Sea to Sky Burning & Smoke Control
Strategic Framework
March 2013
Sea-to-Sky Airshed, British Columbia
March, 2013
Sea to Sky Burning and Smoke Control Strategic Framework
Acknowledgements
The Burning and Smoke Control Strategic Framework for the Sea-to-Sky Airshed was developed
by the Sea to Sky Clean Air Society (SSCAS) and funded by the BC Ministry of the Environment
(MoE). SSCAS is grateful to the MoE for the generous financial support and expertise that made
this framework possible. SSCAS is also grateful to the many stakeholders that contributed to the
development of this framework through their time, hard work and excellent insights. They are
listed alphabetically as follows:
Anna Helmer (Pemberton Framers’ Institute)
Brooke Carere (Squamish Lillooet Reg. District)
Bruce Blackwell (B.A. Blackwell & Assoc. Ltd)
Cami Tedder (Waste Control Services)
Caroline Lamont (Village of Pemberton)
Chief Ralph Thevarge (Nquatqua)
Cindy Watson (Vancouver Coastal Health)
David Dubois (Green Heating Initiative)
Derek Lefler (Coastal Fire Centre)
Dave Southam (MoFLNRO)
Eric Andersen (SquamishCAN)
Frank DeGagne (MoFLNRO)
Graham Haywood (Lil’Wat Nation)
Graham Veale (Ministry of Environment)
Guy Fried (BC Timber Sales)
Ian Holl (Sea to Sky Clean Air Society)
James Hallisey (Resort Municipality of Whistler)
Jeff Fisher (Sqomish Forestry)
Julie Saxton (Metro Vancouver)
Kevin Brown (Kevin Brown Communications)
Khalid Jasim (Howe Sound Pulp and Paper)
Kim Slater (Sea to Sky Clean Air Society)
Linda Kelly-Smith (SquamishCAN)
Louis Legal (Sunshine Coast Clean Air Society)
Maari Hirvi-Mayne (Metro Vancouver)
Marion Town (Fraser Basin Council)
Markus Kellerhals (Ministry of Environment)
Mike Wallace (Sea to Sky Forestry Society)
Morgan Kathy (Gibson’s Conservancy)
Nicolette Richer (Sea to Sky Clean Air Society)
Peter Frinton (Sea to Sky Clean Air Society)
Randall Lewis (Squamish Nation)
Rebecca Freedman (Ministry of Environment)
Rob Whitton (Resort Municipality of Whistler)
Rod McLeod (District of Squamish)
Ruth Simons Sea to Sky Clean Air Society)
Sue Maxwell (EcoInspire, Zero Waste Consultant)
Tom Cole (Cheakaums Community Forest)
Tracey Henderson (Ministry of Environment)
Trish Panz (Greater Vancouver Regional District)
Photo Credits
British Columbia Ministry of Environment & Squamish Climate Action Network
Contact
Please address questions about this document to: seatoskycleanair@gmail.com
2
Foreword
The 2007 Sea to Sky Air Quality Management Plan (AQMP) is a regional, collaborative,
action plan, which guides the Sea to Sky Clean Air Society (SSCAS) in fulfilling its
mandate for protecting air quality in the Sea-to-Sky Airshed. It calls for the development
of a “Smoke Control Strategy that specif[ies] open burning smoke management zones
and tools…”1 towards controlling smoke emissions throughout the airshed. This Burning
and Smoke Control Strategic Framework (BSCSF) is the first step in the creation of the
Smoke Control Strategy and its vision, principles and recommended actions will lay the
groundwork for a future implementation plan. It is intended to be a living document
that continues to be shaped by the policy landscape and the needs of its stakeholders.
Executive Summary
SSCAS with the support of Ministry of Environment (MoE), invited a group of
stakeholders from various levels of government, civil society, First Nations and the
private sector to form an advisory group to develop a vision of how the region could
reduce biomass burning causing harmful emissions. The Advisory Group envisions a
future in which burning and smoke emissions are minimized, and biomass- notably
woody residues and backyard debris- are utilized to the benefit of airshed communities,
local economies and the environment.
Through the implementation of the recommendations and actions, the objectives
presented below can be achieved. This will ensure that the region is a leader in reducing
smoke emissions, and using biomass innovatively towards the provision of economic,
social and environmental benefits.
Objective 1- Reduce the amount of biomass disposed of through burning, notably
forestry wood residues, as well as land clearing and garden debris, while ensuring
appropriate fire hazard abatement can occur.
Objective 2- Apply appropriate technology and burn control methods to unavoidable
burns, in order to reduce smoke emissions and human exposure to smoke emissions.
This BSCSF will adhere to existing regulations, notably the Open Burning Smoke Control
Regulation and Waste Discharge Regulation, as well as Wildfire Regulations and local
burning and waste management bylaws and policies. It will build on previous plans,
notably the BC Smoke Management Framework, and incorporate some of the aims and
objectives of the BC Energy Plan, SLRD Energy Resilience Task Force Report and various
Municipal Solid Waste Management Plans. However, it will provide local context in
order to adequately frame its regionally specific recommendations, providing more
1
See: http://seatoskyairquality.ca/wp-content/uploads/aqmp2007.pdf
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Sea to Sky Burning and Smoke Control Strategic Framework
depth and specificity than provincial plans and strategies. This will ensure the BSCSF is
tailored to the Sea-to-Sky Airshed and relevant for stakeholders.
4
Table of Contents
Acknowledgements ....................................................................................................2
Photo Credits ..............................................................................................................2
Contact .......................................................................................................................2
Foreword ....................................................................................................................3
Executive Summary.....................................................................................................3
Table of Contents ........................................................................................................5
INTRODUCTION ..........................................................................................................6
Vision ..............................................................................................................................................................................9
Values .............................................................................................................................................................................9
Objectives......................................................................................................................................................................9
Principles .................................................................................................................................................................... 10
Biomass Management Hierarchy ....................................................................................................................... 11
BACKGROUND .......................................................................................................... 13
Regional Burning & Smoke Control Practices ................................................................................................. 15
Burning ............................................................................................................................................................................15
Smoke Control ..............................................................................................................................................................17
Policies ........................................................................................................................................................................ 19
Programs ................................................................................................................................................................... 24
Biomass Potential & Challenges ......................................................................................................................... 25
BUSINESS SECTOR PROFILES ...................................................................................... 27
Tourism ....................................................................................................................................................................... 27
Forestry & Timber Harvesting ............................................................................................................................. 28
Farming and Ranching............................................................................................................................................ 30
Development, Construction & Demolition Industries ................................................................................. 31
RECOMMENDATIONS................................................................................................ 33
MAKING THE STRATEGY A REALITY- MOVING TO IMPLEMENTATION ......................... 42
CONCLUSION ............................................................................................................ 44
APPENDICES ............................................................................................................. 45
Glossary ...................................................................................................................................................................... 45
Table: Municipal & Regional District Burning Bylaws ........................................................................... 48
SWOT ANALYSIS- BY SECTOR .......................................................................................................................... 50
Summary of Observations ......................................................................................................................................54
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Sea to Sky Burning and Smoke Control Strategic Framework
Image Courtesy of Sea to Sky Annual Report
INTRODUCTION
Clean air is a priority in the Sea-to-Sky Region as it is essential to the health of visitors
and residents and is a vital component of the regional tourism-based economy that
relies on scenic vistas and clean outdoor recreational spaces.
Biomass burning releases emissions (i.e. smoke) that threaten this valuable resource, as
well as human health.
Important contaminants in smoke include both fine and coarse
particulate matter (PM2.5 and PM10 respectively), carbon monoxide
(CO), nitrogen oxides (NOx), and volatile organic compounds (VOC).
Biomass burning can also release small amounts of toxins such as
benzene, acrolein, polycyclic aromatic hydrocarbons (PAHs),
formaldehyde, and dioxins and furans.2
Some gases and particulates (solid and semi-volatile combustion particles) released
during burning contribute to climate change3, while others contribute to hazy skies that
impair visibility and scenic vistas. Particulate matter (PM), especially fine particulate
matter (PM2.5) has serious impacts on human health. PM2.5 is small enough to be
inhaled into the deepest parts of the lungs and is associated with health problems that
range from a runny nose and coughing, to bronchitis, asthma, emphysema, pneumonia,
heart disease and even death. Senior citizens, infants and people who already have lung
or heart problems are most at risk, but healthy younger adults and children can also be
2
Freedman, Rebecca, et al. (2011). A Smoke Management Framework for British Columbia: A Crossgovernment Approach to Reduce Human Exposure to Smoke from Biomass Burning;
http://www.bcairquality.ca/reports/pdfs/smoke-management-framework-20110722.pdf, pg. 5
3
Although bioenergy can displace fossil fuel use resulting in fewer GhG’s emitted.
6
affected.4 A growing body of knowledge recognizes that even smaller particles (so called
ultrafine particles), also emitted during combustion, have health effects that are
additional causes for concern. More research is needed to understand the range and
extent of such effects and to determine appropriate regulatory approaches and control
methods.5
Smoke is also a sign that resources are not being put to best use; much of the material
that goes up in smoke could be converted into valuable products or energy applications.
It is the imperative of this Framework to highlight what some of those products and
energy applications might be and to suggest actions for how they might be developed in
this region.
Biomass smoke results from a number of planned and unplanned burning activities, of
which planned, human-initiated burns (“anthropogenic”) will be the primary focus of
this Framework and directly targeted in the recommended actions. Natural events, like
lightning-induced fires, though significant sources of smoke on an episodic basis, are
largely outside the scope of this Framework, however they will be addressed indirectly
through actions that support fire hazard abatement. Though it has considerable
potential to harm air quality and human health, burning of non-organic waste (i.e.
garbage) will not be a major focus of this framework, largely owing to the fact that it is
not a widespread practice in the airshed (burning garbage at the residential scale is not
permitted). It is important to note, however, that larger scale industrial or commercial
waste incineration could be authorized subject to appropriate environmental
assessment and regulatory conditions in some airshed locations (e.g. a proposal for the
Sunshine Coast is being considered at the time of writing this framework), posing a
potential future threat to air quality (as well as a perverse incentive for garbage
creation), that warrants greater attention paid to it in the implementation phase of this
Smoke Plan development process. 6
Presently, there are many instances of organic matter being burned. Examples include:
resource and forest management; enhancement of wildlife habitat; wildfire prevention;
disposal of debris from gardening, agricultural and land development; campfires; and
residential and commercial space heating using fireplaces, woodstoves and other
burning appliances.
Because there are so many reasons for burning biomass and with varying impacts, it is
4
See: http://www.bcairquality.ca/topics/smoke-burning.html
BC Lung Conference, Ultrafine Particles, Feb. 20, 2013.
6
The Zero Waste International Alliance recently redefined their hierarchy to rule out burning of waste as
an option owing to its significant negative environmental and social impacts (Sue Maxwell, EcoInspire,
2013). Also, a Life Cycle Analysis report states that incineration is less preferable to landfilling of waste
(provided landfills are properly lined and a high-degree of gas capture is in place). Sound Resource
Management Group Ltd. (2009) Environmental Life Cycle Assessment of Waste Management Strategies
with a Zero Waste Objective, Study of the Solid Waste Management of System in Metro Vancouver, B.C.
5
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Sea to Sky Burning and Smoke Control Strategic Framework
neither easy nor desirable to paint them all with the same brush; a challenge in creating
a “single-airshed wide approach” as directed by the AQMP.7 For instance, burning
woody debris, though intended as a last resort, remains a common method of abating
forest fire hazards (i.e. avoiding larger fires) and the risk they pose to public safety and
Crown assets. This speaks to the complexity of developing an approach to managing
biomass that protects the health and safety of the public in all respects. Ceremonial fires
have tremendous cultural significance to First Nations in the region but are a relatively
rare occurrence and are not considered a significant threat to air quality. Finally, fire is a
natural, normal process in many ecosystems. “It is beneficial and necessary to maintain
a healthy forest and the diversity of plant and animal life.”8 Prescribed fire is a valuable
tool in resource management and therefore will not be considered in this Framework.
