependent on available resources and funding. In
any case, significant increases in fire on all wildlands
are expected to occur, whether by prescribed fire
or by uncontrolled wildfire.
Fire has not only been a natural part of
ecosystems, but has also been an important
management tool for as long as humans have
systematically grown crops. Agricultural burning is
used to stimulate new growth and trigger higher
yields, control pests and weeds, reduce the need for herbicide and pesticide chemical treatments,
reduce fire hazards, clear irrigation ditches and canals, and dispose of crop residue. Although some
western states develop inventories of agricultural burning acreages and emissions, a regional emissions
inventory curently does not exist.
The GCVTC’s recommendations focused on ways to limit increased visibility impairment from
fire that could occur in the coming decades. The GCVTC’s Fire Emissions Project estimated that
emissions from prescribed fire (excluding agricultural), are likely to have the single greatest impact on
visibility at Federal Class 1 areas through 2040. “[This] modeling indicates that, at certain times,
increased visibility impairment from fire is likely to exceed the potential visibility improvements
associated with other GCVTC recommendations.” As an illustration, even if smoke management
programs which employ optimal levels of smoke mitigation and control are implemented throughout the
Grand Canyon visibility transport region, prescribed fire’s contribution to annual visibility impairment at
Hopi Point, a popular vista point at the Grand Canyon, could increase by 400% between 1995 and
2040. Granted, estimates such as these do not take into account the kinds of practical, daily decisions
land and air managers make in utilizing optimal weather conditions to minimize smoke effects from
prescribed burning. Nevertheless, this example illustrates that increased prescribed fire programs in the
West will potentially cause greater visibility impairment at Class 1 areas (and elsewhere) than exists
today.
While the GCVTC focused mainly on the long-term visibility effects of smoke, other air quality
impacts from smoke have been recognized not only by the GCVTC, but by the WRAP, EPA, states,
tribes, land managers, and others. These include such short and long-term effects as public nuisance
during smoke events and exposure to high concentrations of harmful air contaminants like particulate
matter and air toxics. Short-term, high-impact smoke episodes from wildfire and prescribed burning
can produce very high concentrations of inhalable particulate matter in downwind communities and
other smoke-sensitive areas such as hospitals, schools, public events, or tourist attractions. Certain
populations, including children, the elderly, those suffering from asthma and other respiratory diseases
are especially vulnerable. The national (and some states’) ambient air quality standards (NAAQS),
which are set at levels to protect the public health, can be threatened or violated at times by prescribed
burning, and certainly by wildfire events. The FEJF and other agencies and groups throughout the
country all recognize this threat and are combining their efforts to develop effective smoke management
programs.
Yosemite Valley
On a Hazy Day
On a Clear Day
FACTS about the WRAP
What is the Western Regional Air Partnership -- the WRAP?
The WRAP is a voluntary organization of western states, tribes and federal agencies. It was
formed in 1997 as the successor to the Grand Canyon Visibility Transport Commission,
which made over 70 recommendations in June 1996 for improving visibility in 16 national
parks and wilderness areas on the Colorado Plateau. The Partnership promotes, supports
and monitors the implementation of those recommendations throughout the West. The
WRAP is also implementing regional planning processes to improve visibility in all Western
Class I areas to provide the necessary technical and policy tools needed by states and
tribes to implement the federal regional haze rule. The WRAP is administered jointly by the
Western Governors' Association (WGA) and the National Tribal Environmental Council
(NTEC).
The WRAP recognizes not only that residents have the most to gain from improved
visibility, but also that many solutions are best implemented at the local, state, or regional
level with public participation.
Who belongs to the WRAP?
The WRAP is made up of western states and tribes and federal agencies. The states are
Washington, Oregon, Idaho, Montana, Wyoming, North Dakota, South Dakota, California,
Utah, Colorado, Arizona and New Mexico. Tribal nations include Pueblo of Acoma, Campo
Band of Kumeyaay Indians, Cortina Indian Rancheria, Hopi Tribe, Hualapai Nation of the
Grand Canyon, Jicarilla Apache Tribe, Northern Cheyenne Tribe, Salish and Kootenai
Confederated Tribes, Pueblo of San Felipe, and Shoshone_Bannock Tribes of Fort Hall.
Representatives of other tribes participate on WRAP forums and committees. Federal
participants are the Department of the Interior, the Department of Agriculture, and the
Environmental Protection Agency.
How does the WRAP make decisions?
The WRAP’s committees and forums seek consensus among stakeholders including large
and small businesses, academia, environmental groups and other public interest
representatives. Scientific findings and policy options are presented to policy makers and
the public for appropriate discussion and response. The WRAP is committed to bringing
together all those who may cause or be affected by poor air quality.
