Summary of Wildland Fire Issues Group Steering Committee Meeting

Atlanta, Georgia

September 4 - 5, 1997

I.	PURPOSE

The Wildland Fire Issues Group Steering Committee met on September 4 and 5, 1997 in Atlanta, Georgia to review reports generated by the Communications, Science and Technology, and Policy Issues Groups. A presentation was also given on the need and importance of the clarification of definitions for the policy and all pertinent materials.

II.	PARTICIPANTS

Don Arkell, WESTAR

Gary Blais, EPA

Coleen Campbell, Colorado Department of Environment and Public Health

Bob Clark, BLM

Jim Douglas, DOI

Ron Dunton, BLM

Anita Frankel, EPA Region X

Jerry Gause, USDA

Richard Hayslip, Salt River Project

James Hubbard, National Association of State Foresters

Polly Hunter, EPA Region X

Donna Lamb, USDA Forest Service

Brian Mitchell, National Park Service

Dr. Bob Palzer, Sierra Club

Tom Patten for Mary Jo Lavin, USDA Forest Service

Margie Perkins, Colorado Department of Environment and Public Health

Howard Rhodes, Florida Department of Environmental Protection

Sally Shaver, EPA

Sandra Silva, U.S. Fish and Wildlife Service

Dennis Thompson, USDA, NRCS

Ron Tickle, DOD Clean Air Act Services Steering Committee

Arch Wells, Bureau of Indian Affairs

Ken Woodard, EPA

Steering Committee Members Not In Attendance

William Becker, STAPPA/ALAPCO

Bill Dickerson, EPA

Les Rosenkrance, National Interagency Fire Center

Joe Williams, Washington Department of Ecology

Other Attendees: Beth Friedman and Jennifer McCutchen, EC/R Incorporated (EPA contractor support)

III.	ACTION ITEMS

1.	Communication and Outreach group: Incorporate comments made by the Steering Committee into the papers presented on September 4. Finalize the FACT sheet and Q&A sheet for distribution to the appropriate communications networks. Continue to work on the six papers that were discussed at the meeting. Finalize communications strategy. Develop talking points and key themes for release to press officials within various agencies.

Mr. Patten noted that the NWCG has just adopted new wildland fire management terminology, which should be reflected in all of the documents produced by this Committee. He offered to help the authors incorporate the correct terms before any are released to the public. A similar concern was raised about the accuracy of figures cited in the documents. Mr. Douglas suggested the FLM's data used to justify budgets are probably the best source of consistent information, and he offered to provide these data.

Ms. Hunter asked for comments to be transmitted to her as soon as possible so that the subgroup could make final changes at the Lake Tahoe meeting on September 9-11. Any comments that would be considered "show stoppers" that would prevent the papers from going public should be brought to her attention immediately. The group agreed that there would be a final review cycle after the Lake Tahoe meeting. Ms. Hunter will notify the group when the final documents are releasable.

2.	Science and Technology Group: Encourage the development of a pilot emissions inventory program to be used by Federal land managers during the 1998 fire season. Continue to develop issue papers discussed and the remaining issue papers.

3.	Policy Issues Group: Begin resolving the various issues that remain on policy so that the final writing of the policy may begin. The issues are as follows: (1) Define wildlands, (2) Close escape routes about fires being considered under the Natural Events policy, (3) Consequences of NAAQS violations/failures, (4) Applicability policy, (5) The question of emissions tracking, (6) Sources of funding, (7) Bridge between the Natural Events policy and fire policy terminology, and (8) Discussion of smoke management plan requirements. The policy must begin the final phase of writing so that a more final draft will be ready for the October meeting of the steering committee.

4.	The next Wildland Fire Issues Group Steering Committee meeting will be held on either October 21-22, 1997 or November 3-4, 1997 in Washington, D.C. A final Wildland Fire Issues Group Steering Committee meeting may be held in December 9 and 10, most likely on the West Coast.

IV.	MEETING SUMMARY

In order to provide a better understanding of what the subcommittee discussed, this meeting summary is grouped by issue and is not necessarily a chronological synopsis of the meeting.

