1. Fire Emissions Joint Forum Products for Section 309 WRAP June 24, 2002 Pete Lahm, USDA-FS FEJF Chair

2. Section 309 Requirements All prescribed fire programs evaluate & address the degree of visibility impairment from smoke in planning & application. Smoke management programs. Statewide inventory & tracking systems. Identification & removal of administrative barriers to the use of alternatives to burning in prescribed fire programs.

3. Sect. 309 Requirements cont. Enhanced smoke management programs that consider visibility effects, not only health and nuisance objectives. Establishment of annual emission goals that will minimize emission increases to the maximum extent feasible.

4. FEJF Products to Address Section 309 Requirements Policy on Enhanced Smoke Management Programs for Visibility Policy on Fire Tracking Systems Policy on Annual Emission Goals Guidance Documents on Alternatives to Burning 1)Wildlands & 2)Agriculture 1996 and 2018 Emission Inventories Assessment of Smoke Effects in Planning and Operations

5. ESMP Task Team & FEJF Charge Based on the Regional Haze Rule and other guidance documents, develop an Enhanced Smoke Management Program framework that will address smoke effects on visibility from forest land, rangeland and agricultural burning applicable for whole WRAP region.

6. ESMP Policy Major Issues Regional Haze Rule Interpretation Section 308/309 Differences/Similarities State/Tribe Similarities/Differences Relationship to Existing Smoke Management Guidance & Efforts (NAAQS, Nuisance) WRAP Role & Charter Function of a WRAP Policy Assist ALL WRAP States/Tribes (flexibility) Annual Emission Goal and Emissions Tracking

7. ESMP Policy Interpretation of the Rule The ESMP is a smoke management program that specifically addresses visibility effects The ESMP is compatible with current smoke management programs The ESMP applies to all fire sources The ESMP will be developed collaboratively

8. FEJF Product Development Process Multi-Stakeholder Work Group (FLMs, Air Regulators, Industry, Environment, Tribes): ESMP Task Team 9-Month Development Timeline –Annual Emission Goal & Emissions Tracking split out from ESMP Public Outreach Process FEJF Consensus Approval

9. Task Team Membership Ann Acheson – FSSuraj Ahuja – FSJason Baldwin – Farm Bureau, CA Frances Bernards – UT AQ Gretchen Barkmann – FS Scott Downey – EPA Mark Fitch – AQ DEQMark Gray – WA DNRDennis Haddow – USFWS Kerry Kelly – Kennecott Vicky Komie – NM AQ Scott Kuehn – Plum Creek Timber Bruce Oulrey – CA ARB Bob Palzer – Sierra Club Dave Randall – Air Sciences Al Stover – Dept of Ag SD Jeff Schmidt – NRCS/BLM Evan Shipp – San Joaquin APCD Pete Stewart – FSMarcus Schmidt – BLM Mike Ziolko – OR Dept of Forestry Greg Zschaechner – FS/BLM Pete Lahm – FEJF Co-Chair Rebecca Reynolds - Facilitator

10. ESMP Policy Purpose Identify for states the necessary elements of an enhanced smoke management program to address emissions from all types of fire to protect visibility in mandatory Class I areas

11. Regional Haze Rule Preamble Emphasizes “the implementation of smoke management programs to minimize effects of all fire activities on visibility” (64 FR 35748)

12. Foundational Issues 1.Regional Haze Rule Interpretation 2.Section 308/309 Differences/Similarities 3.Links to Current Smoke Management Efforts 4.WRAP Charge and Policy 5.Flexible Approach 6.Annual Emissions Goal and Emissions Tracking

13. Foundational Issues (cont.) GCVTC –“All types of fire (prescribed fire and agricultural burning) must be addressed equitably as part of a visibility protection strategy” Regional Haze Rule –“…will require regional programs that operate over large geographic areas and limit emissions …that…cause regional haze” Clean Air Act Section 118(a) –Equity among sources WRAP Fire Categorization Policy –Consistent consideration between Section 308/309 states/tribes

