1. Region 4 State and Local Modelers Workshop November 16, 2012 Atlanta, Georgia Rick Gillam Air, Pesticides, and Toxics Management Division U.S. Environmental Protection Agency Atlanta, Georgia Wildland/Prescribed Fire Policies and Regulations and Exceptional Events

2. Air Quality Impacts from Fires  Smoke from fires can contain significant amounts of air pollutants  Particulate Matter (PM)  Carbon Monoxide (CO)  Nitrogen Dioxide  Ozone Precursors (volatile organic compounds and nitrogen oxide compounds)  Studies indicate that at least 90% of wildland fire smoke emissions can be classified as PM 10 and, of that amount, at least 70% are PM 2.5 http://www.forestencyclopedia.net/p/p227/i/i207/image_mini

3. Smoke Impacts on Human Health  The most significant health threat from smoke comes from fine particles (PM2.5)  Fine particles can get into the eyes and respiratory system, where they can cause health problems  burning eyes, runny nose, and illnesses such as bronchitis.  Fine particles also can aggravate chronic heart and lung diseases - and even are linked to premature deaths in people with these conditions  Other pollutants of concern in smoke include carbon monoxide, benzene, acrolein, formaldehyde and precursors for ozone

4. EPA Smoke Management Policy  1998 Interim Air Quality Policy on Wildland and Prescribed Fires  Attempts to Integrate 2 Public Policy Goals: 1. To allow fire to function in its natural role in maintaining healthy wildland ecosystems 2. To protect public health and welfare by mitigating the impacts of air pollutant emissions on air quality and visibility  Available on the following website: http://www.epa.gov/ttn/oarpg/t1/memoranda/firefnl.pdf http://www.epa.gov/ttn/oarpg/t1/memoranda/firefnl.pdf

5. Benefits of Prescribed Burning  Reduce Hazardous Fuel Loads & Potential for Wildfires  Maintain & Improve Wildlife Habitats (e.g. Longleaf Pine Ecosystem)  Prepare Sites for Seeding or Planting  Dispose of Logging Debris  Manage Competing Vegetation  Control Insects And Disease  Perpetuate Fire-dependent Species http://www.birdsasart.com/htmlneiger/ red-cocaded%20woodpecker%20p51_std.jpg

6. Update of 1998 Interim Policy  EPA is currently in the process of revising and updating 1998 Interim Policy to:  Address agricultural burning  Be consistent with the requirements of the 2007 Exceptional Events Rule  Address changes to Clean Air Act rules (e.g., revised PM2.5 and ozone standards and General Conformity Regulations)  Address Smoke Management Programs (SMP) and Basic Smoke Management Practices (BSMP) Protect Air Quality and Human Health & Welfare Ecological and Resource Benefits

7. Update of 1998 Interim Policy  EPA sent the Draft Updated Policy Document to the Office of Management and Budget (OMB) and other Federal Agencies for review in the Spring of 2010  Based on comments received during the Federal Interagency Review process, EPA is currently revising the updated document  EPA hopes to have a revised Draft available for public review in 2013  An opportunity will be provided for public comment on the Draft Revised Policy Document

8. SERPPAS  SERPPAS = Southeast Regional Partnership for Planning and Sustainability  Partnership of State Environmental and Natural Resource Officials with the Department of Defense and other Federal Agencies  Includes States of NC, SC, GA, FL, AL, MS  http://serppas.org/

9. Range-Wide Longleaf Conservation Plan Goal: Increase 3.4 million acres to 8 million acres by 2025 9

10. SERPPAS Smoke Management and Air Quality Subcommittee Activities  Smoke Management Recommendations and Prescribed Fire Tracking Document  Prescribed Fire Smoke Management Pocket Guide  Fire Activity and Emissions Tracking System (FAETS)  Communication and Outreach

11. Pocket Guide

12. Fire Activity & Emissions Tracking  SERPPAS partnering with State Forestry Agencies to develop a fire activity and emissions tracking system  Effort being lead by NC Forestry Commission, in collaboration with GA, TN, LA, and SC Forestry Agencies  Grant from US Forest Service funding project  Evaluating existing tracking systems (e.g., FL, SC, GA)  Goal is to have a web-based system that with track fires (prescribed and wildfires) and important parameters (e.g., date of burn, size, location, PM emissions, etc.)