Ceremonial fires, and essential resource management and ecosystem applications aside,
many of the other burning activities previously mentioned are less desirable, and
potentially avoidable. Many occur in the absence of adequate venting mechanisms and
emission controls, or some, like back yard burning and home heating, take place in
residential areas where smoke is very likely to be inhaled by many people and
accumulate in high concentrations (as opposed to burns that occur in remote areas).
Other burning, like that done solely as a means of disposal, is simply wasteful. These
factors make biomass burning a cause for concern, and provide the rationale for finding
alternatives. The focus of this Framework is thus largely on finding alternatives to
burning as a method of disposal, as well as targeting burning that presents the highest
risks to humans. It will principally look at ways of managing biomass resources and
debris more efficiently, as well as applying technology and coordination to the task of
controlling smoke.
Owing to the considerable risk to health and involvement of multiple sectors, burning
and the resulting smoke are highly regulated and are a joint concern of several levels
and divisions of government. They will be discussed at length in the Background Section
of this document.
Along with government bodies, a number of other stakeholders share the responsibility
of protecting our air and health from the effects of biomass smoke. These include civil
society groups like the Sea to Sky Clean Air Society - a non-profit with a mandate to
protect the quality of air in the region by implementing the Air Quality Management
Plan, which has in turn provided the directive for this Framework. Members of key
industries, (e.g. forestry, wood processing industries, farming, construction and waste
management) as well as First Nations also play a critical role in managing this important
resource.
7
Sea to Sky Air Quality Coordinating Committee. (2007). Our Plan to Share the Air: Sea to Sky Air Quality
Management Plan, http://seatoskyairquality.ca/wp-content/uploads/aqmp2007.pdf, pg. 22
8
See: http://bcwildfire.ca/prevention/PrescribedFire/
8
Stakeholders share a common interest in not only protecting air quality in the airshed,
but also finding economically viable and environmentally sound uses for waste products
that might otherwise be burned. Finding alternative uses for wood residues, for fibre or
energy recovery for example, not only eliminates the source of emissions, it has the cobenefit of stimulating the local economy by capturing added value from a precious
resource.
The intention of the Framework is to: provide an overview of policies and practices that
relate to open burning in the airshed; clarify policy language and harmonize policy
intentions where needed; describe stakeholder perspectives and their opportunities and
obstacles in managing biomass more effectively; and to recommend options for
avoiding burning and the smoke emissions it causes, as well as mitigating human
exposure to unavoidable smoke emissions.
Vision
The Stakeholder Advisory Group envisions a future in which the clean air of the Sea-toSky Airshed is protected; air contaminants from smoke are avoided whenever possible
to ensure the health of residents and visitors, and the scenic views they enjoy are
secure; communities are safe from forest fire hazards; and local resources such as
biomass are utilized effectively and sustainably, providing tangible and substantial
benefits to the economy and environment of the region.
The Stakeholder Advisory Group imagines a region in which all airshed stakeholders government, civil society, industry, First Nations and residents - work collaboratively to
find alternatives to burning, principally through cost-effective and environmentally
sound management of biomass resources. This will serve the dual priorities of reducing
forest fire hazards (and liability) related to the accumulation of woody debris and other
forms of land debris, and minimizing smoke emissions, while supporting regional
economic diversification through new jobs and industries, reducing energy imports, and
contributing to a healthy living environment enjoyed by both residents and visitors.
Values
Working collaboratively to develop and implement strategies throughout the airshed
that manage biomass burning and smoke control towards 1) protecting public health
and safety, 2) supporting flourishing local economies and environments, and; 3) moving
communities and industries closer to ‘zero waste’ are the key values underlying this
vision.
Objectives
To achieve this vision, and contribute to an over-arching management strategy for the
airshed, the Stakeholder Advisory Group developed two key objectives that guide the six
recommendations and numerous actions detailed in Section 5. The objectives are as
follows:
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Sea to Sky Burning and Smoke Control Strategic Framework
Objective 1. Reduce the amount of biomass disposed of through burning, notably wood
residues, as well as land and garden debris, while continuing to abate fire hazards.
Objective 2. Apply appropriate technology and burning methods to unavoidable burns,
in order to reduce smoke emissions and human exposure to smoke emissions.
Principles
Applied to the aforementioned objectives and recommendations to follow, are these
general principles:
Adaptable- the framework will be flexible enough to adapt to changing
regulatory, economic and environmental conditions.
Balanced- competing stakeholder priorities shall be address through balanced
recommendations and equitable actions.
Collaborative- the framework will be developed and implemented by
stakeholders that work together to achieve mutually desired outcomes.
Cost-effective- recommended measures will be economically viable and will not
place burdensome costs on stakeholders. Rather measures will aim to
significantly contribute to local industries, economies and employment, while
minimizing environmental and social costs.
Inclusive- a diverse group of stakeholders representing a cross-section of airshed
stakeholders will participate in crafting and executing this framework.
Innovative- an imperative to develop regional capabilities in improved methods
and technologies around biomass management, burning and smoke control will
be recommended.
Science-Based- measures will be rooted in science drawn from several disciplines,
including environmental and health sciences, forestry and agriculture and waste
management.
Zero Waste- an imperative to conserve and recover local resources towards
minimizing all forms of waste and toxic build-ups. Identifying synergies between
industries such as converting by-products from one industry into inputs for other
industries (closing the loop) is key. Ensuring all biomass is source-separated,
sustainably sourced, and the by-products of another activity is embedded in this
principle.
10
Biomass Management Hierarchy
One of the key principles for the BSCSF is Zero Waste, which is largely reflected in the
Biomass Management Hierarchy (see Figure 1) that has been used to prioritize the
Framework’s recommendations. The biomass management hierarchy was provided by
the BC Smoke Management Framework9 and while two of its strategies, “Energy
Recovery” and “Disposal” are not aligned with the concept of Zero Waste, they are
provided as options after the higher priority Zero Waste strategies; “Reduce,” “Reuse,”
“Recycle / Compost” have been reasonably exhausted.10
Figure 1- Biomass Management Hierarchy
Source: BC Smoke Management Framework
Examples to illustrate the categories in Figure 1 are taken from the BC Smoke
Management Framework. They are:
• Reduce – Reducing waste biomass could be done by changing harvest practices or
increasing use of the harvested biomass. Also, leaving some waste biomass on
the landscape may be ecologically desirable in agriculture or forestry.
9
Freedman, Rebecca, et al. (2011). A Smoke Management Framework for British Columbia: A Crossgovernment Approach to Reduce Human Exposure to Smoke from Biomass Burning;
http://www.bcairquality.ca/reports/pdfs/smoke-management-framework-20110722.pdf, pg. 15.
10
Energy recovery is used here to consider projects that derive energy from source-separated biomass,
not inorganic waste (garbage). Traditional waste-to-energy projects or any projects that create a reliance
on waste are not recommended. Stakeholders were not in agreement on how best to categorize
bioenergy. Some felt it belonged under the recycling category and should be considered a true Zero
Waste strategy. For the purposes of this Framework, the boundaries between some of the categories are
considered to be somewhat fluid.
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Sea to Sky Burning and Smoke Control Strategic Framework
• Re-use – Some biomass products, especially in agriculture, can be re-used for their
original purpose. An example is the re-use of fence posts.
• Recycle or Compost – Residual biomass can be recycled by diverting it into the
manufacture of useful products such as engineered wood products, animal
bedding and mulch. Compost and soil amendment is another recycled product of
waste biomass.
• Energy Recovery – Waste biomass is burned for energy to power industrial processes,
to generate electricity, or to heat buildings. The desirability of energy recovery
from biomass is highest for options that include advanced emissions controls.
• Disposal – Waste biomass may be landfilled, incinerated, or open-burned. The
relative desirability of these options depends on location and other factors.11
11
Freedman, Rebecca, et al. (2011). A Smoke Management Framework for British Columbia: A Crossgovernment Approach to Reduce Human Exposure to Smoke from Biomass Burning;
http://www.bcairquality.ca/reports/pdfs/smoke-management-framework-20110722.pdf, pg. 16.
12
BACKGROUND
The Sea-to-Sky Airshed is bounded by Bowen Island in Howe Sound to the south, to
Pemberton Valley in the north. It includes communities along the eastern and western
shores of Howe Sound, such as parts of West Vancouver, Gibsons, Langdale, Lions Bay,
and Squamish, and along Highway 99 including Whistler and Pemberton. The geographic
features and meteorological conditions of the Sea-to-Sky Corridor can result in poor air
circulation, which can cause pollutants to become trapped. In addition to Howe Sound,
which acts as a funnel channeling air from the Sunshine Coast and Greater Vancouver
up into Squamish, the rest of the region is comprised of a host of peaks, valleys, and
associated inversions.12
Fig. 2 Sea-to-Sky Airshed
Image Courtesy: Natural Resources Canada and the Geological Survey of Canada
The configuration of the airshed and its propensity for trapping smoke emissions,
combined with the region’s high priority on clean air for health, tourism and
12
Sea to Sky Air Quality Coordinating Committee. (2007). Our Plan to Share the Air: Sea to Sky Air Quality
Management Plan, http://seatoskyairquality.ca/wp-content/uploads/aqmp2007.pdf, pg. 2.
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Sea to Sky Burning and Smoke Control Strategic Framework
recreational values provided the impetus to create the AQMP, from which this BSCSF
has emerged.
Since the late 1990’s, pollutants such as PM have been identified by MoE as
approaching levels of concern to human health in the Sea-to-Sky Airshed.13 This trend
has also been observed provincially; “Biomass burning is the dominant contributor of
PM emissions on a province-wide scale.”14 The following provincial sources and key
emissions are shown in the graph below.
*Open burning includes pile burning of forestry, agricultural, and land-clearing debris and controlled
burns for ecosystem restoration, fuel reduction, and ecosystem health.
Source: BC Smoke Management Framework
More work is needed in the Sea-to-Sky Airshed to develop an updated and more
comprehensive emissions inventory that similarly identifies specific emissions sources.
Indeed, it is one of the recommended actions of this Framework. In the absence of such
data, stakeholders have offered observations and information related to burning
practices in the airshed, as detailed below.
13
Stantec Consulting, (2011). Sea to Sky Clean Air Annual Report, 2010;
http://www.seatoskyairquality.ca/wp-content/uploads/S2S2010AnnualReport.pdf
14
Kellerhals, Markus, (2011). Biomass, Climate and Health: A.B.C Government Perspective;
http://www.bc.lung.ca/association_and_services/documents/KellerhalsBiomassClimateandHealth_BCLun
g_AQAH__2011_03_08.pdf
14
Regional Burning & Smoke Control Practices
Image courtesy of MoE
Burning
Key burning activities in the airshed include the use of woodstoves and other burning
appliances (heaviest during the cold winter months), episodic forest fires (primarily in
the hot summer months), and the disposal of biomass residues from construction, land
clearing and agricultural industries, as well as residential gardening. Recreational
burning (e.g. campfires) also contributes smoke emissions (largely during the summer),
though it is not known to what degree. This presents challenges in terms of monitoring
burning activities, ensuring regulations are being followed, and developing programs
that promote alternatives.
Of particular concern, are the number of woodstoves and fireplaces burning wood in
communities throughout the airshed. Such burning is done within communities, often
simultaneously (i.e. in response to cooler temperatures), potentially compromising
peoples’ immediate neighbourhood air quality. Air quality is further compromised when
unseasoned wood (i.e. has a higher moisture content than 20%) is burned, which emits
more smoke and harmful emissions. that has not been seasoned.15 Provincial surveys
have been conducted periodically (including most recently in 2012) to determine wood
burning practices and attitudes towards the practice, but a more granular study of this
region would be helpful in addressing the issue. As such, it is one of the recommended
actions.