Overview of Wildfire Policy Status

Ms. Shaver summarized the overall status of the ozone/particulate matter (PM)/regional haze Federal Advisory Committee Act (FACA) process. The revised PM and ozone standards will become effective on September 16, 1997, and guidance to the States will soon follow. The implementation rulemaking needs to be complete by December of 1998; the final FACA meeting will be held in December 1997 with the possibility of two or three meetings in 1998. Ms. Shaver anticipates presenting a draft wildland fire policy to the FACA committee at its October meeting and a final draft at the December meeting. Final polishing of the policy may need to occur in early 1998.

Other EPA efforts include finalizing the interim implementation plan later this month and rulemakings on transportation conformity and New Source Review (NSR) in the spring. The regional haze rule was proposed in July, the public hearing is scheduled for September 18, in Denver, Colorado, and the public comment period ends on July 20. The EPA hopes to finalize this rule by February 1998. Finally, the EPA is still working on a proposal related to designations, which will be partially proposed in late 1997, with the remainder due for proposal by spring 1998.

A small FACA has been established by the USDA on agricultural issues. Ms. Shaver is a member of this group, which is discussing agricultural burning. This group has only had two meetings. The wildland fire policy will be considered by this group in developing related agricultural burning policies.

Presentation on Communications Materials and Strategy Documents

Mr. Gause provided an overview of the progress made by the Communications Subgroup. The development of the communications strategy began with three people and was guided by the original guiding principles. Since then, the subgroup has produced several products, including a paper entitled Frequently Asked Questions and Answers: Wildland Fire and Air Quality Issues, a FACT sheet on the EPA's Wildland Fire and Air Quality Policy, draft issue papers, and a communications strategy to communicate the policy to Federal agencies, State and local (S/L) agencies, and the general public. Also, the subgroup has drafted an article for the Department of Interior newsletter.

Ms. Hunter then presented the details of the communications strategy. She described three phases by which the subgroup will accomplish its goals. First, the subgroup will finalize the fact sheet and the Q&A paper, distribute the documents to the communications networks, and place the papers on the Web site. Final Steering Committee comments needed to be collected so that the final versions of the paper would be ready for distribution. Second, the subgroup plans to continue work on the six papers. The six papers are as follows: (1) Effective Wildland Fire Management, (2) Wildland Fires and Air Quality, (3) The Impact of Fire on Visibility, (4) Understanding the Use and Role of Fire, (5) The National Role of Fire in the North American Landscape, and (6) Wildland Fire: Prevention, Control, and Use. These issue papers will delve further into the various background subjects than the Q&A sheet does, and the target date for completion is early October. Third, during the fall of this year, the subgroup plans to finalize the issue papers and communication strategy as well as develop an executive summary of the final policy and key themes and talking points for release to the various press officials within Federal and S/L agencies. A resource list of "key concepts" will also be released. The group is also developing graphics for the communication package.

Ms. Hunter described the various methods for distributing information about the wildfire and air quality policy. Federal agencies will use their existing communications networks, which include intra-agency communications channels and informal dissemination methods. Mr. Wells said intertribal councils as well as the Bureau of Indian Affairs will assist in distributing the information to the tribes. Ms. Hunter added that when the FACT sheet and Q&A sheet are ready to be released, two possible venues for presentations to S/L/T agencies are the National Association of Foresters national meeting and the STAPPA/ALAPCO communications network. Mr. Dutton asked if the information would be aimed at non-profits and industry or just at the S/L/Tribal authorities. Ms. Hunter replied that the Sierra Club would serve as the conduit for transmitting information to the non-profits, but the subgroup needed guidance on who to contact in the private sector.

Ms. Hunter added that key websites will be the EPA/FACA web page, the WESTAR site, Federal Land Manager (FLM) sites, and the National Association of State Foresters. Mr. Douglas said that some form of group should continue to work together to keep the Fact sheets, web sites, etc. current. Ms. Hunter suggested that the National Wildfire Coordination Group's (NWCG's) education subgroup might be an appropriate vehicle to maintain and update all information. Mr. Douglas added that the membership of the NWCG should be expanded beyond the FLM's to include State and Federal regulators. Ms. Hunter said that she has been invited to the group's next meeting. Ms. Silva added that the responsibility to continuously update information also rests with the steering committee, and that the steering committee should ensure that the information is continuously updated.

