Recommended Policy forCategorizing Fire Emissions

WRAP Meeting November 15, 2001

Pete Lahm - USDA, Forest Service

Fire Emissions Joint Forum Co-Chair

Darla Potter - WDEQ, AQD

Natural Background Task Team Co-Chair

Categorization of Fire Sources

• Scientific inability to identify the source of monitored organic carbon aerosol

• Categorization of Fire is Necessary– Ambient Monitoring & Reporting Forum

(AMRF) request to Fire Emissions Joint Forum (FEJF)

– FEJF formation of the Natural Background Task Team (NBTT)

Regional Haze Rule Preamble

• “The EPA also recognizes that fire of all kinds (wildfire, prescribed fire, etc.) contributes to regional haze, and that there is a complex relationship between what is considered a natural source of fire versus a human-caused source of fire.”

• “Consequently, in determining natural background for a Class I area, EPA believes States [and Tribes] should be permitted to consider some amount of fire in the calculation to reflect the fact that some prescribed fire effects serve merely to offset what would be expected to occur naturally.”

Focus of Work to Date

1. Develop a methodology to categorize fire into “anthropogenic” and “natural” source classifications.

• NBTT 18-month process• NBTT/FEJF Outreach & Interaction

– Discussions with AMRF• Need to track fire emissions for attribution

– NBTT 17 meetings & 33 conference calls

– NBTT briefings at 7 FEJF meetings• Input from FEJF & Non-FEJF Members

– FEJF Website postings

Two-Workshop Format• Diverse Stakeholder Representation & Input

– Senior Staff Workshop - January 24/25, 2001• Technical & Policy Input• Categorize fire emissions sources into two

classifications, “natural” and “anthropogenic”• 65 Participants & Presenters• 22 People to conduct the 1 1/2 day workshop

– Convergence of Thought• Equity among all fires on agricultural land and

wildlands• Ecosystem maintenance prescribed fires are natural• Ecosystem restoration prescribed fires are

anthropogenic

Two-Workshop Format

– Senior Staff Workshop Convergence of Thought• Few classification distinctions based on the fire’s purpose• Wildfires under suppression are natural• Wildfires managed for resource benefits are to be classified as

prescribed fires• A “natural” classification does not exempt a source from other

regulations (i.e., to protect public health or ambient air quality)• Manage emissions from natural sources whenever possible• Control emissions from anthropogenic sources whenever possible

– Senior Staff Workshop Results• Basis for development of a comprehensive policy approach (i.e.,

Draft Policy for Categorizing Fire Emissions)– Equitable and livable policy that can be implemented in the

WRAP region

Draft Policy for Categorizing Fire Emissions

– Classify fire emissions and clarify the relationship between “natural” and “anthropogenic” fire source classifications

– Approach toward management of “natural” and “anthropogenic” fire emissions

– Guiding Principles• Equity among all large sources of fire emissions• Apply emission controls on sources that could feasibly be

controlled to demonstrate reasonable progress• Regional Haze Rule and/or GCVTC language to ensure

consistency and allow Draft Policy linkage to SIPs/TIPs• Consistent Smoke Management Programs for both Sections

308 and 309 of the Regional Haze Rule

Two-Workshop Format– Policy Maker Workshop - May 2, 2001

• Policy Input• Review Draft Policy for Categorizing Fire Emissions• 54 Participants• 9 People to conduct the 1 day workshop

– General Assent & Key Issue Convergence• Restructure into two associated sections (e.g, Classification

and Implementation/Management)• Add “feasibility” language re: emissions control• Recognize Native American religious and ceremonial

burning along with traditional burning • Address all prescribed burning together• Classifications made at the local level• Several changes and additions to Annotated Sections

Further Policy Development• WRAP Input

– Acoma Pueblo Meeting May 24, 2001• Support of NBTT/FEJF’s direction and approach to

development of a draft Recommended Policy• Additional outreach to agricultural stakeholders• Develop guidance for the “feasibility” implementation• Develop a stepwise progression to the

implementation/management policy aspects

• IOC Input– Meeting June 19, 2001

• Avoid potential conflicts with EPA policy

Further Policy Development

• FEJF Input– Meeting July 11-12, 2001– Input from FEJF & Non-FEJF Members

• “Checks & Balances” to classification at the local level with oversight by air quality regulator

• Escaped prescribed fire approach• Need for inclusion of clear examples

• Agricultural Air Quality Task Force Input– Meeting July 19, 2001

• Concerns regarding all WRAP activities related to agricultural effects on visibility

• No direct comments on the draft Recommended Policy• Concern over “control” of agricultural sources

Focus of Work to Date• NBTT Finalize a Recommended Policy for Categorizing

Fire Emissions– Consideration of all input obtained during process

• Recommended Policy Approval Process– NBTT Submission to FEJF - August 14, 2001

• FEJF Consensus Approval - August 30, 2001• All comments received and conference call discussions made part of

the record.• Addition of Executive Summary

– FEJF Submission to IOC & TOC - August 30, 2001• IOC Endorsement• Items for the FEJF to consider and clarify during current and future

work.– IOC Submittal to WRAP - October 31, 2001

NBTT Participants• Federal

– Dennis Haddow, USDA FS; Patti Hirami, USDA FS; Bill Leenhouts, FWS; Tim Sexton, NPS; Patrick Shaver, USDA NRCS

