1. 1 Incorporating Smoke Management Plans into SIPs: THE OREGON 309 SIP Brian Finneran Oregon Department of Environmental Quality Smoke Management Planning Workshop WRAP 308 Planning Committee & Fire Emissions Joint Forum Portland, Oregon - June 16, 2004

2. 2 1.Document if PF programs address visibility in planning and application. 2.PF programs must have 7 Basic smoke management elements (BMP): 1) Actions to minimize emissions 2) Evaluate smoke dispersion 3) Promote non-burning alternatives 4) Public notification of burning 5) Air quality monitoring 6) Surveillance and enforcement 7) Program evaluation. Sec. 309 Requirements for Fire

3. 3 3.Statewide inventory & emissions tracking system. 4.Identify barriers to non-burning alternatives & a process to overcome these barriers. 5.Adopt Enhanced Smoke Management Program (ESMP). Add to BMP: 8) Burn Authorization 9) Regional Coordination 6.Establish Annual Emission Goals

4. 4  Adopted December 6, 2003  Submitted to EPA by 12/31/03 deadline  Oregon SIP Fire Section titles: 1.Prescribed Fire Program Evaluation 2.Emission Inventory & Tracking System 3.Identification and Removal of Administrative Barriers 4.Enhanced SMP 5.Annual Emission Goal Oregon Section 309 Regional Haze Plan

5. 5  Under Sec. 309, 1 st SIP addresses only the 16 Class I areas of the Colorado Plateau. 2 nd SIP in 2007 to address all other Class I areas (e.g. Oregon’s).  Given long distance to the CP, our SIP addressed only larger fire sources.  Most of Oregon is identified as a Clean Air Corridor. We did not believe smaller fire sources were significant – except to make sure we track their emissions.  Greater effort will be made to address smaller fire sources in 2007 SIP. How much Fire did we address in our 309 SIP?

6. 6 SIP addressed two largest fire sources:*  Forestry prescribed burning  Willamette Valley field burning How much Fire did we address in our 309 SIP? % Fire Emissions in Oregon (PM 2.5) 69% 5% 1% 25% * Does not include rangeland burning and some ag burning for which ODEQ does not have reliable emission estimates.

7. 7 A mandatory SMP for prescribed fire on state and federal forest lands statewide. A mandatory SMP for prescribed fire on state and federal forest lands statewide. A mandatory SMP for Willamette Valley field burning. A mandatory SMP for Willamette Valley field burning.  Both SMPs “advanced programs”. Meet EPA’s criteria for BACM (NAAQS protection).  We knew both SMPs would meet most of Sec. 309 requirements for Fire. Preparing the 309 SIP: What we already had in place

8. 8 Preparing the 309 SIP: Work we conducted for fire Work needed mostly to address the Annual Emission Goals requirement. Work needed mostly to address the Annual Emission Goals requirement. Statewide prescribed fire SMP also needed work on Alternatives to Burning. No formal mechanism in place to show how to overcome barriers. Statewide prescribed fire SMP also needed work on Alternatives to Burning. No formal mechanism in place to show how to overcome barriers. Minor work needed to ensure fire emissions tracking consistent with the WRAP FTS Policy. Minor work needed to ensure fire emissions tracking consistent with the WRAP FTS Policy.

9. 9 On Alternatives to Burning for PF:  Put in SIP commitment to follow WRAP Nonburning Alternatives To Prescribed Fire document. Still need to figure out how to incorporated it into planning process. On Annual Emission Goals:  Put in SIP commitment to follow WRAP Annual Emissions Goals for Fire Policy. Still need to figure out how to track ERTs and quantify emissions. Will provide EPA with SIP supplement upon completion. Will provide EPA with SIP supplement upon completion. Oregon 309 SIP: Work we conducted for fire

10. 10 Next 309 SIP (2007): Work anticipated to address Fire  Unregulated Ag Burning – estimate emissions, then assess significance to regional haze and how to best control.  Problem: Ag burning currently exempt under state law. May have to rely on enforceable local measures (e.g., county ordinances) as alternative.  Rangeland burning – evaluate same as unregulated Ag Burning.  Determine if any improvements can be made to existing mandatory SMPs.