Mr. Douglas stated that on September 30, a U.S. House of Representatives hearing will be held on wildland fire issues, and he would like to be able to use the materials presented by the Communications and Outreach Group as part of the material for the hearing. Mr. Palzer objected, stating that the materials developed so far concern policy currently under development and, thus, are still changing. Ms. Hunter replied that the FACT sheet and Q&A sheet supply basically background information on the policy and discuss only the mission of the policy, not the policy itself. Mr. Rhodes suggested striking any information that presupposes policy from the two sheets, and the group agreed.

Mr. Patten noted that the NWCG has just adopted new wildland fire management terminology, which should be reflected in all of the documents produced by this Committee. He noted that the current documents also error in misapplying terms or inappropriately using them interchangeably. He offered to help the authors incorporate the correct terms before any are released to the public. Mr. Gause raised a similar concern about the accuracy of figures cited in the documents. He was concerned that the most accurate and up-to-date figures should be used. Mr. Douglas suggested the FLM's data used to justify budgets are probably the best source of consistent information, and he offered to provide these data.

Mr. Rhodes suggested striking any information about required smoke management programs and prescribed burns from the papers because these topics presuppose policy decisions. Furthermore, Mr. Mitchell suggested other places within the Fact sheet and Q&A sheet where policy was mentioned and recommended that these be examined and possibly removed. Mr. Thompson added that clarifications to the definitions need to be settled. Both Mr. Palzer and Mr. Hubbard suggested taking a balanced approach to issue presentation. They suggested adding more details on the health effects of wildland fires and the air quality goals of the policy. Finally, Mr. Palzer suggested adding a comment that the information presented in the Fact sheets and Q&A sheets represent an ongoing process. As comments are received from other groups, the documents can be updated.

Ms. Hunter asked for comments to be transmitted to her as soon as possible so that the subgroup could make final changes at the Lake Tahoe meeting on September 9-11. Any comments that would be considered "show stoppers" that would prevent the papers from going public should be brought to her attention immediately. The group agreed that there would be a final review cycle after the Lake Tahoe meeting. Ms. Hunter will notify the group when the final documents are releasable.

Presentation on Wildland Fire Terminology

Mr. Patten gave a brief presentation on definitions describing wildland fire management terminology that were adopted by the NWCG in June 1997. In particular, the new terminology distinguishes a prescribed fire as any fire ignited by management actions to meet specific objectives. In contrast, a wildland fire is any non-structure fire, other than prescribed fire, that occurs in the wildland. The previous terminology incorporated the idea of a prescribed natural fire, which is no longer relevant to the program. The group agreed that it is important to use the new terms correctly in all documents issued by the group.

Mr. Woodard suggested that if no Fire Management Plan (FMP) with a prescription exists and a fire starts, then the fire would be considered a wildfire. Mr. Patten added that within a FMP, part of the prescription might be to put out the fire. Mr. Douglas added that the fire policy states that people should act appropriately if a fire threatens resources or if it threatens to escape. People need to get out of the mind set that a fire is good or bad. By breaking free of this mind set, fire managers would be able to implement fire management policies.

Ms. Lamb brought up the point that there is a difference if a wildland fire is started by an arsonist or is started accidentally. Mr. Patten added that the Department of Interior (DOI) considers arson fires to be unwanted and puts out arson fires so as not to encourage arson or accidental fire. Also, if the DOI lets arson fires burn out naturally, then they would have no recourse for prosecution. Ms. Lamb suggested examining this issue in the policy.

Mr. Thompson asked about the actual definition for wildlands. Mr. Douglas replied that a wildland fire is a nonstructural fire on Federal lands that does not include agricultural lands. The wildland fire management terminology does not distinguish between agricultural lands, range lands, pasture, etc. Ms. Shaver noted that there is a potential conflict between this definition and the definition of "wildlands" used by other groups.

Mr. Patten added that the type of fire (i.e. pile fires, woodland fires) will decide the type of emissions that occur. For example, pile fires would emit PM that would travel greater distances than other types of fires. Mr. Douglas added that prescribed fires can encompass a range of fire types, and the smoke management program (SMPr) should address the range of emission reduction techniques for each activity.