13. Smoke Modeling Tools

14. BlueSky Framework http://www.getbluesky.org/bluesky/sti/

15. NWS Smoke Forecasts http://www.arl.noaa.gov/smoke.php

16. SHRMC Smoke Tools

17. http://shrmc.ggy.uga.edu/maps/vsmoke.html

18. Exceptional Events  CAA Section 319 defines an exceptional event as an event that:  Affects air quality  Is not reasonably controllable or preventable  Is an event that is caused by human activity that is unlikely to recur at a particular location, or is a natural event, and  Is determined by EPA to be an exceptional event  In certain circumstances, wildland and prescribed fires may be classified as exceptional events  Further details in in the SERPPAS Smoke Management Guidelines and Prescribed Fire Tracking Document Image from GA EPD Exceptional Event submittal to EPA November 2007 Image of smoke across downtown Atlanta taken by WSB Skycam

19. Exceptional Events Rule  Preamble in the Final Rule Federal Register addresses wildland and prescribed fires (72 FR 13566-13567)  Indicates that wildfires and wildland fire use fires fall within the meaning of ‘‘natural events.’’ Therefore, ambient particulate matter and ozone concentrations due to smoke from a wildland fire will be considered for treatment as an exceptional event if the fire is determined to be either a wildfire or wildland fire use fire.  Describes criteria for determining if air quality impacts from prescribed fires can be considered to be exceptional events  Continues to endorse 1998 Interim Policy and require Smoke Management Programs (SMPs) or implementation of “basic smoke management practices” for a smoke impacts on air quality from prescribed fires to be considered an “exceptional event” (EPA must also agree that the fire meets the definition of an exceptional event)  Indicates that the 1998 Interim Policy will be updated to be consistent with the rule, address agricultural burning, and address basic smoke management practices

20. 2012 Exceptional Events Guidance  Draft Guidance available on EPA website  http://www.epa.gov/ttn/analysis/exevents.htm http://www.epa.gov/ttn/analysis/exevents.htm  Comment period ended on 9/4/12  Relatively small amount of fire-related information in current guidance  Q6: Types of evidence that could be provided to demonstrate “but for” test for ozone fire-related events  Q11a: Change EE Flags to eliminate the “Wildland Fire Use” flag since Federal Land Managers have stopped using that term  Q20a: Provides definitions of “Prescribed Fire” and “Wildfire”  Q20b: Wildfire is not reasonably controllable or preventable  Q21: EPA intends to develop separate guidance to address prescribed fire exceptional events

21. General Conformity  EPA Revised General Conformity rule on April 5, 2010  The General Conformity Rule ensures that the actions taken by federal agencies in nonattainment and maintenance areas do not interfere with a state’s plans to meet national standards for air quality. [http://www.epa.gov/oar/genconform/]  Prescribed fires are presumed to conform if:  Done in accordance with a Smoke Management Program that meets EPA’s Interim Air Quality Policy on Wildland and Prescribed Fires or an equivalent replacement policy or  Follows the procedure in 40 CFR 93.153 (g) and (h)  Will not cause or contribute to NAAQS; interfere with maintenance; increase the frequency or severity of any existing violation; or delay attainment of a NAAQS  Demonstrate emissions are below cutoff for conformity determination or  Emissions are included in the SIP or TIP.  Any list of activities that a federal agency wants to treat as “presumed to conform” must be public noticed in the FR with an analysis to support it.

22. Regional Haze  EPA promulgated the Regional Haze Rule in 1999  Calls for States to establish goals for improving visibility in national parks and wilderness areas and to develop long-term strategies for reducing emissions of air pollutants that cause visibility impairment  State Implementation Plans (SIPs) for first planning period (2008-2018) were due in December 2007  No Region 4 State SIPs rely on Wildland Fire Smoke Management to reduce emissions during first planning period http://www.epa.gov/visibility/

23. EPA 2011 NEI for Wildland Fire  EPA 2011 National Emissions Inventory (NEI) is under development  NEI is important because data is used for modeling and regulation development  Draft Wildland Fire NEI Data Currently available for review on EPA website  http://www.epa.gov/ttnchie1/ net/2011inventory.html  State Air Quality Agencies must provide any revisions to the draft data by 12/31/2012

24. EPA 2011 NEI for Wildland Fire  USFS AirFire Effort to provide best fire emissions data in the 2011 NEI  States have option to provide fire activity data to USFS/AirFire in any format  Will be reformatted to enable SmartFire 2 processing for estimating emissions  Deadline – 11/1/2012  If you have 2011 fire activity data, contact your State Air Quality Agency to make sure it is included http://www.airfire.org/emissions/2011nei/

25. Questions? http://s2.hubimg.com/u/116245_f260.jpg Contact: Rick Gillam Environmental Engineer 404.562.9049 gillam.rick@epa.gov