Backyard burning, though less prevalent (owing to a number of municipalities that have
banned the practice), is a concern owing to its wasteful nature and its proximity to
people within communities. Work is being done to direct garden debris and yard waste
into the composting stream, and the Recycling Council of BC (RCBC) has even published
15
Kellerhals, Marcus. Wood Burning Emission Inventory and Behaviour / Opinion Survey, Webinar
Presentation, June 6, 2013
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Sea to Sky Burning and Smoke Control Strategic Framework
a directory of alternatives to open burning for regional districts across the province.16
Recreational burning is another common burning practice that happens variably
throughout the airshed and time of year. “Concerns with backyard bonfires are similar
to those with backyard waste burning, although the fuel quality is usually better, fire
sizes smaller, and fire duration often shorter.”17 Restrictions vary between communities
and are subject to changes based on fire danger (e.g. Low Moderate High Extreme).18
Education campaigns including signage at parks and campgrounds help raise awareness
of air quality issues stemming from campfires.
Also, of concern are the increasing number of slash piles in the working forest,
surrounding communities such as Squamish and Pemberton. As Derek Lefler, Fuels
Management Specialist with the Coastal Fire Centre notes;
At present, there is not a viable option for utilizing this material and it is
likely that these piles will be burned by the Licensees in order [for them] to
comply with a legal order to abate issued from the Coastal Fire Centre.
Given the number of harvest blocks and licensees involved, these orders
could result in a fairly large burning program in order to remove the
backlog, with potential impacts to air quality simply due to the large
volume of piles, varying levels of decay and pile construction quality. This,
of course, is not the ideal situation, as burning is always intended to be the
last resort for dealing with logging slash, and when conducted by
responsible, experienced professionals incrementally year after year, should
have very minimal effect on air quality and public health. However, we are
quickly reaching the point where short-term air quality may need to be
impacted in order to reduce the long term potential for a catastrophic
wildfire event in the Sea to Sky corridor (Feb, 2013).
Work is currently underway to gain a better grasp on the amount, location,
obligation (i.e. ownership), and age of these unabated harvest openings, with the
result being a spatial and temporal prioritization of areas needing to be addressed.
16
See: http://www.bcairquality.ca/topics/rcbc-alternatives.html
Freedman, Rebecca, et al. (2011). A Smoke Management Framework for British Columbia: A Crossgovernment Approach to Reduce Human Exposure to Smoke from Biomass Burning;
http://www.bcairquality.ca/reports/pdfs/smoke-management-framework-20110722.pdf, pg. 25.
18
See: http://bcwildfire.ca/weather/maps/danger_rating.htm
17
16
Smoke from Forest Fire, Image Courtesy of Ministry of Environment
Smoke Control
The fact that emissions’ sources are largely dispersed and episodic throughout the
airshed makes prioritizing smoke abatement problematic. For many stakeholders, wood
smoke is deemed both a small issue and a large issue, depending on a confluence of
factors such as timing and duration of smoke event, weather conditions, amount of
smoke, and degree of human exposure, especially by sensitive populations. Myriad
smoke control methods are available to minimize emissions and human exposure to
emissions, with some used more frequently throughout the corridor than others.
Available smoke control methods include: air curtains and forced air devices applied to
large open burns; burning during prescribed periods when atmospheric conditions are
favourable for smoke dispersion;19 adhering to appropriate burning set-backs as
described in the OBSCR; and using ‘seasoned’ wood (properly dried firewood) for
burning in efficient wood burning stoves with an EPA or comparable certification.
Ministry of Forests Lands Natural Resource Operations (MoFLNRO) has developed a set
of Best Management Practices (BMPs) for woody debris management from forest
harvesting operations (see Appendices) that describe suitable burning practices and
smoke control methods, notably making the suggestion to; “consider alternative
methods for fuel hazard abatement including salvage, chipping, hog fuel, firewood
19
As determined by the Environment Canada (EC) Ventilation Index and required under the Provincial
Open Burning Smoke Control Regulation [OBSCR]; the regulation that sets out the conditions under which
the open burning of vegetation debris may be authorized. For more information on the Ventilation Index,
visit: Explanation of VI http://www.bcairquality.ca/readings/ventilation-index.html
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Sea to Sky Burning and Smoke Control Strategic Framework
cutting and other minor forest products extraction.”20 The BMPs also outline proper
training protocols, pile construction and guidelines for ignition that when followed serve
to greatly reduce smoke. Individuals and companies involved in disposal of land clearing
debris from development activities could considerably improve their burning practices
by adoption of applicable areas of these BMP’s, which is supported by Recommendation
2.2.3 of this framework.
Challenges do exist for the forestry and logging industry in following these guidelines as
well as the OBSCR venting requirements, as favourable venting ‘windows’ can be
infrequent, and lead times can be too short to enable mobilization of burn resources
(i.e. venting forecasts are only determined on the morning of each day, leaving little
time for mobilization). It has also been argued that the limited Ventilation Index sites
produced by Environment Canada do not always reflect the site-specific conditions
where burns are located. In response, MoE and MoFLNRO have collaborated to run a
‘custom venting’ program available during recent Fall burning seasons. Under this
program prospective burners can contact a qualified forecaster to produce a sitespecific venting forecast for their location. In some cases, the custom forecast,
reflecting local atmospheric conditions and terrain considerations, offers an opportunity
to conduct a burn that would otherwise be prohibited under the Environment Canada
produced Ventilation Index. It also provides for some lead-time in that it can be
provided a day in advance of a burn, allowing for mobilization of workers and
equipment. However, there is a fee for this service and no guarantee that the custom
forecast will be different from the EC forecast, and it is only available in the Fall burning
season.
Another approach adopted by several MoE Regions (e.g. Vancouver Island, Skeena) has
been development of Smoke Management Plans in which the signatories to the Plan
(usually, forest companies or licensees and government agencies – MoE, MoFLNRO)
agree to cooperate in managing burning and smoke emissions over a prescribed area.
Some important components of these Plans include flexibility around venting
requirements for burns in areas considered unlikely to result in impacts to communities,
cooperation between burners to avoid the cumulative impacts of concurrent burns and
commitments to use BMP’s, as well as increased opportunities for alternative uses for
residual woody debris.
Another key method of minimizing human exposure to smoke is through informing the
public of burn times, location, and prevailing weather conditions, as well as
communicating real-time pollutant monitoring information, so that citizens can
minimize their exposure to this source of pollution.21 Information on current venting
conditions and air quality is available through the BC Air Quality website:
20
MoFLNRO, Best Management Practices SEVI 2012-2014
Freedman, Rebecca, et al. (2011). A Smoke Management Framework for British Columbia: A Crossgovernment Approach to Reduce Human Exposure to Smoke from Biomass Burning;
http://www.bcairquality.ca/reports/pdfs/smoke-management-framework-20110722.pdf, pg. 18.
21
18
http://www.bcairquality.ca
Policies
In general, air quality and emissions management in Canada is a shared responsibility
and follows a hierarchical approach with lower levels of government able to establish
more stringent criteria and requirements within the limits of their jurisdictional powers.
The federal government usually focuses on issues of national and international
importance, while Provinces and Territories have primary responsibility over air quality
and emissions management within their geographical boundaries. The Canadian Council
of Ministers of the Environment (CCME) provides a forum for representatives of the two
levels of government to discuss issues of national significance and develop strategies
and criteria. Local regional and municipal governments are able to develop bylaws and
regulations under the authority provided by the Local Government Act and Community
Charter.
The following is a summary of key legislation and policies that pertain to biomass
burning, smoke control and waste disposal in the airshed. This legislative summary is
largely taken from the BC Smoke Management Framework.22
Federal
Canadian Environmental Protection Act (CEPA).
• CEPA outlines national air quality objectives, guidelines and standards and is
administered by the Government of Canada.
• A national air quality and emission management approach, formerly known as
the Comprehensive Air Management System (CAMS) and now renamed the Air
Quality Management System, is currently under development with the
cooperation of the Provinces and Territories through the Canadian Council of
Ministers of the Environment (CCME). The AQMS will include revised ambient air
quality criteria, establishment of airsheds and zones across Canada and sectorspecific industrial emission requirements.23
• In 2000, the CCME endorsed the Canada-wide Standards (CWS) for Particulate
Matter (PM) and Ozone, which committed signatories to implementation of
specified actions to ensure achievement of the numerical standards by 2010. In
developing the CWS, the CCME acknowledged that there are differences in air
quality between jurisdictions and that governments should take steps to ensure
air quality is protected where needed through regulations and management
approaches that may be more stringent than national standards. 24
22
Freedman, Rebecca, et al. (2011). A Smoke Management Framework for British Columbia: A Crossgovernment Approach to Reduce Human Exposure to Smoke from Biomass Burning;
http://www.bcairquality.ca/reports/pdfs/smoke-management-framework-20110722.pdf, pg. 31-35.
23
Comprehensive Air Management System,
http://www.ccme.ca/assets/pdf/cams_proposed_framework_e.pdf
24
See: https://www.ec.gc.ca/lcpe-cepa/default.asp?lang=En&n=26A03BFA-1
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Sea to Sky Burning and Smoke Control Strategic Framework
Provincial
Environmental Management Act (EMA)
•
•
•
•
The EMA aims to protect human health and the quality of water, land, and air in
B.C., applying environmental management tools, within a flexible authorization
framework that includes a range of enforcement options to ensure compliance.
One of the major changes brought forward with the current EMA is the way in
which MoE authorizes the introduction of waste into the environment. Under
the Waste Management Act, which preceded EMA, all introductions of waste to
the environment, whether from a pulp mill or a car wash, required some form of
authorization, such as a permit or approval. Under sections 6(2) and 6(3) of the
EMA, only introductions of waste from prescribed industries, trades, businesses,
operations, and activities require authorization.
Industries, trades, businesses, operations, and activities are prescribed in the
Waste Discharge Regulation
If an industry, trade, business, activity, or operation is not prescribed by the
regulation, then it does not require an authorization to introduce waste into the
environment. However, the discharge must not cause pollution (EMA section
6(4)). 25
Waste Discharge Regulation (WDR)
•
•
•
In the context of section 6 of the EMA, the WDR serves two purposes:
It prescribes in schedule 1 the industries, trades, businesses, operations, and
activities that must obtain authorization before introducing waste into the
environment (sections 6(2) and 6(3)). Burning of vegetative debris, burning or
incineration of waste, and burning or incineration of wood residue are included
here.
It prescribes in schedule 2 those industries, trades, business, operations, and
activities that may be exempt from sections 6(2) and 6(3) through compliance
with a code of practice if an applicable code has been issued for their waste.
Those industries, trades, businesses, operations, and activities that the WDR
does not prescribe in Schedules 1 or 2 do not require an authorization to
introduce waste into the environment. However, they must not cause pollution
as in section 6(4). 26
Wood Residue Burner and Incinerator Regulation (beehive burners)
•
25
26
The Wood Residue Burner and Incinerator Regulation (under the EMA)
establishes the phase-out dates and operating conditions for specified burners
and sets fees for the discharge of associated particulate matter for all burner
See: http://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/03053_00
See: http://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/50_320_2004
20
facilities in the province.27
Open Burning and Smoke Control Regulation (OBSCR)
•
•
•
The current OBSCR governs the burning of vegetation associated with a range of
activities, including land clearing and forestry-related resource management. It
sets out the conditions under which the open burning of vegetation debris may
be authorized. A checklist is provided to ensure the regulation is followed.28
The OBSCR is undergoing revisions that are set to be finalized by Fall or early
Winter 2013.29
The proposed changes may include: the establishment of smoke-sensitivity
zones based on population density; primary smoke sensitivity zones (PSSZ)
where risks of burning are higher (200 people or more per square kilometres,
plus a 10km buffer) and less densely populated secondary smoke sensitivity
zones (SSSZ) where risk is lower, but not insignificant. The scope of the
regulation may also be expanded to include open burning at dry land sorts
(previously called “log sorts”) and the development of best management
practices for burning.
Solid Fuel Burning Domestic Appliance Regulation (SFBDAR)
•
•
•
The SFBDAR aims to reduce air pollution from domestic wood heating by
regulating the sale of woodstoves and other solid fuel burning domestic
appliances in B.C.