• State– Coleen Campbell, CODPHE; Tim Rogers, SDDENR; Brian Finneran, ORDEQ; Robert Wilkosz,

IDDEQ; Fred Greef (past Co-Chair) WADE• Tribal

– Rose M. Lee, Yakama Nation Environmental Program; Kevin McKernan, Yurok Tribe Environmental Program, Amy Mignella, Esq. White Mountain Apache Tribe, Special Counsel

• Industry– Ken Evans, Phelps Dodge Corporation

• Agriculture– Mark Wagoner, Alfalfa Seed Farmer, Washington

• EPA– Lara P. Autry, U.S. EPA OAQPS

• Environmental– Bob Palzer, Sierra Club

NBTT Management & Content Team

• Established June 2000– Darla Potter, Co-Chair - WYDEQ, AQD – Carl Gossard, Co-Chair - BLM– Pete Lahm, FEJF Co-Chair - USDA FS– Mark Fitch, AZ DEQ– Dave Jones, San Joaquin Valley APCD– Shelley Nolde, USDA FS– Jim Russell, USDA FS– Sam Sandberg, USDA FS Research– Mike Ziolko, OR DOF

• Coordination/Facilitation– Rebecca Reynolds Consulting, Inc.

Recommended Policy for Categorizing Fire Emissions

Approved by:Fire Emissions Joint Forum

Prepared by:Natural Background Task Team of the

Fire Emissions Joint Forum

Table of Contents

EXECUTIVE SUMMARY

1. INTRODUCTION1.1. Background

1.2. Context

1.2.1. Current Condition and Future Fire Emissions

1.2.2. Natural Background Conditions

1.2.3. The Classification of Fire

1.3. Purpose

1.4. Scope and Applicability

Scope and Applicability

• Visibility effects of fire emissions

• Wildland and Agricultural Lands– Regardless of Ownership, Cause of Ignition, or

Purpose of the Fire

• Equitably across all land types and sources

• Federal Class I areas in the WRAP region

Scope and Applicability (cont.)

• Does Not Apply To:– Other open burning activities

• Residential, Commercial, or Industrial Property – backyard burning, garbage incineration, residential wood

combustion, construction debris

– Native American cultural non-vegetative burning• Traditional, Ceremonial, or Religious Purposes

– cremation, sweat lodge fires

“Natural” & “Anthropogenic”Classifications

• Natural Emissions Source Classification (“natural”)– A categorization that designates which fire emissions can result in a

natural reduction of visibility for each Federal Class I area in the WRAP region. This classification includes natural and human-caused ignitions.

• Anthropogenic Emissions Source Classification (“anthropogenic”)– A categorization that designates which fire emissions contribute to

visibility impairment in a Federal Class I area. “Anthropogenic” emissions must be controlled to achieve progress toward the 2064 natural conditions goal for each Federal Class I area in the WRAP region. This classification includes natural and human-caused ignitions.

Table of Contents (cont.)

2. CLASSIFICATION POLICY2.1. Classification Program Management

2.2. Classification Criteria

3. CLASSIFICATION POLICY ANNOTATION3.1. Classification Program Management

3.1.1. Management to Minimize Visibility Impacts

3.1.2. Control Emissions from “Anthropogenic”

Sources

3.1.3. Tracking Fire Emissions

Classification Policy• Classification Program Management

– Requirements for classification to be effective and equitable.

• Classification Criteria– Determine the “natural” and “anthropogenic” sources of

fire that contribute to regional haze.

• The Classification Policy statements apply to both wildland and agricultural lands regardless of ownership, cause of ignition, or purpose of the fire within the WRAP region.

Classification Policy

CLASSIFICATION PROGRAM MANAGEMENT

A. All fires must be managed to minimize visibility impacts.

B. All emissions from fires classified as an “anthropogenic” source will be controlled to the maximum extent feasible subject to economic, safety, technical and environmental considerations.

C. Emissions from all fire will be tracked.

Classification Program Management

• Elements added to ensure effective & equitable treatment among sources (No Free Lunch).

• Current SMP’s typically address public health and nuisance.

• These Program elements are intended to be progressively implemented by states/tribes.

• Specific structure was avoided to allow states/tribes needed flexibility for program development.

Classification Program Management

A. All fires must be managed to minimize visibility impacts.

– Broad definition of fire including wildfire

– Provides for equity

– Maintains rationale used elsewhere in policy-WRAP

– Allows states/tribes to define “managed to minimize visibility impacts” - SMP, WFSA, NEPA Analysis, etc.

– FEJF Guidance under development

Classification Program Management (cont.)

B. All emissions from fires classified as an “anthropogenic” source will be controlled to the maximum extent feasible subject to economic, safety, technical and environmental considerations.