Presentation on Issue Papers Written by the Science and Technology Subgroup

Prior to the issue paper discussion, Mr. Blais distributed copies of the executive summary of a national strategic plan for wildland fire and air quality data and modeling systems developed by the NWCG's Air Quality Express Team. The group is hosting a national interagency workshop in November to develop the final strategic plan. The Express Team's vision is to balance and advance ecosystem and air quality goals by focusing efforts in smoke management. The National Strategic Plan is a vision of how to organize the many facets of smoke management so that priorities can be identified between and within agencies. Mr. Douglas added that there needs to be a partnership between the FLM's and regulators to accomplish this sort of integrated effort.

Mr. Blais brought the steering committee up to date on the progress made by the Science and Technology (S&T) subgroup. Three issue papers were discussed and are titled as follows: (1) What Wildland Fire Conditions Minimize Emissions and Hazardous Air Pollutants and Can Land Management Goals Still be Met, (2) Air Monitoring for Wildland Fire Operations, and (3) Policy Committee Inquiry: Emission Inventories for SIP Development. Two papers are still in the process of being written and are entitled: (1) The Natural Level of Emissions and (2) Smoke Management: A Tiered Approach. The three complete issue papers were then discussed separately.

Mr. Blais presented an overview of the first paper, What Wildland Fire Conditions Minimize Emissions and Hazardous Air Pollutants and Can Land Management Goals Still be Met. Following is a summary of the discussion on the paper.

The authors concluded that all pollutants, excluding carbon dioxide, are negatively correlated with combustion efficiency. Mr. Palzer asked about the carbon monoxide emissions that would result from more complete combustion. Granted, better combustion reduces the amount of nitrogen oxides (NOx) and hazardous air pollutants (HAPs) emitted into the atmosphere, but more efficient combustion also causes an increase in carbon monoxide. Ms. Lamb stated that when writing the paper, the authors presented a graph that showed how the efficiency of burning produced different amounts of reductions. It showed that if emissions were reduced, then the amount of HAPs were reduced. Furthermore, outdoor combustion conditions differ significant from internal combustion (e.g., boilers), because the presence of air is not a limiting factor. Instead, the heat from the fire pulls in air, and the main danger from carbon monoxide relates to the exposure to firefighters rather than a broader environmental effect. She added that wetter fuel results in more smoldering and emissions, but less fuel burned. Mr. Palzer suggested adding more detail to the paper on this topic would be beneficial. Ms. Campbell added that the authors wanted to look at the techniques to minimize emissions, but that more detail should be added on SMPr's, dispersion monitoring, etc. to clarify that the paper presents only one aspect of a SMPr.

Mr. Blais added that this paper discusses one element of the overall plan (basic smoke management) and that a new paper will be included in the appendix of the policy. It will outline a tiered approach to smoke management that will act as a guidance for agencies needing to upgrade their basic SMP. Mr. Douglas stated that it would be good to have an appendix to the policy, but the technical document should be kept relevant over time by expanding the AP-42 (or through some other means) and updating it on a continuous basis. He strongly recommended that the committee think of a way to keep the policy relevant over time. Mr. Palzer there should also be an effort to track the combined effects of both emissions and health impacts resulting from the wildland fire policy.

Mr. Blais presented the second paper, Air Monitoring for Wildland Fire Operations. He noted that additional references will be added to this paper, including a report by CH2MHill that evaluates the effects, including costs, of different monitoring tools in smoky environments. Mr. Douglas mentioned he had difficulty in having information containing costs in the paper because costs will change over time. He suggested finding a different way to convey the information. He added that the paper sounded like more of a discussion of the issues instead of a blueprint or policy, which is implied by the lead paragraph. Either the paper needs to change, or the lead paragraph needs to change. Mr. Blais replied that he had assumed that the group wanted to see guidelines for setting up a monitoring program. Ms. Lamb and Mr. Douglas agreed that the policy group should use the information provided in this paper to develop policy recommendations for monitoring requirements. Ms. Lamb added that monitoring requirements should be integrated with the SMPr. Ms. Frankel suggested clarifying that monitoring contributes to a feedback loop to make adjustments in an ongoing program.