Proposed revisions arising from the 2010 intentions paper
(http://www.env.gov.bc.ca/epd/codes/solid-fuel/pdf/intentions-paper.pdf) will
aim to further reduce impacts on human health and ecosystems by further
reducing air pollution from domestic wood heating.
Considerations include: lowering particulate matter emission standards for
woodstoves and fireplace inserts covered by the regulation, expanding the scope
to include both indoor central heating appliances (such as forced air furnaces),
outdoor central heating appliances (known as outdoor boilers or outdoor woodfired hydronic heaters), and cooking stoves.30
Agricultural Waste Control Regulation (AWCR)
27
See: http://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/51_519_95
See: http://www.env.gov.bc.ca/epd/regions/skeena/air/burning/Checklist-2009.pdf
29
The 2010 intentions paper, based on feedback for a new approach is available here: www.env.gov.
bc.ca/epd/codes/open_burning/index.htm
30
See: http://www.env.gov.bc.ca/epd/codes/solid-fuel/index.htm
28
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March, 2013
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Sea to Sky Burning and Smoke Control Strategic Framework
The AWCR was amended in 2008 to set more stringent emissions limits along
with registration, monitoring, reporting, and record keeping requirements for
agricultural biomass-fired boilers.31
Public Health Act (PHA)
•
•
The Public Health Act provides the Minister of Health Services, public health
officials, regional health authorities, local governments, and others with the
authority to define, monitor and control health hazards. It offers important tools
such as up-to-date information gathering abilities, modern inspection, and
ordering abilities, and other measures necessary to respond to public health
emergencies.
By prescribing a health impediment, regulations can be developed that apply to
those who engage in the prescribed activity.32
Clean Energy Act
•
This act encourages use of clean or renewable resources for energy needs, while
reducing waste, which supports the hierarchy of biomass management described
in this framework.33
Wildfire Act and Regulation
•
Numerous sections in the Wildfire Act and Regulation apply to the use and
application of fire. However, neither specifically addresses smoke. Provisions
range from defining categories of fire, when fire may be used or alternatively
restricted, managing fuels, and providing for the requirement for a burn
registration number.34
Farm Practices Protection (Right to Farm) Act (FPPA)
•
•
31
FPPA protects farmers that are using normal farm practices from nuisance
lawsuits and nuisance bylaws of local governments, including those related to
odour, noise, dust or other disturbance resulting from a farm operation that is
part of a farm business.
The Act also establishes a process to resolve concerns and complaints.
See: http://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/10_131_92
See: http://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/00_08028_01
33
See: http://www.leg.bc.ca/39th2nd/1st_read/gov17-1.htm
34
See: Wildfire Act: http://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/00_04031_01
See: Wildfire Regulation:
http://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/11_38_2005
32
22
•
The farm operation must not contravene the Public Health Act, Integrated Pest
Management Act, Environmental Management Act, the regulations of those acts,
or any land use regulation. 35
Local Government
The Local Government Act & Community Charter (Municipal & Regional District
Bylaws)
•
•
•
•
•
The Community Charter provides the authority for municipalities and regional
districts to enact bylaws that address issues not covered by provincial legislation
or that are more restrictive than provincial legislation.36
Municipalities typically enact bylaws for backyard burning of vegetative debris
and for installation and use of residential wood heaters. In some cases, bylaws
include provisions that govern activities also covered by the OBSCR.37
A number of municipalities in the airshed also influence local burning practices
through bylaws that regulate and set tipping fees for waste, notably for back
yard debris and wood waste. “Pay as you throw” is an important principle for
implementing Zero Waste as are other regulations (e.g. burning bans) and
incentives that support desired behaviour where waste is concerned. Free yard
waste drop-off days, provided in the spring and fall are initiatives in several
airshed communities (e.g. Whistler, Lions Bay) that incentivize residents to dropoff their yard waste (in Whistler for use in the industrial composter) rather than
burn it or mix it with trash. Bowen Island offers weekly year round pick-up of
yard waste as part of its organics program.
A number of communities have solid waste plans or are in the process of
developing a solid waste plan, aiming to achieve zero waste. This same ethos is
often articulated in communities’ Official Community Plan, another policy tool
governed by the Community Charter.
The Ministry of Environment has developed a model backyard-burning bylaw
that local governments can use as the basis of their own bylaw.38
35
See: http://www.alc.gov.bc.ca/alr/fppa.htm
See:
http://www.cscd.gov.bc.ca/lgd/gov_structure/community_charter/concordance/local_government_chart
er.htm
37
See appendix for a complete list of local bylaws related to burning in the Sea-to-Sky Airshed
38
See: http://www.bcairquality.ca/reports/pdfs/model-bylaw-backyard-burning.pdf
36
23
March, 2013
•
•
Sea to Sky Burning and Smoke Control Strategic Framework
The Sunshine Coast Regional District regulates burning practices through its Fire
Protection Bylaw No. 631, 2001 and manages waste that directs burning
practices (i.e. by setting tipping rates for wood waste and yard waste) through its
Solid Waste Management Plan: The Foundation for Zero Waste (2011).
Currently, the Squamish Lillooet Regional District has no explicit restrictions on
burning or smoke control, however, it influences burning practices through its
Refuse Disposal Site Tipping Fee, Bylaw No. 202, 2004. The District’s Solid Waste
Management Plan also makes reference to developing a ban on open burning in
the future.39
Programs
There are several provincial programs that are also active in the airshed intended to
complement the aforementioned legislation and policies. Two notable ones include:
BC Woodstove Exchange Program
• The Provincial Wood Stove Exchange Program provides financial incentives for
upgrading old wood stoves, in addition to educating wood burners on how to
improve their burning practices.
• By the end of 2012, over 5,000 old stoves are expected to have been exchanged
for cleaner burning models. This equates to a reduction of over 310 tonnes of
PM2.5 per year.40 In this airshed over 70 rebates have been provided to area
woodstove owners, encouraging them to replace their old woodstove with a
newer, cleaner burning one.
• Complementing this program is the Burn It Smart Program, an educational
initiative that provides woodstove owners with information and tools to build
hot, efficient fires that produce minimal amounts of smoke.
Image Courtesy of Ministry of Environment
39
Gartner Lee Limited (2007), Prepared for the Squamish Lillooet Regional District Solid Waste
Management Plan: Update: http://bit.ly/173CkhI, pg. 2-5
40
See: http://www.bc.lung.ca/airquality/documents/StateOfTheAir2012-Web.pdf
24
The Strategic Wildfire Prevention Initiative (SWPI)
• SWPI provides a number of funding options for communities to mitigate risk
from wildfire in the wildland urban interface; “any area where combustible
wildland fuels (vegetation) are found adjacent to homes, farm structures or
other outbuildings.”41 This initiative is coordinated by the Provincial Fuel
Management Working Group.
Biomass Potential & Challenges
According to the BC Sustainable Energy Association; “woody biomass can be used
effectively and sustainably to reduce fossil fuel consumption for commercial,
institutional, municipal and micro grid district heating deployments.”42
Indeed, a pre-feasibility study conducted by Whistler that “screened a wide variety of
potential fuel sources” determined that biomass was the preferred alternative fuel
option for a potential District Energy System.43
There are many potential applications for biomass residues (primarily the by-products of
forestry and timber harvesting activities), many of which are in effect throughout the
airshed. Dry land log sort wood waste represents a major volume of material, some of
which is mulched for landscape material rather than burned as previously done.44
Fraserwood Industries Ltd. has for several years utilized much of its own wood wastes as
boiler fuel for space heating its factory premises. Howe Sound Pulp & Paper Ltd. is an
ongoing purchaser of wood wastes from forestry and forest industry, as well as
municipal landfill operations in this region, which it uses for its cogen operation
(providing heat and electricity to its mill).
These instances aside, biomass applications have not yet reached their full potential in
the region. For adding value to small quantities of dispersed waste biomass they appear
promising to varying degrees. Some view such applications as future, not present,
alternatives to burning, owing to the high cost of access (i.e. transportation and
handling) combined with the relatively low-value of biomass products and fuels
(compared to alternative cheaper fuels) in the region.
The desire to find ways of capturing additional value from residual biomass, especially
for biofuels and bioenergy, is however, building in momentum, not least of which is
coming from the Province. The BC Bioenergy Strategy, in support of commitments made
41
See: https://ground.hpr.for.gov.bc.ca
BC Sustainable Energy Association (2013) Biomass Heating: This Ain’t Your Grandpa’s Old Wood Stove
http://www.bcsea.org/sites/bcsea.org/files/bcsea_webinar_2013-01-15_v3.pdf)
43
FBV Energy (2012). Whistler Pre-Feasibility Study, prepared for the Resort Municipality of Whistler, pg. 8.
44
Until quite recently, dry land log sort operators were simply given open burning permits (e.g., Black
Mount Logging Ltd., at Watts Point; and others near Pemberton) (Eric Anderson, SquamishCAN, March
2013).
42
25
March, 2013
Sea to Sky Burning and Smoke Control Strategic Framework
in the BC Clean Energy Plan, has set forth a number of ambitious goals, along with a
significant amount of funding to spur greater investment and innovation in BC
Bioenergy products and technologies. Specific commitments include:
 Establish $25 million in funding for a provincial Bioenergy Network for greater
investment and innovation in B.C. bioenergy projects and technologies.
 Establish funding to advance provincial biodiesel production with up to $10
million over three years.
Issue a two-part Bioenergy Call for Power, focusing on existing biomass inventory in the
forest industry.45
Wood Chipper, Image Courtesy of the Ministry of Environment
Expertise within the region and throughout the province, as well as cost-effective
models for using residual biomass with minimal smoke emissions do exist and this BSCSF
makes recommendations to identify and harness such resources. 46
Each bioenergy project should be reviewed on a case-by-case basis with the BSCSF
principles applied, as is required by law. Potential emissions and byproducts, as well as
the source of the biomass and future use of burning facilities, make the difference
between a better alternative to burning or a worse one. Another consideration is
ensuring sound ecosystem management practices are followed, and soil nutrients,
wildlife habitat and forest carbon storage capacity of the forest are not negatively
impacted by removal of biomass. Biomass energy projects considered in this document
are meant to run on waste biomass, that which is a byproduct of a primary industry or
activity and which would otherwise be burned.
45
See: http://www.energyplan.gov.bc.ca/bioenergy/
For more information on the particulars of using biomass for energy applications, see:
http://www.bcsea.org/sites/bcsea.org/files/bcsea_webinar_2013-01-15_v3.pdf
46
26
BUSINESS SECTOR PROFILES
The Sea to Sky District is an area bounded by Lions Bay in the south, Anderson Lake
in the north, and extending along the Lillooet River from its headwaters in the west
to Harrison Lake in the east. Key industries include tourism, forestry as well as
ranching and farming; all of which may involve burning activities of one type and
scale or another. In the broader Sea-to-Sky Airshed, other industries such as
development, construction and demolition, and waste management also play direct
or indirect roles in the burning of land debris and wastes.47 The following are brief
overviews of the industries directly involved in burning; respective burning practices
and smoke control methods; and the burning regulations to which they primarily
adhere.
Tourism
“The tourism industry has long been an important contributor to the economy of
British Columbia. In 2010, the BC tourism industry generated $13.4 billion dollars in
revenue, contributing $6.5 billion to the province’s GDP. BC’s tourism employment
record is equally as impressive. In 2010, there were approximately 255,000 total
tourism jobs, a number which is forecasted to grow to over 300,000 by 2020.”48
Even more than the rest of the Province, the Sea to Sky Region’s economy is tied to
tourism, and its contributions to provincial tourism revenues are considerable. Over
half of BC’s tourism-related establishments are located in the Vancouver, Coast &
Mountains region.49
47
As many as possible were invited to participate in the development of this framework, however,
there were some notable absences largely owing to time constraints.