How is the WRAP funded?
The WRAP receives a share of money Congress appropriates to US EPA for visibility
improvement throughout the US. However, a far greater contribution is made by
stakeholder organizations and individuals whose time and effort for committees and forums
is not reimbursed by the WRAP.
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Who does the work?
The WRAP has no staff of its own. Two project managers are housed at Western
Governors’ Association in Denver and at the National Tribal Environmental Center in
Albuquerque, but their duties for the WRAP are only part time. Much of the WRAP’s
technical work is conducted by outside contractors. Work plans are prepared by one or
more WRAP forums and work products are reviewed by the forums and the project
managers.
What projects has the WRAP completed? Were they successful?
In the spring of 1999, the US EPA published a proposed rule to reduce sulfur in gasoline.
Western governors, concerned that the rule might have an inequitable effect on small
western gasoline refineries and thus on the availability of gasoline and its price to
consumers, asked that the WRAP’s Mobile Sources Forum examine the issue. The forum,
a broad_based group of stakeholders that includes representatives of government,
environmental groups and the automobile and refinery industries, recommended a national
one_year compliance extension of the standard for small refineries and relatively stringent
interim gasoline sulfur standards. It also proposed a limited banking and trading program
that will include incentives for early sulfur reductions and an anti_backsliding provision. The
WRAP adopted the Forum’s recommendations, and EPA included these provisions in the
final rule.
How can individuals and organizations be involved in the WRAP’s work and
decisions?
The WRAP’s success depends on the participation of concerned and informed participants
who commit time and energy to this endeavor. Committees and forums are continuously
accepting applications for a limited number of appointments. For more information, check
out the WRAP’s Web site at www.wrapair.org, and look for the button labeled “Getting
Involved.”
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Fire Emissions Joint Forum
Clean Air Act 1990
Grand Canyon Visibility Transport Commission
PM2.5, PM10,
Ozone NAAQS
6/96 Report to EPA
Implementation
Strategies - EPA
Policy on Wildland/
Prescribed Fire
WRAP
IOC / TOC
External Groups
Fire Emissions Joint Forum
(Workplan)
FACA
NAS
Proposed
Regional Haze
Rule 7/97
Final
Regional Haze
Rule 7/99
Develop GCVTC Implementation
Strategies & Recommendations
and Address Regional Haze Rule
Requirements (308/309) for WRAP
Task Teams
•Smoke Management
Programs (Basic/Enhanced)
•Fire Emissions/Assessment
•Natural Background
•Alternatives to Burning
(Ag. Land & Wildland)
•Public Education/Outreach
•Prescribed Fire Plan
Assessment
WRAP
Consensus
Tribes
TIPs
Land Mgrs.
FLMs
LMPs
FMPs
SMPs
States
SIPs
SMPs
Land Mgrs.
Regional Cross-Boundary Coordination
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Private
Land Mgrs.
FIRE EMISSIONS JOINT FORUM MEMBERSHIP ROSTER (9/13/01)
Co-Chairs:
Pete Lahm, USDA Forest Service
Environmental Representative:
John Veranth, Department of Chemical and Fuels Engineering, University of Utah
Federal Representatives:
John Kennedy, USEPA Region IX
Tim Sexton, National Park Service
Pat L. Shaver, USDA/NRCS, Grazing Lands Technology Institute
State Representatives:
Frances Bernards, Utah DEQ - Division of Air Quality
Diane Riley, Idaho Division of Environmental Quality
Jim Lawrence, Council of Western States Foresters
Tribal Representatives:
William Malone, White Mountain Apache Tribe
Kevin McKernan, Yurok Tribal Environmental Program
Small Business:
Dave Randall, Air Sciences Inc.
Large Manufacturing:
Dick Hayslip, Salt River Project
Scott Kuehn, Plum Creek Timber Co.