Mr. Thompson asked what body will be responsible for the monitoring. Mr. Woodard said that he envisioned that the States would conduct monitoring on a voluntary basis in sensitive sites, e.g., at the wildland/urban interface. Ms. Campbell disagreed and said that she saw the States' role as limited to ambient monitoring. Fire monitoring would be conducted (or at least paid for) by the landowner, based on the "polluter pays" concept. The role of the State is to establish monitoring requirements and provide expertise, but if the State determines a project may result in a problem in the community, the FLM should support the monitoring. She added that it would not be her intent to require monitoring of every prescribed burn. Mr. Rhodes agreed that monitoring in a SMPr should be incumbent on the sources to financially support. Mr. Thompson was concerned about expanding this policy to private landowners, who would lack the capability to perform this kind of monitoring. He said private landowners would have an expectation that their tax dollars would support this service.

Mr. Dunton mentioned that the monitoring plan should be defined to meet the objectives of the smoke management plan (SMP) or program (SMPr). Mr. Hayslip and Mr. Dunton agreed that air quality problems are a significant issue, and air quality issues should be defined for not only the SMPr managers but also for the burn bosses who would conduct the burn on the ground. Mr. Hayslip said that the discussion of monitoring should be expanded to include other types of monitoring such as the acquisition of meteorological data. Mr. Thompson added that using more public relations up-front might be better than using lots of monitoring, which could turn out to be more of a nuisance than a help. Ms. Campbell said that Colorado is considering a requirement that addresses issues similar to the ones being discussed. In Colorado, for larger burns that would last longer than one day and would take place near populated areas, some sort of notification would have to be in place to let people know of a possible drop in air quality. She said that the paper should clarify that monitoring would not be expected in every burn situation.

The group discussed the need to clearly define the differences between a smoke management program (broader policy) and a smoke management plan (components of a fire burn) and to use the terms correctly. Ms. Campbell added that the objectives of the SMPr's would vary across regions of the country.

Mr. Douglas stated that when considering SMPr's, it is important to keep in mind the need for a tiered program because of the complexities in the different situations. The basic required program would establish the floor. As more complicated situations arise, more monitoring would be required. Mr. Woodard added that two goals exist for monitoring: (1) Checking impacts on the air quality standards in areas not typically monitored year-round and for the ability to react at the urban interfaces and (2) Checking the effectiveness of SMPr's. Mr. Tickle added that monitoring could be incorporated into the fire management plan (FMP) and could be used in cases where burning could create a problem. Mr. Rhodes stressed that coordination with S/L officials should be part of the FMP.

Mr. Clark commented that the paper has an incomplete discussion of the different types of monitoring that are available. Ms. Campbell stated that they could add explanations about different types of monitoring into the introduction. Mr. Douglas suggested adding a whole section that would discuss the different types of monitoring.

Ms. Campbell summarized the third paper, Policy Committee Inquiry: Emission Inventories for SIP Development. The goal of the paper is to address a request by the policy group to recommend a sound method to obtain consistent data to compare emissions from fires with emissions from other sources and to evaluate the effects of increases in prescribed burns. The paper expanded the scope of the initial request to include data gathering from sources in addition to the FLM's and to address other uses for the data. The paper recommends a 3-year baseline for the inventory. Data would be collected in a tiered system as needed to support individual programs. She stressed the need for some entity to take the raw numbers generated by the inventory and turn the data into usable emissions information. Mr. Clark pointed out the tremendous gaps in existing inventories, which do not include local (vs. Federal) information, for example.

Mr. Woodard explained that the emission inventory data would be needed by the States to address their obligations to develop programs to attain/maintain the NAAQS. Mr. Douglas asked if the burners would be required to submit information, and if they are, then in what manner would the recipients use the information. Ms. Perkins stated that the policy group is looking at these issues. Mr. Douglas continued by stating that from the viewpoint of FLMs, it would be a good idea to have consistent data requirements, which would reduce the collection burden. He added that the FLM's already have a need for these data and are working to standardize information collection across agencies. Given appropriate direction from the wildland fire policy, the FLM's would incorporate the EPA requirements into their management policy in individual agencies.

Mr. Douglas further stated that it would be a good idea to maintain a "home" for the database where people would know to go to search for information. The form should also be standardized and the information which is asked for should be realistic. However, Ms. Lamb added that before the database is created, the uses and objectives of the database should be clearly defined. Mr. Tickle suggested that there may be a way to set up a database without it being economically dysfunctional. He suggested that the FLMs should have access to the EPA aerometric information retrieval system (AIRS) database in a way that would minimize costs.