48
See: http://www.go2hr.ca/sites/default/files/legacy/reports/go2-Data-Gaps-Analysis-Report2012.pdf
49
See: http://bit.ly/YwrmK0
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Framework
Sea to Sky Burning and Smoke Control Strategic
Outdoor recreation, featuring activities such as skiing, hiking, climbing, biking and
camping is a strong focus of the region’s tourism industry. The building of campfires,
which may accompany any of the aforementioned recreational activities, is the main
burning activity associated with this industry. They generally occur on a seasonal
basis (i.e. during summer) and while they contribute relatively little in the way of
smoke emissions to the overall airshed, they can be an air quality concern
depending on location. Burning salt-soaked wood, as is often done on beaches,
carries the additional threat of emitting dioxins and furans when burned, which are
particularly toxic. Campfires also pose the threat of causing forest fires, which can
be major threats to public safety and health.
Campfires are exempt from the OBSCR, however they are subject to the Wildfire
Regulation, as well as Burning Bans and Area Restrictions set by the Wildfire Branch
of MoFLNRO, and by Municipalities and Regional Districts, which in some instances
have set more stringent bylaws that require permits for campfires.50 Each
municipality / regional district has varying ways of classifying campfires and a
different set of regulations that pertain, which are subject to the discretion of the
designated Fire Chief in times of elevated wildfire danger, usually during the warmer
summer months.
Forestry & Timber Harvesting
“The forest industry is one of B.C.’s longest standing industries and has contributed
enormously to the province’s economic position.”51 Provincially, the forest industry
produces approximately $16 Billion in forest products annually and directly employs
over 80,000 workers.
Logging is also an important industry in the Sea-to-Sky District- an area
encompassing approximately 1,098,000 hectares. Approximately 40% of the region
is forested with temperate rain forest and transitional interior forest, made up
primarily of coniferous and some deciduous trees.
As part of the BC Forest Service;
25 personnel in Squamish (representing Field Services, Resource
Management Coordination Division, First Nations Consultation, BC
Timber Sales, Wildfire Management Branch, Recreation Sites and
Trails) are responsible for administering Crown land and forest
resources in the field, and for ensuring that resource use by the public
and forest industry is consistent with current legislation.52
50
One example is the RMOW, Fire Protection and Fireworks Bylaw NO. 1956, 2010,
http://www.whistler.ca/sites/default/files/bylaws/1956_2010.pdf.
51
Czuczor, Andy, Brooke Hanson, Andrea McLean, Maggie Skiber,
http://torc.linkbc.ca/torc/downs1/SquamishForestryCentreBusinessPlanFINAL.pdf.
52
See: http://www.for.gov.bc.ca/dsq/
28
The annual district expenditure for forest resource management, forest investment,
and the BC Timber Sales Program is $6 million. Annual stumpage revenue is
approximately $23 million.53
Logging, sawmills and the pulp and paper industries have traditionally been and
continue to be important sources of employment throughout the region. Prior to
being shut down in 2006, Western Forest Products pulp mill and before that the
International Forest Products (Interfor) sawmill had been Squamish’s largest
employers. Howe Sound Pulp and Paper (HSPP) in Port Mellon on the Sunshine
Coast (55 kilometres north of Vancouver in Howe Sound) remains and employs a
significant number of local residents, approximately 500.54
There are several burning activities associated with the forestry and timberharvesting sector, which have already been mentioned in this Framework. They
include prescribed burning for resource management and ecosystem applications
with the objectives of helping to grow better forests, creating better habitat for
wildlife and domestic animals, reducing the intensity of naturally occurring wildfires,
and returning an integral process to some ecosystems. Prescribed fires are subject
to extensive planning, monitoring and certification protocols as described in the
Wildland Fire Management Strategy55 and enforced under the Wildfire Regulation.
They are managed in such a way as to minimize the emission of smoke and
maximize the benefits to the site.
On the timber harvesting side, burning is intended to be used as a least preferred
method of disposing of unwanted, typically uneconomical, biomass (e.g. slash piles).
Such biomass is a by-product of timber activities and disposing of it through burning
is done in order to abate the forest fire hazard it poses (as required by the Wildfire
Act and Regulation). Such burning must conform to the provisions contained within
the Open Burning and Smoke Control Regulation (detailed in the previous section),
administered by the MoE. Additionally, pile size and type, proximity to urban or
forest values and suppression methods are regulated through the Wildfire
Management Regulation. Burns are conducted by experienced professionals that
have obtained a Burn Registration Number from the Coastal Fire Centre, Wildfire
Management Branch.
There are a number of wood processing plants in the region, as well as one sizeable
pulp and paper operation- Howe Sound Pulp and Paper (HSPP). Biomass burning is
part of their operations, used for energy and / or heat applications. HSPP has the
largest cogeneration plant in the region using waste biomass to generate electricity
53
MoFLNRO, http://www.for.gov.bc.ca/dsq/
Howe Sound Pulp & Paper,
http://www.profilecanada.com/companydetail.cfm?company=121682_Howe_Sound_Pulp_Paper_Lt
d_Port_Mellon_BC
55
MoFLNRO , http://bcwildfire.ca/Prevention/PrescribedFire/docs/BCWFMS.pdf
54
29
March, 2013
Framework
Sea to Sky Burning and Smoke Control Strategic
and heat for its mill. Dry land log sort wood wastes operations account for a very
large volume of the wood wastes in this region and are the focus of a number of
actions recommended in this Framework.
Farming and Ranching
Despite using less than three per cent of the provincial land base (2.6
million hectares) 20,000 farms produced more than 200 agriculture and
agri-food commodities in BC in 2011. Provincial agriculture farm cash
receipts for grains and oilseeds, tree fruits, berries, grapes, field and
greenhouse vegetables, floriculture, nursery, forage and other crops,
cattle, hogs, poultry, eggs, dairy, honey and other animals and animal
products totaled $2.6 billion in 2011.56
Each of the three larger communities (Squamish, Whistler, and Pemberton) in the
airshed offers both similar and different opportunities around food production. Each
community has at least one community garden operating, many backyard gardens
for personal and/or other consumption. There are some working farms in the
Squamish and Pemberton areas that produce food for cost. It was estimated that
there are 15 to 20 large farms (i.e. over 200 acres) operational in the corridor with
full-time farmers and approximately 40 small farms.
While food was the original industry in Squamish, with a hay ranch occupying what
is now downtown Squamish and Brackendale being home to dairy and hop farms,
this is no longer the case. There are a few small farms in Squamish and Paradise
Valley where food is grown on a small scale.
In Whistler, the value of locally grown food is increasing in the community. Currently
there are three community greenhouses in which food is grown through the spring
and summer. There are plans to expand the project and to have greenhouses
growing food throughout the year, pending access to funding. There is a farmer’s
market, and several large greenhouses.57 Squamish is following a similar trajectory
and has similar plans.
Farming has been a mainstay of the Pemberton Valley economy since Europeans
first settled here more than 100 years ago and continues to be a strong part of the
community economy. Led by the multi-million dollar seed potato industry,
Pemberton agriculture also includes a growing organic sector, farm gate operations,
equestrian facilities and specialty crop production. Agri-tourism has lately flourished
with events such as Slow Food Cycle Sunday, which brings over 4,000 visitors to the
valley annually. In the context of this report, it is interesting to note that the event
56
See: http://www.agf.gov.bc.ca/stats/YinReview/Agrifood-YIR-2011.pdf
Szymanski, Lydia. Kate Sutherland (2006). Community Food Action Initiative Food on EVERY Table;
http://www.vch.ca/media/CFAI_Summary_Sea_to_Sky.pdf
57
30
was cancelled in 2009 due to forest fires in the region.
Most farmers burn in the spring in order to clear up fallen branches from pastures.
Some landowners (not all of them farmers) also burn the dead grass from fields,
which apparently allows the nascent grass crop to get a head start. Some burn along
fence-lines in order to maintain the integrity of the line.
From time to time, a farmer or landowner will clear a treed section of land, which
results in significant slash piles that are eventually burned. Land clearing is usually
done by logging equipment operators, so the piles are typically built in the manner
of slash piles.58
Burning activities related to agriculture are regulated through the Environmental
Management Act: Agricultural Waste Control Regulation and FPPA as described in
the previous section. Boilers are common pieces of equipment, which burn various
kinds of fuels, commonly biomass. Burning leaves, foliage, weeds, crops or stubble
for domestic or agricultural purposes are exempt under EMA Sec. 6(5)(e), which
means the farmer is protected under FPPA, provided all other pertinent FPPA
conditions are met. Farmers must also comply with any local open burning bylaws.
In instances when they want to burn anything other than exempt items listed above,
then they must follow the OBSCR and its Code of Practice if applicable, or obtain an
authorization under section 14 of the EMA. The farmer must also comply with the
local open burning bylaw.
Development, Construction & Demolition Industries
British Columbia’s construction industry has seen phenomenal growth in recent
years. In 2008, the industry moved ahead of manufacturing to become the largest
employer in the goods sector, a position it has never held in the past.59
Employment in the industry doubled between 2000 and 2008, outpacing real GDP
growth, as investment in new buildings and infrastructure soared. Construction is
now the third largest employer in the province, providing jobs to nearly 10% of BC’s
workforce.60
In the Sea-to-Sky Airshed the development and construction industry has also
experienced a boom- although not evenly distributed throughout the region or over
time. As one would expect, the increase is largely tied to new housing, which is in
turn tied to population growth. By far the area that has experienced the largest
population growth in the airshed is Squamish, which now represents 41% of the
region’s population.61 The 2010 Winter Olympics also saw a major increase in
58
Helmer, Anna. Pemberton Farmers’ Institute.
See: http://guidetobceconomy.org/major_industries/construction.htm
60
See: http://guidetobceconomy.org/major_industries/construction.htm
61
According to the BC Census 2011
59
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construction activities with new facilities built, such as Whistler’s Sliding Centre, and
the major highway improvement project, undertaken by the S2S Transportation
Group (S2S) under the supervision of the Ministry of Transportation (MoT).62
(http://www.seatoskyimprovements.ca/procurement.htm)
Burning activities in this industry are described in the BC Smoke Management
Framework as:
[l]and clearing by individual property owners on acreages to developers
clearing areas for subdivisions. Generally, entire trees are removed, including
the root systems that contain soil. In many cases, this debris is not left to
season before it is disposed of. This results in less-than-optimal burning
because of the high moisture content and the presence of large quantities of
soil. Often, such debris is open-burned in close proximity to residences and
other existing developments.
Burners must adhere to the Open Burning Smoke Control Regulation, the Wildfire
Regulation and any Municipal bylaws. More research and engagement with this
sector is required to fully understand any barriers this sector faces in adhering to
these regulations. Some local fire departments, municipalities, and improvement
districts or regional districts in the airshed have specific bylaws on open burning that
affect land clearing activities within local jurisdictions. Where these are more
stringent, they apply over provincial regulations. It should be noted that the above
discussion relates only to burning of vegetative debris from land clearing operations.
Burning of other material related to development activities (e.g. construction or
demolition waste) would require an authorization from MoE – something unlikely to
be granted due to the potential for excessive smoke and/or toxic emissions to be
released. Options for disposing of land clearing and construction debris do exist- an
inventory of facilities that accept vegetation debris was created by the Recycling
Council of BC.63 Maintaining this list and ensuring it is kept up to date is one of the
actions recommended by this Framework.
62
63
Now Ministry of Transportation and Infrastructure (MOTI)
See: www.bcairquality.ca/topics/rcbc-alternatives.html.
32
RECOMMENDATIONS
Recommendations and actions have been developed towards fulfilling the stated
objectives. This strategy has two key objectives, with three recommendations apiece
that strategy stakeholders believe will reduce open burning and smoke emissions, as
well as result in safe and sustainable use of biomass resources in the SSCAS region.
The recommendations have been prioritized in accordance with the biomass
management hierarchy supplied by the BC Smoke Management Plan (See Fig. 1). It
should be noted that this hierarchy is a management tool that offers one approach
to prioritizing actions. It does not preclude implementing strategies from various
tiers simultaneously or in a different order. Additionally, there are some varying
opinions regarding the placement of energy recovery second from the bottom of the
pyramid as some heat substitution and energy applications can have direct and
indirect benefits that may exceed those generated from recycling or composting
biomass, while in other cases burning can be worse than landfilling.64
Each of the recommendations are followed by a number of actions that can be
undertaken by various parties, such as local governments, private and public
institutions, the provincial or federal governments.