14. Foundational Issues (cont.) Regional Haze Rule Interpretation in the context of: –Grand Canyon Visibility Transport Commission –WRAP Bylaws, Charge & Policy –EPA Interim Air Quality Policy on Wildland and Prescribed Fire –AAQTF Recommendation on Air Quality Policy

15. Current Smoke Management Efforts Focus on NAAQS/nuisance Variety –Not all fire sources addressed –Little or no regulation in some areas –Rx fire on forest land most regulated ESMP Policy would provide consistent approach to address regional haze

16. ESMP Policy on NAAQS/Nuisance The ESMP specifically addresses visibility effects ESMP is compatible with all existing smoke management efforts ESMP does not erode current smoke management efforts Visibility protection may come into conflict with NAAQS and/or nuisance protection – plan for this

17. ESMP Policy on State/Tribe Status Tribes are not subject to the same requirements as States under the CAA Under the Tribal Authority Rule (TAR), Tribes may apply “to be treated as States” – and then are encouraged to meet the requirements/deadlines EPA has the responsibility for Tribal Air Quality Programs until Tribes take over

18. ESMP Policy on WRAP Role/Policy WRAP charged with developing technical & policy tools to assist States & Tribes with implementing the Rule WRAP recognizes States’ autonomy & Tribal sovereignty WRAP Policy provides States & Tribes with clear direction that carries the authority of the consensus process WRAP Policy is flexible in its application to accommodate all WRAP States/Tribes

19. ESMP Document 1.WRAP Policy 2.Background 3.Development and Application of Enhanced Smoke Management Programs 4.Appendices

20. 1. WRAP ESMP Policy Enhanced smoke management programs: A.Are efforts that specifically address visibility effects B.Will apply to all fire sources C.Are required for 309 states D.Are a viable tool for 308/309 states to develop SIPs

21. 1. WRAP ESMP Policy (cont’) Enhanced smoke management programs: E.Include nine (9) elements: 1.Actions to minimize emissions 2.Evaluation of smoke dispersion 3.Alternatives to fire 4.Public notification 5.Air quality monitoring 6.Surveillance and enforcement 7.Program evaluation 8.Burn authorization 9.Regional coordination

22. 1. WRAP ESMP Policy (cont’) Enhanced smoke management programs: F.Will be based on the criteria of –efficiency, economics, law, emissions reduction opportunities, land management objectives, reduction of visibility impacts G.May be applied uniformly or tailored to meet a need H.Will be developed and applied collaboratively

23. ESMP Process - next steps - IOC Review at last meeting – –Fundamental approval of “Policy Elements” –Comments on background IOC Comments to FEJF by 7/31 ESMP TT and then FEJF consideration Revise ESMP draft accordingly FEJF consensus on any revisions IOC Final review WRAP approval States use to help determine 308/309 pathway

24. Basis of a separate Annual Emission Goal Policy Fire Tracking System Policy ESMP Policy Annual Emission Goal Emission Tracking

25. ESMP Policy Relationship to Emission Goal & Tracking Emission Goals & Emissions Tracking are separate requirements under Sect 309 Both requirements relate to and support the ESMP Both are referenced in the ESMP Policy, and are forthcoming as separate WRAP Policies

26. Fire Tracking Policy Development Process Grew out of work done by the ESMP Task Team Split out as a separate document Currently under final development & review by the FEJF Policy Document to be presented to WRAP

27. Fire Tracking Policy Issues Fundamental element to the implementation of the Rule (308 and 309) Consistent fire emissions inventories enable inter-jurisdictional comparability across region Determine fire’s contribution to natural background visibility conditions & anthropogenic visibility impairment Support the application of regional modeling Demonstrate reasonable progress 1st step for progressive implementation of WRAP’s Policy for Categorizing Fire Emissions

28. Fire Tracking System Fundamental Components –Ensure comparability Between and within states and tribes Across the WRAP region Optional Components –Support integration with other policy and technical tools being developed by FEJF