The group discussed the types of participation needed to compile the data base. Mr. Douglas reiterated that the FLM's would respond to a mandate from this group to develop a compatible inventory system. The FLM's managers are already in the process of attempting to standardize fire-related data by the 1998 fire season. He suggested that the FLM's could provide a pilot study of the efficacy of the data base, which would then be reviewed prior to expansion to private landowners, State-owned lands, and/or agricultural lands. Mr. Thompson agreed with the need to keep private landowners out of the system.

Mr. Rhodes said that any system should keep the States out of the data collection loop. In other words, the FLM's should submit their data directly to the data collection system, e.g., AIRS. Mr. Patton stressed the need to use a central data collection point, while Mr. Douglas emphasized the need for the data collected to be "transportable." Ms. Lamb added that technical issues would need to be resolved to allow the necessary interface with the AIRS system. Mr. Woodard noted that the EPA's overall concept regarding the States' use of AIRS would be compatible with this program. The EPA does not enforce the States use of AIRS or the quality of data that they submit to the system. Instead, the system is self-policing, because users have an incentive to improve the quality of data they submit to the system. In the case of the fire data base, the existence of regional air management programs (RAMPs), the need for PM-fine analyses, and other factors will contribute to the States' incentives to use and expand the data base.

Mr. Thompson suggested that the group should continue to examine what parameters would be necessary for the database. For example, Mr. Palzer suggested that the FLM's could provide emission estimates per event through the use of nanographs or other sources. He also suggested that the basic inventory should include information on the duration of the fire. Mr. Douglas noted that the FLM's are already examining data needs. He asked the Steering Committee to work with them to develop the detailed data elements that would be required to meet the regulators' needs. Mr. Dutten expressed his concern that the EPA may not need these data. Ms. Frankel noted that these data would be an asset in regional planning and in other programs. Mr. Mitchell added that a data collection effort would also be consistent with the Grand Canyon Visibility Transport Commission recommendations. Mr. Douglas emphasized the need for an affirmative decision on creating a database as soon as possible to take advantage of ongoing FLM efforts.

Presentation and Discussion of Draft Policy

Mr. Woodard provided an overview on the development of the draft Wildland Fire/Air Quality Policy. He also provided the group with copies of the written comments on the draft policy submitted by Joe Williams. The subgroup met in San Diego to discuss ideas on what should go into the policy. At a subsequent meeting in Orlando, the group discussed a draft policy outline, issues, questions for the S&T subgroup, and Clean Air Act related issues such as conformity, visibility, and prevention of significant deterioration (PSD). The August 18, 1997 draft the outcome of these discussions to date. The goal at the upcoming Lake Tahoe meeting is to develop the detailed policy statement, using guidance from the Steering Committee at the Atlanta meeting. When writing the policy and accompanying guidance, S/L agencies were the target audience.

Throughout the course of the discussion of the policy, several suggestions were made to adjust specifics within the language itself. For example, suggestions were made to ensure that Indian Tribes were explicitly mentioned and also to more accurately describe what the policy entails. The following discussion focuses on the broader issues raised by Committee members rather than editorial comments and specific language changes.

Mr. Hayslip stated that ambiguity exists about how the air quality goal is expressed within the policy. As currently written, it understates the importance of visibility and haze. Ms. Perkins concurred and added that this would be especially important because of the sensitivity in the West to regional haze and visibility. Mr. Hayslip also added that it is important to clarify what the wildland fire policy addresses. It does not address stationary sources, and he wanted to modify the policy so that it would be clear as to what it does address. Mr. Douglas suggested that the policy should specifically discuss wildland fires or prescribed fires. Ms. Shaver stressed that the policy needs to address the equity issue between stationary sources and fire-related sources, because they both emit common pollutants of concern. Ms. Perkins noted that a major concern is that exceedances due to fires could trigger the need for additional mandatory controls on stationary sources. Ms. Shaver asked for specific language from the group to address these concerns.

The group also discussed the scope of the policy and what types of land use are covered. Mr. Thompson said the guiding principles section singles out "agricultural" burning as being part of a separate process (e.g., the USDA FACA). How would burning for commercial development be addressed. Mr. Rhodes agreed that it is unclear whether the policy covers agricultural lands, land clearing, and private land holders. If these are not addressed, then how are they dealt with? Ms. Shaver said that some of these uses might not justify the attention of a national policy and would be better dealt with at the S/L level. She reminded the group that their original mandate was to focus on problems at the Federal level and said she does not necessarily favor extending the program to private lands. The group agreed that the scope issue deserved further discussion and public review.