The actions presented are intended to serve as guideposts for future planning and
implementation of the strategy. They were derived from the information developed
in preceding sections and address requirements such as research, policy, business
and social development, collaborations, infrastructure, technology, training,
communications and investment.
Actions 1.2.1, 1.2.2, 1.2.3- identify sources of PM via and updated emissions
inventory, developing a risk assessment tool regarding slash piles, and completing a
biomass inventory respectively-are deemed to be most important actions to
complete in the short-term as the resulting information supports a number of other
actions.
Further engagement with and between SSCAS and stakeholders is needed to identify
regional and local interests, and opportunities. Making new relationships a reality is
a very high priority for the initial implementation phase of all of the strategies. The
recommended studies could grow into projects, which would provide excellent
opportunities for positive and mutually beneficial engagement at the community
level. These opportunities are indicated in several of the recommended actions and
it is likely that further opportunities will be identified as the strategy is implemented.
64
Some hierarchy depictions, such as the US EPA District 9, are using the inverted pyramid to
emphasize waste reduction and make burning equivalent to other forms of disposal. See earlier
footnote regarding Zero Waste International Alliance and LCA Study.
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For the purpose of general guidance, responsibilities and time frames have been
defined. Timeframes are grouped into three categories:
• Short-term (actions to be realized within one year after the strategy is released);
• Mid-term (actions to be completed within one to five years);
• Long-term (ongoing actions and actions requiring more than five years to be
completed).
Responsibilities will be refined as each action is examined in more detail during the
implementation phase. Consideration of available resources will take place prior to
the execution of a given action, and will dictate next steps. Stakeholders will apply
best efforts to move ahead with recommended actions.
SSCAS is confident that if these recommendations and the associated actions are
implemented, the vision and objectives will be achieved.
Objective 1. Significantly reduce the burning of biomass, notably wood residues, as
well as land and garden debris, while abating fire hazards.
Recommendation 1.1: Reduce the amount of ‘waste’ biomass produced, particularly
wood residues. Waste biomass is defined as that which is subject to being disposed
of through burning (biomass only).
Rationale: Eliminates necessity of burning and associated smoke emissions, and
conserves precious resources. This recommendation and its associated actions
belong in the top tier ”Reduce;” the highest priority strategy in the Biomass
Management Hierarchy.
Specific Actions
Requirements
1.1.1
Research degree of waste
biomass currently created in
the region and investigate
models for reduction,
notably ascertain wastereduction potential of areabased model, while ensure
ecosystem needs (e.g.
nutrients) are met.
1.1.2
Work with local
governments to ensure
sustainable land clearing
practices are articulated
through OCPs, SWMPs, and
34
Target
Key Players
Timeline
Research,
Business
Development
Woodyresidues from
timber
industry
Forestry
industry,
MFLNRO, First
Nations,
Community
Forest
Mid-term
Policy,
Collaboration
Land clearing
debris, yard
waste
Municipalities,
Regional
Districts,
Developers,
MOE First
Long-term
other relevant policies and
permits (e.g. development
permits) and incentives are
in place that reward
sustainable land clearing
practices.
Nations,
1.1.3
Engage farmers towards
learning about current
practices, opportunities and
obstacles related to
minimizing agricultural
debris.
Communication,
Coordination
Agricultural
debris
Farmers,
Regional
Districts, SSCAS
Mid-term
1.1.4
Work with licensees and
timber harvesters to
determine ways of reducing
wood waste in forest
operations. Support existing
certification programs
through green purchasing.
Promote Woody Debris Flip
Chart (See appendices).
Communication,
Coordination
Woody
residues
MFLNRO,
licensees, First
Nations, local
governments
Mid-term
Recommendation 1.2- Create (non-burning related) products from sustainably
sourced ‘waste’ biomass, remove impediments of moving it through supply chain
and to available markets. Develop new products and markets where none exist.
Rationale: Eliminates smoke emissions and fire hazards, stimulates local economies
through value-add industries, and reduces CAC emissions associated with burning.
This recommendation and its associated actions focus on “Reuse/ Recycle,” the
second and third highest priorities in the Biomass Management Hierarchy.
Specific Actions
Requirements
Target
Key Players
Timeline
1.2.1 Complete updated emissions
inventory to identify main sources of PM in
airshed.
Research,
Communications
ALL
MOE, SSCAS
Short-term
1.2.2 Support and expand existing biomass
inventories in the region through increased
research and development, and information
sharing between licensees, second tenure
users and interested agencies. Explore
opportunities and incentives for [licensees]
collecting additional information and applying
to GIS platform.
Infrastructure,
Communications,
Collaboration
Wood
residues
Forestry
Licensees,
MFLNRO,
developers
Short-term
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1.2.3 Investigate feasibility of exchanging
agricultural debris for soil amendments
(create a closed loop) and align with solid
waste management directives.
Business Development,
Infrastructure, Policy
Agricultural
residue
Regional Districts,
Farmers, Waste
Management
Industry
Mid-term
1.2.4 Support composting programs for yard
waste through setting of standardized tipping
fees throughout entire region and supportive
incentives / fines/programs (including
backyard composting). Align with Solid Waste
Management Plans and Principles. Consider
banning yard waste from disposal. Promote
Recycling Council of BC (RCBC) inventory of
businesses accepting biomass debris (from
both commercial and residential sources).
Ensure list is kept current.
Policy, Infrastructure,
Communications
Residential
Yard waste,
Land Clearing
Debris
Local
governments,
regional districts,
waste managers,
residents
Mid-term
1.2.5 Source funding and resources to
support ongoing research of potential
products and markets for biomass (nonenergy / burning related. (e.g. using biomass
for raised beds) that would succeed in the
region. Bring leaders together to share ideas
and successful models from other regions.
Research, Business
Development,
Collaboration,
Communications
Wood
residues
Mid-term
1.2.6 Build on and share existing risk
assessment tools that measure liability
associated with fire hazards towards
rationalizing alternative uses of biomass.
Policy, training,
business
development
Wood
residues. Land
clearing debris
Universities,
Businesses /
entrepreneurs
Forestry
Licensees,
M0FLNRO,
developers ,
SSCAS
Forestry industry
MoFLNRO,
Developers,
Farmers
1.2.7 Source funding to conduct a feasibility
and cost-benefit study of best location(s) and
operation of collection and processing hub(s)
for biomass. Ensure new studies build on
pertinent previous studies (e.g. Whistler PreFeasibility Study for District Energy and SLRD
Organics Study).
Business
development,
infrastructure
All types of
residue and
biomass
Local
governments,
regional districts,
waste managers,
businesses
Mid-term
1.2.8 Source funding to conduct a feasibility
study of regionally appropriate second-tenure
models, focusing on surmounting the major
obstacles of access and cost.
Research, Business
Development
Wood
residues
Mid-term long term
1.2.9 Direct waste biomass (i.e.
transmission line clearing, Christmas trees,
hemp plantations) to local compost collection
facilities by finding ways of minimizing
transportation and handling costs. Consider
biogas recovery on-site.
Research,
Infrastructure,
Business
Development,
Investment
Industrial
Wood &
Biomass
Residues
1.2.10 Create policy for using wood first (local
Policy
Wood
Universities,
Businesses /
entrepreneurs
Forestry
Licensees, MoE,
MoFLNRO, SSCAS
Local
governments,
Provincial
Ministries (Mines,
Transportation)
Industry (BC
Hydro), Business /
Entrepreneurs
Local
36
Mid-term
Long-term
Long-term
government- e.g. Building Code) and other
methods for making buildings more easily
deconstructed, thus reducing wood waste
(e.g. regulating for use of screws over glue)
residues
governments,
developers /
builders, forestry
industry
Recommendation 1.3 Upon exhausting non-burning options for utilizing biomass
residues, investigate regionally appropriate energy applications for biomass. Aim to
remove impediments to the flow of wood fibre to biomass energy projects that have
high emissions standards and are scaled for the sustained supply of material once all
best practices have been followed.65
Rationale: Meets a proportion of the region’s energy needs and reduces GhG related
to the burning of conventional fuels for heating and power. This recommendation
and its associated actions focus on “Reuse/ Recycle,” the second and third priorities
in the Biomass Management Hierarchy.
Specific Actions
1.3.1 Research feasibility of slashpiles to firewood program,
addressing obstacles of handling,
and transportation costs, and
access issues. Overlay
communications objectives
regarding Smart Burning methods
onto program and build
relationships with wood suppliers.
Find ways of mitigating increase in
proximity of emissions to
residents.
1.3.2 Source funding for R&D.
Determine feasibility of biomass
energy projects in the region by
identifying consumption patterns,
trends, and potential sources of
biomass and collaborating with key
businesses throughout supply
chain (e.g. HSPP). Be sure to align
actions with policies and ensure
projects attain highest emissions
standards.
Requirements
Research, Business
Development,
Infrastructure, And
Investment
Requirements.
Research, Business
Development,
Infrastructure,
Training, And
Investment
Requirements, Policy
Target
Key Players
Timeline
Wood Residues
Forestry Industry,
MFLNRO, First
Nations,
Businesses,
Residents, Wood
Suppliers
Mid-term
Wood Residues,
Industry Residues
Forestry Industry,
Businesses, First
Nations, Local
Governments /
Regional Districts
Mid-term
65
Not built to handle a one-time glut of material or to a size that will discourage the further
reduction of the material.
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1.3.3 Develop relationships and
collaborations between industries
to encourage flow of wood fibre to
biomass projects. Ensure Life Cycle
Analysis and Cost-Benefit studies
have been completed prior to
moving wood fibre and action
aligns with SWMP
Collaborations
Wood residues
Forestry, Industry
(HSPP), Businesses,
Municipalities /
Regional Districts,
MOE. MFLNRO,
First Nations
Short-term
1.3.4 Research suitability of
converting agriculture debris to
energy / fuels, particularly in the
context of local hothouses.
Research BMP’s and case studies
from projects in other regions
(Fraser Valley). Ensure outputs /
byproducts are safe for the
environment and air quality.
Ensure alignment with BC
Agricultural Waste Control
Regulation.
Research, Business
Development,
Infrastructure,
Training &
Investment
Agricultural
residues
Farmers,
Businesses (Triact
Resources),
Pemberton
Hothouses
Long-term
1.3.5 Develop regional expertise
in research, development,
manufacturing and installation of
biomass energy technologies and
biomass products that can be used
regionally and exported elsewhere
in Canada and to the world.
Provide training for installation and
systems operation to help build
regional expertise in biomass
energy. Developing fuels holds
promise. Explore new means of
collaboration to facilitate greater
knowledge transfer (BMPs) and
cross-jurisdictional approaches.
(e.g. via UBCM)
Training,
Collaboration
All Sectors
Forestry, Industry
(HSPP), Businesses,
Municipalities /
Regional Districts,
MOE MFLNRO, First
Nations, SSCAS,
Universities,
Biomass Innovation
Network, UBCM
Long-term
Objective 2- Apply appropriate technology and burning methods to unavoidable
burns, in order to reduce smoke emissions, reduce human exposure to smoke and
mitigate fire hazards.
Recommendation 2.1: Ensure woodstove owners in the airshed are aware of
woodstove exchange rebate program and smart burning measures, and are offered
incentives to burning alternatives.
Rationale: Wood smoke from fireplaces and woodstoves, particularly from older
inefficient stoves, emit particulate matter at the local atmospheric level, which is
38
known to have significant negative health implications. Burning wood that is not
properly dried (‘seasoned’) further compounds the issue. This recommendation and
its associated actions focus on “Energy Recovery,” the second and third highest
priorities in the Biomass Management Hierarchy.
Specific Actions
Requirements
Target
Key Players
Timeline
2.1.1 Complete woodstove
inventory and contact list of
owners.