29. Fundamental Components Fundamental, post-burn activity information 1.Date of Burn 2.Burn Location 3.Area of Burn 4.Fuel Type 5.Pre-Burn Fuel Loading 6.Fuel Consumption 7.Type of Burn 8.“Anthropogenic” or “Natural” Classification

30. Optional Components Degree of implementation for optional components IS NOT prescribed 1.Burn Emissions 2.Annual Emission Goal-309 requirement 3.Daily Tracking 4.Fire Emissions Projection-309 planning requirement 5.Additional Fire Tracking Information Justify implementation based on different air quality issues, emissions information, state/tribe needs and/or fire source sectors

31. Annual Emission Goals Policy Development Process Grew out of work done by the ESMP Task Team Split out as a separate document Currently under final development & review by the FEJF Policy Document to be presented to WRAP

32. AEG Policy Major Issues Definition of an “annual emission goal” Interpretation of the Rule & GCVTC Feasibility of approach Conclusion: Emission Reduction Techniques (ERT) Concept

33. AEG Policy on Definition of Annual Emission Goal AEG as Cap or Target – Conflict at FEJF Meaning or intent of “Annual Emission Goal” from GCVTC negotiations ERT approach can be implemented now in a meaningful and effective manner

34. Annual Emissions Goal Policy Section 309 of RHR requires: “Establishment of annual emission goals for fire, excluding wildfire, that will minimize emission increases from fire to the maximum extent feasible and that are established in cooperation with States, Tribes, Federal land management agencies, and private entities.” (RHR, 42 CFR 51.309(d)(6)(v))

35. Annual Emissions Goal Policy Approach: –Statewide annual assessment of potential emission reduction by acre (fuel type/land use/physical/economic constraints) –Set feasible ERT use goals –Could create an annual value from annual fire activity projections

36. Annual Emissions Goal Policy Apply to Federal, Tribal, State, and local land managers; and private landowners. Apply to prescribed fire, WFU/PNF, and agricultural burning Program would not apply to wildfire

37. Annual Emissions Goal Policy Build on ERTs that are currently being used Each State will work cooperatively with stakeholders to establish ERT options for various vegetation types Net emission reductions achieved will be calculated for each ERT New ERTs could be added as available

38. Annual Emissions Goal Policy To assist with effort, FEJF will prepare: –List of documents that identify ERTs for various vegetation types –Develop protocol for estimating net emission reductions achieved by using ERTs

39. Annual Emissions Goal Policy States will need to develop tracking system for all land managers (tracking of ERT use) Could be tied to existing or planned tracking requirements for ESMPs Could be established similar to non-point source program under the Clean Water Act for agricultural community

40. Annual Emissions Goal Policy Beginning in 2008, 309 States are required to submit periodic reports to the EPA to assess adequacy of SIP Reports are due every five years If SIP is deficient, State may decide to strengthen Annual Emission Goal

41. AEG Example 30,000 acres ponderosa pine with activity/thinning to be burned-can use ERT’s –State assesses potential ERT’s with land manager FEJF supplies list of ERT options (high fuel moisture, piling, fuelwood use, etc.) –Jointly establish percent “goal” of ERT use to be used consider: efficiency, economics, land management objectives, law, and reduction of visibility impact. –Track use of ERT and attainment of cooperatively set “goal” – Periodic reports to the EPA to assess adequacy of SIP

42. Major Issue for IOC & WRAP Outlier visibility data effects on Baseline and Reasonable Further Progress –EPA Guidance on RFP is still in draft –WRAP did not take opportunity to comment on draft to insure that “exceptional event” approach was included –Data presented at TOC Workshop from several IMPROVE sites show dramatic effects on Worst 20% day calculation (Dust, Fire, etc.) –Approach???????????????????

43. Alternatives to Burning Agricultural Alternatives Report- Final –Established methodology and tools for assessing use of alternatives –Use method to guide states/tribes in ESMP Alternatives Assessment element

44. Alternatives to Burning Wildlands – Prescribed Burning –Draft under review by Task Team –FEJF Draft will be on web in the next month –Will provide guide for states/tribes in ESMP Alternatives Assessment element