– Goes beyond “management” principles to be used for all fires in A.– Recognizes limits of applicability desired by Policy Makers

(WRAP)– Consistent with GCVTC / RHR concepts

• Annual Emissions Goals / ESMPs– FEJF developing guidance

Classification Program Management (cont.)

C. Emissions from all fire will be tracked.– Recognized obstacles to implementation– Acknowledged varying levels of current smoke

management– Mandatory element for the interpretation of IMPROVE

data– Equity amongst fire sources and other anthropogenic

sources– FEJF developing tracking guidance

Table of Contents (cont.)

3.2. Classification Criteria

3.1.1. Prescribed Fire

3.1.2. Wildfire

3.1.3. Native American Cultural Burning

Classification Policy

CLASSIFICATION CRITERIA

A. Prescribed fire is an “anthropogenic” source, except where it is utilized to maintain an ecosystem that is currently in an ecologically functional and fire resilient condition, in which case it is classified as a “natural” source.

B. Wildfire that is suppressed by management action is a “natural” source. Wildfire, when suppression is limited for safety, economic, or resource limitations, remains a “natural” source. Wildfires managed for resource objectives are classified the same as prescribed fires.

C. Native American cultural burning for traditional, religious, and ceremonial purposes is a “natural” source.

Classification Criteria

• Local determination by burner based on general classification principles (PM).

• Oversight by applicable air quality regulatory authority (NBTT & FEJF).

Classification CriteriaA. Prescribed fire is an “anthropogenic” source, except where

it is utilized to maintain an ecosystem that is currently in an ecologically functional and fire resilient condition, in which case it is classified as a “natural” source.

– Recognizes maintenance burning and role in WRAP Region– Local determination of

• Ecosystem maintenance burn– Ecologically functional, Fire resilient, No excess fuels

• Ecosystem restoration & other prescribed fire types– Unnatural biomass levels, re-establishment of natural vegetation– Control of emissions possible-fuel consumption can be reduced

Classification Criteria (cont.)B. Wildfire that is suppressed by management action is a

“natural” source. Wildfire, when suppression is limited for safety, economic, or resource limitations, remains a “natural” source. Wildfires managed for resource objectives are classified the same as prescribed fires.

– Opportunity for management, not control of emissions of wildfire under suppression

– Wildfires managed for resource benefits have management and/or control potential

– **Escaped Prescribed Fires treated as wildfire under suppression with guidance from EPA Interim Air Quality Policy on Wildland and Prescribed Fires

Classification Criteria (cont.)

C. Native American cultural burning for traditional, religious, and ceremonial purposes is a “natural” source.

– Tribal government defined – All other Native American vegetative burning

defined in policy: prescribed fire, wildfire, etc.

Table of Contents (cont.)

4. APPENDICESAppendix A. Glossary

Appendix B. Recommendation for the Formation of an

Inter-Forum Workgroup

Appendix C. Website References

Appendices• Appendix B - Recommendation for the Formation of an

Inter-Forum Workgroup– Concern about “natural” wildfires masking improvement and

artificially high background levels– Suggestion to parallel Natural Events Policy - PM10– Recommendation for multi-forum and stakeholder workgroup

formation to explore concept and develop formal approach

• EPA’s Tracking Progress Guidance Document– Potential conflict re: “outlier” visibility data from significant

natural events not excluded from background & current conditions

• EPA’s Natural Visibility Condition Guidance Document– Refined approach allows for WRAP Recommended Policy for

Categorizing Fire Emissions

Classification PolicyCLASSIFICATION PROGRAM MANAGEMENT

A. All fires must be managed to minimize visibility impacts.B. All emissions from fires classified as an “anthropogenic” source will be

controlled to the maximum extent feasible subject to economic, safety, technical and environmental considerations.

C. Emissions from all fire will be tracked.CLASSIFICATION CRITERIA

A. Prescribed fire is an “anthropogenic” source, except where it is utilized to maintain an ecosystem that is currently in an ecologically functional and fire resilient condition, in which case it is classified as a “natural” source.

B. Wildfire that is suppressed by management action is a “natural” source. Wildfire, when suppression is limited for safety, economic, or resource limitations, remains a “natural” source. Wildfires managed for resource objectives are classified the same as prescribed fires.

C. Native American cultural burning for traditional, religious, and ceremonial purposes is a “natural” source.

Recommendation

• WRAP Approval of the Recommended Policy for Categorizing Fire Emissions

• Change cover & Publish– Policy for Categorizing Fire Emissions– Approved by the Western Regional Air

Partnership November 15, 2001

• Post on the WRAP Website www.wrapair.org

Continued Work

• Ambient Monitoring & Reporting Forum - Utilize the WRAP approved Policy to apportion fire emissions

• States and Tribes in the WRAP Region - Incorporate the WRAP approved Policy into the technical support documentation for a SIP/TIP

• FEJF – Develops and incorporates further guidance into upcoming WRAP policy and technical recommendations