Research,
collaboration
Residential
SSCAS, Fire Chiefs,
Building Inspectors,
(Municipalities),
First Nations, MOE
Short-term
2.1.2 Ensure all woodstove
owners have access to Smart Burn
Kits (including moisture meters and
storage instructions). Use events
(e.g. workshops, presentations) to
reach public. Explore funding
opportunities to develop a
community-based social marketing
campaign to encourage smart
burning behaviours.
Communications,
social development
Residential
SSCAS, MOE,
Municipalities /
Regional Districts,
First Nations,
businesses
(chimney sweeps)
Mid-term
2.1.3 Explore additional
opportunities / incentives
/regulations (i.e. Building Code) for
prospective woodstove owners to
install clean appliances. Identify
and take advantage of connection
points to communicate messages
(i.e. share info related to wood
stoves with audiences that are
interested in AQ e.g. yoga
community)
Business
development,
infrastructure /
technology, policy
Residential,
Commercial
SSCAS, MOE,
Municipalities /
Regional Districts,
First Nations
Long-term
Recommendation 2.2: Harmonize regional burning-related policies by developing
and sharing best management practices and tools (guide) between government
agencies and industries.
Rationale: Applying the same best management practices throughout the airshed
will simplify existing measures and help ensure compliance. This recommendation
and its associated actions focus on “Disposal,” which is at the bottom of the Biomass
Management Hierarchy.
Specific Actions
Requirements
Target
Key players
Timeline
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2.2.1 Communicate new OBSCR
Communications,
All sectors
guidelines (Fall / Winter 2013) to
Research, Collaboration residues
all stakeholders. Build on existing
policy ‘cheat sheet’ / key (e.g.
OBSCR). Ensure piece delivers clear
messages to a diverse audience
and can be used as an educational
tool by municipalities / regional
districts. Consider grouping
policies according to specific
burning practice. Determine a
suitable ‘home’ for this cheat
sheet / policy inventory that is
cross- referenced between
ministries.
SSCAS, MOE,
MFLNRO, MOA,
Municipalities /
Regional Districts
Short-term
2.2.2 Work collaboratively to
support adherence to venting tool
and flexibility in removing fire
hazards. Consider developing a
Smoke Plan and forming a
committee that commits to BMPs
in exchange for custom venting.
Communications,
Policy, Collaboration
Wood residues,
land clearing
Timber Industries,
Developers, MoE,
MFLNRO, SSCAS
Mid-term
2.2.3 Share teaching tools
between industries (i.e. from
forestry to developers) and sectors
to foster widespread BMPs.
Consider using workshops to
accomplish this.
Training
All Sectors’
Residues
Timber Industries,
Developers, MoE,
MFLNRO, First
Nations, SSCAS
Mid-term
2.2.4 Create an intra-agency
centralized hub for burning and
smoke related information,
including interactive information
tools for enhanced sharing with the
public.
Communications
All sectors’
residues
All Ministries. Local
Government /
Regional Districts,
First Nations, SSCAS
Long-term
2.2.5 Support technology use such
as air curtain incinerators or forced
air assist. Explore feasibility of
short-term leasing of equipment /
technology.
Business
development,
infrastructure /
technology, policy
All sectors’
residues
All Ministries. Local
Government /
Regional Districts,
First Nations, SSCAS
Long-term
Recommendation 2.3 Expand current monitoring and enforcement efforts to ensure
all residents and industries are adhering to best practices developed for open
burning including observing appropriate distances and burn periods.
Rationale: As smoke emissions that are harmful to human health, burners should be
held responsible. Costs associated with monitoring and enforcement will be
40
outweighed by savings to health care and community wellness programs. This
recommendation and its associated actions focus on “Disposal,” which is at the
bottom of the Biomass Management Hierarchy.
Specific Actions
2.3.1 Develop a complaints
registrar for residents and industry
representatives to provide
comments on local air conditions
and presence of smoke. Investigate
suitability of building on existing
tool (PGAIR) as well as other
existing resources (e.g. RAPP).
Develop funding model to maintain
service.
Requirements
Communications,
collaboration
Target
All sectors
Key Players
SSCAS, MOE, Local
Governments,
Industry, Forestry
Timeline
Mid-term
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MAKING THE STRATEGY A REALITY- MOVING TO
IMPLEMENTATION
This strategic framework is intended to be a foundation for a future implementation
plan. Such a plan will explore each of the recommended actions in more detail,
breaking each one into a series of measureable tasks assigned to a committed
implementing party or task force. Such a plan will also outline monitoring,
evaluation and reporting methodologies and track progress towards or away from
the stated vision.
Naturally, the key to implementing many of the recommended actions will be in
removing barriers; namely overcoming prohibitive costs associated with burning
alternatives and the current low market value of waste biomass; improving access to
waste biomass resources; improving regionally-specific research and development
and closing gaps in knowledge and technology related to efficient, low emissions
burning; adoption of standard best management practices within all industries; and
improving communication and coordination between industries and agencies.
Prior to seeking solutions to these obstacles and proceeding to an implementation
plan, some pieces that were missed in the development of this strategic framework,
(owing to the unavoidably tight timeframe in which it was crafted), will need to be
addressed. These might be considered ‘pre-implementation tasks’, and they are as
follows:
1. Of greatest necessity is the continuation and deepening of the stakeholder
engagement process. Cultivating new relationships with potential
stakeholders and partners, while building on and growing trust within
existing stakeholder relationships is paramount to the successful
implementation of the recommended actions. In addition to the
stakeholders involved in creating this framework, a number of other sector
or industry representatives that were unavailable at the time of writing will
need to be consulted and engaged before moving ahead. This nonexhaustive list of representatives might include:
 Representation from each of the First Nations bands in the region
 Wood stove owners
 Woodstove / fire appliances retailers HPBAC
 Firewood Suppliers
 Insurance Agencies
 Sawmill Operators
 BC Hydro
 Ledcor
 Developers
 Construction & Demolition
 Farmers
42







University / Colleges
SLRD
Ministry of Transportation and Infrastructure
Ministry of Agriculture and Lands
Ministry of Energy, Mines and Natural Gas
Ministry of Health
Recycling Council of BC
2. Convening task forces and / or industry specific groups may be one method
of engaging these actors, however, other tools and methods will need to be
deployed as well to overcome the travel restrictions and scheduling
constraints that many of these representatives contend with. An open
forum or virtual porthole could provide interim space for connecting and
communicating.
3. Enlisting the expertise of (a) skilled facilitator(s) to move the process along
from pre-implementation to implementation to completion of actions is
another necessary pre-condition to implementation. Such an individual will
be neutral, with an understanding of the issues, but no vested interest in the
outcomes. They will have experience engaging a diverse group of
stakeholders in an ongoing results-oriented process.
4. Greater research around potential models and available technology for
biomass utilization (as a burning alternative) is another critical step that will
be an important component of the feasibility studies suggested. Much
research and pilot projects have been initiated outside of the region, so
Compiling existing research
5. Assessing available resources- of both a financial and personnel/ human
nature- across the participating sectors will also be essential in effectively
prioritizing actions and equitable allocation of resources will need to be
collectively determined. A gap analysis would be an important step to
complete prior to the creation of an implementation plan.
6. Sourcing funding and resources for each of these pre-implementation tasks is
most critical of all. Cost-sharing models and resource sharing are options that
should be discussed amongst the current group of stakeholders. Determining
funding sources will also greatly influence the scope and speed at which an
implementation plan is carried out.
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CONCLUSION
The Vision and Recommendations contained in this framework are ambitious,
however, armed with this framework and a commitment to collaboration and
resource sharing, SSCAS and signatory stakeholders are ready to take the next steps
towards implementation and achieving the goal of protecting air quality in the Seato-Sky Airshed.
44
APPENDICES
___________________________________________________________________
Glossary
Best Efforts a principle requiring all parties to use highest efforts to perform their
respective obligations although it does not generally require the achievement of any
specific goals.
Biogas A methane rich gas created from the biological decomposition of non-wood
biomass in anaerobic digesters.
Biomass Energy is derived from the combustion of source-separated organic matter
such as the waste products in a forestry operation or other plant matter. Biomass
can be combusted in a boiler to produce steam for turbines to produce power. In
cogeneration applications, the residual heat (thermal energy) is used as energy for
other end uses, such as heating buildings. Biomass power generation is primarily
connected to the Pulp and Paper Manufacturing and Wood Products Manufacturing
sectors through the combustion of wood residue products from those industries.
Cogeneration The combined generation of heat and power. Used as equivalent to
“combined heat and power” (CHP) in this document. Cogeneration is the use of a
heat engine[1] or a power station to simultaneously generate both electricity and
useful heat. All thermal power plants emit a certain amount of heat during
electricity generation. This can be released into the natural environment through
cooling towers, flue gas, or by other means. By contrast, CHP captures some or all of
the by-product heat for heating purposes, either very close to the plant, or—
especially in Scandinavia and eastern Europe—as hot water for district heating with
temperatures ranging from approximately 80 to 130 °C. This is also called Combined
Heat and Power District Heating or CHPDH. Small CHP plants are an example of
decentralized energy.[2]
Controlled burning, see Prescribed Burning
Conventional energy Fossil fuels like coal, petroleum products, and natural gas, as
well as large-scale hydropower.
Debris means disturbed or undisturbed vegetative matter targeted for management
or disposal by open burning
Demolition waste is any material resulting from or produced by the complete or
partial destruction or tearing down of any structure.
45
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District energy District energy is the distribution of thermal energy to multiple
buildings using a pipeline distribution system. The central thermal plants may use
various types of fuel including natural gas, oil, or renewable energy. Heat may be
generated from either purchased fuel or waste heat. The economic viability of
district energy systems relates closely to the energy density of the thermal
customers being served. Consequently, district energy systems tend to be located in
urban cores serving commercial, institutional, and residential customers.
Distributed energy sources are smaller and produce energy closer to demand. They
can provide energy to a single building or facility, or be connected to a common
distribution grid or heating system to serve multiple users.
Domestic waste means household material and food waste, but does not include
newspaper and cardboard.
Forced air technology air curtain incinerators, or other appropriate air-assist
technology employed to promote a hotter, clean burn reduce emissions.
Forest biomass: any live or dead tree that is not generally considered to be
merchantable under current product specifications.
Gasification Thermal conversion of solids to a gas that can be further refined or
combusted.
Open (Outdoor) Burning
The combustion of material with or without control of the
combustion air and without a stack or chimney to vent the emitted products of
combustion to the atmosphere.
Prescribed burning means the knowledgeable application of fire to a specific land
area to accomplish predetermined forest management or other land use objectives
in accordance with the "Glossary of Forest Fire Management Terms" published by
the National Research Council of Canada, 1994.
Renewable energy resources are derived from naturally regenerating energy
resources such as the sun, wind, moving water, earth energy and biomass (i.e., hog
fuel, wood waste, black liquor, etc.). These resources can be used for electricity
generation, heating and cooling services, and other purposes. Both low and high
temperature thermal energy can be produced, depending on the resource. Some
technologies can be used for cogeneration. In addition, renewable power can be
used in water electrolysis technologies to generate hydrogen that would be used as
a mobile (i.e. transportation) or stationary fuel through fuel cells or direct
combustion. Renewable energy resources can also be used to produce liquid bio--‐
46
fuels such as ethanol or biodiesel, both of which can serve as mobile or stationary
fuels.
Smoke means the gases, particulate matter and products of combustion emitted
into the atmosphere when debris is open burned.
Ventilation Forecast: means the afternoon ventilation index forecast issued by
Environment Canada for a geographic area, or a forecast of the atmosphere’s ability
to disperse smoke in a geographic area as determined by a ventilation forecaster,
also known as “custom ventilation forecast.”
Waste Biomass: the portion of biomass resulting from a land use activity that is no
longer wanted by its producer (e.g. organic material such as wood by-products and
agricultural and land clearing debris) and is subject to disposal by burning. This
material can be redirected towards products and energy applications.