Mr. Woodard clarified that the August 18 draft policy was written to cover all wildlands of any ownership. While agricultural crop products are excluded, rangeland would be included. Mr. Thompson pointed out that private landowners do not have the same capabilities to manage the land as public landowners. Furthermore, as written, the draft policy would apply to a class of agricultural lands in the conservation reserve program (CRP). Mr. Thompson said that these lands are better addressed by the agricultural FACA. Mr. Douglas interjected that it is important to burn on a landscape basis because of the complicated nature of land boundaries. Different policies for FLM's and private landowners would be very difficult to implement in cases where a public/private partnership would otherwise provide the best fire management program. For changes in the applicability section of the policy, the following issues should be resolved: (1) The public versus private issue, (2) Providing clear examples on what the term fuel really means, (3) The wildland/urban interface needs to be clarified, and (4) Any places where ambiguities in definitions cause problems should be remedied. It should be made clear that wildlands are not as far away as people think.

Discussion of the policy then proceeded to the background section. In order to give a balance to the background section, Mr. Palzer wanted to add a discussion on the history of fire incidences. He stated that as currently written, the policy does not give background on events that were lesser known but that took a lot of human life. He also felt the need to emphasize the change in the natural environment that was brought about by man. He wanted to emphasize that the policy should not discuss the idea that the land should be transformed back to the way it was over a thousand years ago. Ms. Shaver asked if the policy implied a return of the ecosystem to presettlement days. Mr. Palzer replied that it talks about restoring ecosystems. Mr. Palzer said that the reasons for preventing catastrophic fires should be the reasons that the public will accept. He concluded that adding historical events to the background of the policy will demonstrate that this problem is not a recent problem.

Mr. Douglas argued that, while the draft document may overstate the risk of wildfires, he stressed that the background should set the stage as to why fire in an ecosystem is important. The policy should explain how the suppression of fire and changes in land use have led to an increase in the risk of wildfire and that the planned application of fire is a tool to address this situation. The purpose of this policy is to mitigate the effects of the need to increase prescribed burning. Mr. Douglas added that information should be added to capture the fact that there are two types of burning: (1) in the West, burning being ramped up and (2) in the East and Southeast, burning continuing as is or increasing prescribed burning, respectively.

Ms. Shaver questioned the statement that increases in prescribed burning on private lands is at a lower rate of increase than on public lands. Mr. Patton said that the rate of increase is determined by the amount of resources the owner can devote to prescribed burning. The FLMs have significantly more resources, and, hence, are expected to conduct more burns.

Mr. Palzer mentioned that in the Air Quality section, the mortality resulting from emissions from fires is not clearly discussed. Because the data shows that increased particulate matter leads to increased mortality, the policy should address this.

Mr. Woodard said that agencies should have a land management plan (LMP) to decide how to use the lands. While the LMPs decide how to use the lands, the fire management plan (FMP) is on a lower level and specifically discusses how to implement the LMP. One of the main themes in this policy is that the air quality agencies should be involved early in the planning process. Mr. Palzer reemphasized that the need for a mechanism so that such involvement happens early in the process. As currently written, there is no direct linkage to air quality personnel. Mr. Dunton opined that it is difficult and unrealistic to bring air quality agencies in on every burn. Instead, he stated that environmental impact statements (EISs) written under the National Environmental Policy Act (NEPA) allow for public comment and thus comment by air quality agencies as part of the public. Furthermore, he suggested allowing air quality officials to have input at the LMP level. Mr. Patten agreed and stated that decisions to use fire will be made at the LMP level instead of the FMP level. Mr. Rhodes added that the use of fire is decentralized and that resources will not allow air quality agencies to have a say in every fire. Also, each State has their own way of managing smoke.