General Public:
Chas Erickson, Ranching
Mark Wagoner, Farming
Academia:
Phil Omi, Colorado State University
Bryan M. Jenkins, University of California
Local Government:
David L. Jones, San Joaquin Valley Air Pollution Control District
WRAP Initiative Oversight Committee Liaison:
Richard Sprott, Utah Department of Environmental Quality
WRAP Technical Oversight Committee Liaisons:
Rich Fischer, USDA Forest Service
Mike George, Arizona Department of Environmental Quality
WRAP Communications Committee Liaison:
To Be Named
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NATURAL BACKGROUND TASK TEAM ROSTER
NBTT Management & Content Teams
Carl Gossard, Co-Chair
Bureau of Land Management at National Interagency Fire Center
Darla Potter, Co-Chair
Wyoming DEQ – Air Quality Division
Pete Lahm, FEJF Co-Chair
USDA Forest Service
Mark Fitch
Arizona Department of Environmental Quality
Dave Jones
San Joaquin Valley Air Pollution Control District
Shelley Nolde
USDA Forest Service
Jim Russell
OR/WA State Office Forest Service and Bureau of Land Management
Sam Sandberg
USDA Forest Service Research
Mike Ziolko
Oregon Department of Forestry
NBTT Participants
Lara P. Autry
U.S. EPA OAQPS
Coleen Campbell
CODPHE, Air Pollution Control Division
Ken Evans
Phelps Dodge Corporation
Brian Finneran
Oregon Department of Environmental Quality
Fred Greef, past Co-Chair
Washington Department of Ecology
Dennis Haddow
USDA Forest Service
Patti Hirami
USDA Forest Service, Fire & Aviation
Rose M. Lee
Yakama Nation Environmental Program
Bill Leenhouts
USDI Fish & Wildlife Service
Kevin McKernan
Yurok Tribe Environmental Program
Amy Mignella, Esq.
White Mountain Apache Tribe, Special Counsel
Bob Palzer
Sierra Club
Tim Rogers
SD Department of Environment & Natural Resources, Air Program
Tim Sexton
USDI National Park Service
Patrick Shaver
USDA Natural Resources Conservation Service
Mark Wagoner
Alfalfa Seed Farmer
Robert Wilkosz
Idaho Department of Environmental Quality
Coordinator/Facilitator
Rebecca Reynolds
Rebecca Reynolds Consulting Inc.
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WEBSITE REFERENCES
This listing is intended to provide readers with several website addresses that were used to locate
supporting information for the categorization of fire emissions.
— Western Regional Air Partnership (WRAP) website
(http://www.wrapair.org)
— WRAP Fire Emissions Joint Forum (FEJF) website
(http://www.airsci.com/splprj.htm)
— U.S. Environmental Protection Agency’s Visibility Improvement Program website
(http://www.epa.gov/oar/vis)
— Agricultural Air Quality Task Force website
(http://www.nhq.nrcs.usda.gov/faca/aaqtf.html)
— National Fire Plan, Interagency website
(http://www.fireplan.gov)
— GCVTC Recommendations for Improving Western Vistas, June 10, 1996
(http://www.nmia.com/gcvtc)
(http://www.wrapair.org) Click on the GCVTC link
The report was used as the basis for developing section 51.309 of the regional haze rule.
— Regional Haze Rule, 40 CFR Part 51, July 1, 1999
(http://www.epa.gov/ttn/oarpg/t1/fr_notices/rhfedreg.pdf)
— The EPA Interim Air Quality Policy on Wildland and Prescribed Burning, April 23, 1998
(http://www.epa.gov/ttn/oarpg/t1/memoranda/firefnl.pdf)
This document describes the components of a state/tribal basic smoke management program.
— White Papers associated with the Interim Policy:
(http://www.westar.org/projects_fp.html)
1. Background on the Role of Fire
2. What Wildland Fire Conditions Minimize Emissions and Hazardous Air Pollutants and
Can Land Management Goals Still Be Met?
3. Air Monitoring for Wildland Fire Operations
4. Emissions Inventories for SIP Development
5. Estimating Natural Emissions from Wildland and Prescribed Fire
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WEBSITE REFERENCES, continued
— The EPA Natural Events Policy for Particulate Matter, June 6, 1996
(http://www.epa.gov/ttn/caaa/t1/memoranda/nepol.pdf)
This document outlines how states should address “natural events” that produce high levels
of particulate matter.
— Agricultural Air Quality Task Force
Air Quality Policy on Agricultural Burning, November 10, 1999
(http://www.nhq.nrcs.usda.gov/faca/Policies/Burning%20Policy.htm)
Production Agriculture Voluntary (Incentive Based) Air Quality Compliance Program,
November 10, 1999
(http://www.nhq.nrcs.usda.gov/faca/Policies/Voluntary.htm)
FR Vol. 65, No. 181, September 18, 2000 (56308-56310).
(http://www.epa.gov/fedrgstr/EPA-AIR/2000/September/Day-18/a23948.htm)
The task force recommendations and public comment will be used by the EPA to develop a
policy for agricultural burning.
— A Collaborative Approach for Reducing Wildland Fire Risks to Communities and the
Environment, 10-Year Comprehensive Strategy
(http://www.westgov.org/wga/initiatives/fire/)
— EPA Prescribed Burning Background Document and Technical Information Document for
Prescribed Burning Best Available Control measures, EPA-450/2-92-003, September, 1992
(http://www.epa.gov/ttncaaa1/t1bid.html)
This document provides RACM and BACM for prescribed burning (includes measures for
agricultural burning).
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