Zero Waste means designing and managing products and processes to
systematically avoid and eliminate the volume and toxicity of waste and materials,
conserve and recover all resources, and not burn or bury them (Zero Waste
International Alliance, 2004).
47
March, 2013
Framework
Sea to Sky Burning and Smoke Control Strategic
Table: Municipal & Regional District Burning Bylaws
Municipality
Bylaw
Open
Burning
Allowed
No, but
some
exceptions
(to which
dates
apply)
Open Burn Exceptions
(no permits required)
Small
Hazard
Confined
Abatemen
Other
Fires
t
Yes (food,
Yes
Fire Dept.
warmth,
Training w
ceremony)
Council
approval
Restrictions
apply based
on draught /
fire
conditions
Lillooet
Fire &
Safety
Regulation
, Bylaw No.
202, 2004
Pemberton
Bylaw to
Regulate
the Use of
Public
Spaces and
Parks
BYLAW No.
707, 2012
Only with
permit
Whistler
Fire
Protection
and
Fireworks
Bylaw No.
1956, 2010
No
Only from
Sept. 16June 14, or
anytime if
low fire
rating
Yes, if
authorized
by Fire
Chief
Yes, for
Fire Dept.
training
Squamish
Fire
Service
Bylaw No.
2040, 2008
Yes
Yes. Under 1
m. in
diameter, for
food,
warmth,
ceremony
No,
requires
permit.
Landfill
burning
Lions Bay
Fire Bylaw,
428
No
Bowen
Bylaw to
Yes
48
Land-
Prohibitions
Dates
Allowed
Permits
Smoke
Materials
Oct. 1- April
30
For small open
air burning,
burn barrels
and small fires
Anytime,
with permit.
Restrictions
re: wind and
fire
conditions
apply.
Max size: 1 m
Valid 2 weeks
15 m set back
from slash, dry
grass and
buildings.
Possible to
obtain
multiple
permits.
Yes, organic
matter only.
No
construction
debris or
garbage
For fireworks,
campfires (b/w
Jun 15- Sep.
15), ceremony,
pest
management
as per Fire
Chief
For garden
debris, land
clearing, fires
bigger than 1
m, special
effects, hazard
abatement,
waste disposal
as per
Provincial
regulations
Yes. Yard
waste to be
directed to
Transfer
Station
(tipping fee
waived)
Spring & Fall
(garden
debris)
Yes, as
per MoE
OBSCR.
Smoke
from
seasone
d wood
only
Yes, as per
Waste
Management
Act
Never
N/A
No burning
any material
Anytime
Yes,
Island
provide
regulations
for the
control
and
prevention
of fires.
Bylaw 270,
2009
clearing
and yard
waste
Gibsons
Residential
Backyard
Burning
Bylaw 971,
2005
Yes,
permit
only. None
during fire
ban
Sunshine
Coast
Regional
District
Fire
Protection
Bylaw No.
631, 2011
Yes,
permit
only
Yes,
confined, for
cooking only
Squamish
Lillooet
Regional
District
No burning
regulations
n/a
n/a
Municipal
Employees
burning
garden
debris
Firefightin
g Training
must
comply
with
MoE
OBSCR
By permit:
April 1- May
31, Oct. 1Nov. 30
10 am -4 pm
Garden debris
only:
Fire must be 1
m2 max
Supervised
7.5 m setbacks from
combustibles
and buildings,
1.5 m set-back
from shrubs /
dry grass
No
Venting
index
must be
“good”
for burn
period
No animal
waste,
noxious
materials,
garbage or
construction
waste
n/a
n/a
n/a
n/a
Training
purposes
n/a
n/a
49
March, 2013
Framework
Sea to Sky Burning and Smoke Control Strategic
SWOT ANALYSIS- BY SECTOR
The following is a SWOT analysis by sector (or stakeholder group) towards realizing
the objectives of reducing biomass burning and smoke emissions in the airshed. This
section will grow as more stakeholders get involved; in the interim, it is a useful
exercise for understanding different perspectives on the issue of burning and smoke
control.
SECTOR
Private
Tourism &
Outdoor
Recreation
INTERNAL
Strengths
Weaknesses
Threats
No direct
Branding
Competition with
smoke emissions /
minimal burning
activities
influence / authority
on the issue of
burning (only
indirect)
promoting clean air
and recreation (PR,
events)
other destinations
that permit campfires
/ open burning
Large player in
Collaborations
regional economy
with policy makers
to help communicate
clean air messages /
values to public
Highly
collaborative by
nature
High economic
value placed on
clean vistas could
factor into
cost/benefit analysis
of alternatives to
burning
sustainable practices
Recognizes
importance of clean
air to tourism assets
/ values = high
commitment level
Excellent BMPs
Conflicting
Share BMPs /
Liability
Commitment to
risk assessment with
other industries
associated with fire
hazards / residuals
sustainable practices
priorities (fire hazard
mitigation vs. smoke
control)
Low quality
Building on
Market
Most in depth
risk assessment
(compared with
other industries)
(higher moisture
content) of biomass,
relative to sawmill
residues
existing risk
assessment tools to
support burning
alternatives
fluctuations re: value
of wood residuals
High
commitment to
public safety and
managing fires safely
/ with few smoke
emissions
50
Opportunities
Relatively few
Commitment to
Forestry &
Timber
Harvesting
EXTERNAL
Access to waste
Creation of
biomass cost
prohibitive for nonburning purposes
Committee / Smoke
Plan to trade BMP
commitment for
custom venting
High costs of
Add more
Price of other
fuels / energy stays
low / goes down
(electricity, natural
gas)
Venting index
limitations /
inflexibility
Operations are often
away from urban
areas= less human
exposure to smoke
Farming &
Ranching
transportation &
handling
Small sector in
Transportation
costs
this region. Harder to
achieve economies
of scale.
New technology
Potential
Unsure of
flexibility within
operation to
substitute fuels (e.g.
for boilers)
amount of waste
biomass created /
specific burning
activities
Closed loops (onsite
production of
alternative fuels for
farm operation)
Distance from
Right to Farm
populous
communities means
relatively low
potential for
exposure to
emissions. Although
the potential for
future conflicts due
to zoning do exist.
permits burning,
detracts from finding
burning alternatives?
Access to
Proximity to
Learning from
Fewer regulations
financial resources
densely populated
areas = high
potential for human
exposure to
emissions
other industries and
adopting their BMPs
/ enforcement
(e.g. converting
biomass to fuel)
Seasonal factors
Cost savings- by
using biomass for
farming related
activities (e.g.
hothouses)
Onsite
composting
Environmental
Farm Plans –
potential for BMPs
to be incorporated,
with potential
funding available.
Burning
Development
&
Construction
information to GIS
tool for use by 2nd
tenure holders
practices need
improvement, fewer
BMPs and internal
protocols
Permitting /
rebates that
encourage
minimizing waste
onsite / less land
cleared
Shared
responsibility for fires
in urban areas= less
incentive to take full
responsibility for
actions
Contaminated
biomass (dirt and
construction debris)unusable for burning
alternatives
Generally land
clearing immediately
precedes
development –
51
March, 2013
Framework
Sea to Sky Burning and Smoke Control Strategic
challenge to season
the debris or leave
onsite for any length
of time
Strong anti-
Indirect
Setting regional
Alternative prices
burning regulations
– most regional
players are not
involved in burning
influence on burning
practices
tipping fees to guide
desired behaviour
of composting feed
stock
Capacity-limited
Collecting and
Consistent
space for storing
/sorting processing
biomass waste?
sorting biomass
(acting as a hub)
sources of green
wood waste
Creating a
Future waste to
demand for waste
biomass
energy plans
(incinerator
proposals)
Key player in
Waste
Management
development of solid
waste management
plans and directing
where biomass ends
up
Limited
resources for sorting
(i.e. hired personnel)
Inflexible in
terms of amount of
waste and types
acceptable
Develop /
support programs
that eliminate
backyard burning
Varying
Education &
Alternative costs
Tools re: Smart
Burning
Appliance swapping
/ rebate program
(other fuels relative to
wood)
commitment to zero
waste
High
Power as
consumers and
constituents to
effect change
Potential for
biggest impacts with
changes made
Low cost
Public:
Residential
solutions available
(e.g. moisture
metres)
transportation and
handling costs
Significant
burning & smoke
emissions
Proximity to
densely populated
areas = high
potential for human
exposure to
emissions
Perception that
burning wood is
natural / not a health
/ AQ issue,
aesthetically pleasing
and comforting
Disperseddifficult to regulate
and contact
Fewest financial
resources available
52
Mixed messages
support / funding
regarding
acceptability of wood
as fuel
Point of contact
Unaware of poor
between wood
suppliers, appliance
retailers, forestry
performance of their
stove (don’t monitor
chimney)
Provincial
Resistance to relearning techniques
and practices (can’t
teach an old dog new
tricks)
Competing
priorities- value for
clean air vs. value to
save money (burn
cheap fuel)
Public:
Local
Government
Can make
Needs clear
Regional
Community
bylaws / permit
restrictions that are
more stringent than
province
direction from
community and
strong partnerships
before moving on
something (therefore
slower to act)
collaborations (i.e.
standard burning
bylaw and tipping
fees)
perception that
smoke / burning is not
a significant issue and
therefore doesn’t
warrant taxpayer
$ spent (competition
with other issues)
High interface
with publiccommunication &
education capacity is
high
Using existing
resources for
enforcement
policies (OCPs,
SWMP) that have
public support to
further this issue
Inconsistent
Can work with
Funding cut from
resources
many sectors to
achieve good results
higher power
Limited
High
commitment to
public health and
safety
Sets regulations
Has resources
Public:
(financial, personnel)
to address issue
Provincial
Highly
Ministries
committed, highly
knowledgeable of
issue
 “Silo” perspectiveministries not
working with one
another. Proprietary
of some info?
Share models
/learning from other
parts of the province
Too many
regulations. Varying
and constantly
changing.
53
March, 2013
Framework
Sea to Sky Burning and Smoke Control Strategic
Experts in
Jobs related to
Sharing practices Policies to reduce
Stewardship, High
level of commitment
to protecting
ecosystems and air
quality
supplying firewood
and burning conflict
with goal of reducing
burning especially
woodstoves
and knowledge with
individuals and
industry
Many old wood
First Nations
Non-Profit:
SSCAS
stoves located in FN
communitieschallenges in
acquiring resources
to replace them all
burning are not
applicable unless
internally created
Job creation
through biomass
utilization and
research and
development
investment in the
region
High level of
Few financial
Source funding
External funding
commitment
and human
resources to
leverage
(write grants),
(i.e. MOE) stopsactivities grind to a
halt
High degree of
knowledge
Outsider
perspective on
industry realities
Communicate /
share info & tools
Coordinate /
lead stakeholder
processes
Summary of Observations
The recommended actions (see Section 5) are intended to play to the respective
strengths of the sectors and actors, while exploring their promising opportunities.
The implementation plan will focus on removing the obstacles standing in the way.
The observations taken from the SWOT analysis are as follows:




54
Many of the seemingly low hanging fruit items would be accomplished
simply through continued collaboration and improved coordination between
stakeholders.
Actors that are naturally poised to interface with the public (e.g. tourism
industry, a non-profit like SSCAS, local government) are able to communicate
messages from industries that are less able to engage to the public.
Some industries and stakeholders are natural leaders in terms of mitigating
smoke emissions and burning efficiently (e.g. forestry and First Nations) and
could help other industries and stakeholders in improving their burning
practices (e.g. developers and residents).
Prohibitive costs / limited resources is a commonly stated weakness for most


of the stakeholders, however, it would seem logical that available resources
could be pooled and leveraged to achieve the goal and benefit everyone.
Conflicting priorities will need to be managed throughout the engagement
process, using balanced dialogue to ensure consensus and compromise.
A balance of sticks (regulations & penalties) and carrots (incentives and
behavior change campaigns) evenly distributed between stakeholders
(neither favouring or penalizing one in particular) are needed to achieve
aims.
55