Mr. Douglas agreed that there is a public participation process, but air quality agencies have not really participated in the public comment period. Also, Federal agencies have not been closely looking at alternatives to using fire. There should be opportunities for air management agencies to work with land management agencies. Mr. Palzer supplied an example. He stated that in Oregon, a stakeholder group is working on a State Implementation Program (SIP) because of exceedances of particulate matter/ozone (PM/O3). In the original SIP, modeling showed that there would be a problem because of a change in wildland and/or prescribed burning. An increase in prescribed burning could have a negative impact on nonattainment areas. Thus, air quality officials need to be involved in planning and also at the site-specific level. Mr. Perkins stated that the SIP situation is not an all or nothing proposition and depends upon the situation of the individual SIPs.

Mr. Dunton said that NEPA is a cornerstone to everything done that concerns burning, and that NEPA provides a mechanism to include air quality issues. Thus, a whole other process is not needed. Ms. Shaver asked if the FLM's typically respond to comments generated through the NEPA process. Mr. Dunton replied that, yes, the agencies did respond and would conform to the desires of the air quality agencies. Mr. Hubbard added that in some States, the NEPA plan is site-specific. If the air quality officials do not agree with the plan, then changes will be made. Leaving flexibility in the plan means a lot to the States and is important.

Mr. Douglas stated that he was having difficulty ascertaining what is policy and what is description in the document. The policy should clearly state what actions are required of the various entities so that they can be in compliance with the policy. In a similar vein, Mr. Wells asked how an agency or tribe would declare that they had met an approved plan. He suggested having a checklist. Ms. Shaver added that the EPA must be able to document that a proper plan was developed and used. Mr. Woodard explained that the air quality agency needs to be involved in the LMP process. Mr. Dunton added that once the air quality agency has provided its input on the LMP, the compliance burden would rest with the FLM. Only in borderline cases would the air quality agency have to be involved in site-specific projects. Mr. Palzer added the LMP could include criteria that would guide site-specific projects, such as the trigger events resulting in no-burn days.

Mr. Hubbard resisted the idea that a Federal policy would tell the States how to do their plans. Ms. Lamb suggested that until LMPs are in place, air quality officials should participate on a burn-by-burn basis. Mr. Douglas emphasized that it would be best if existing processes were used. A process should not be added unless someone could show that there is not an adequate process already in use. Ms. Shaver added that the linkage between the SIP, Federal,, and planning requirements has not been defined. The linkage should be clearly defined in the policy so that duplication of planning will not occur.

Mr. Rhodes asked if the outcome of the policy would always be a SIP call. Mr. Woodard replied that if there were no air quality problem, then the status of the SIP would not be an issue. Mr. Rhodes then stated that the SIP is a vehicle that ensures that everyone who has an air quality problem may contribute fairly to its solution.

Section IX of the policy discusses the response States and Tribes should take to reduce immediate threats to public health and to take appropriate steps to prevent future adverse impacts. Long term solutions would be set in place in the form of regulations that need to be developed. Short-term solutions would consist of emergency episode plans. The hierarchy of response would depend on the type of event. Section X, failure to adopt an adequate SMPr, describes the process by which EPA would call for the development of a SMPr or, if the State/Tribe, fails to do so, designate the area to nonattainment status. In other words, the message to the States/Tribes is to develop a SMPr if there is any concern that wildland fires could result in air quality impacts. Ms. Shaver discussed the need to ensure that the policy contains minimum upfront requirements for SIPs and that EPA's recourse in the face of continued air quality degradation is clear. Mr. Patten added that there needs to be an accountability system and a way to determine significance.

Mr. Gause asked what would happen if a prescribed fire turned into a fire that got away. Mr. Woodard replied that a prescribed fire that got away would be handled in a similar way that States handle malfunctions in industry that result in excess emission events. Mr. Patten said that it is difficult to deal with these types of fires under the policy as it is currently written. Ms. Shaver stated that this draft of the policy intentionally avoid the issue of making policy distinctions based on the cause of the fire. Mr. Patten argued that the policy should be defined so that if the event should meet the prescription up to a point where the prescription fails, then the fire should go from this policy to the Natural Events policy set by EPA. Alternatively, if the event meets the prescription, then the fire manager should follow through with the plan.

Mr. Douglas suggested the idea of management units having two zones. In Zone A, the fire would be put out immediately. In Zone B, the fire would be managed by prescription only, which would mean aggressively or by closely monitoring the fire. Mr. Woodard added that a fire managed in Zone B would be managed under an approved prescription that would have air quality criteria already approved. Mr. Patten argued that he didn't see a reason to define prescription because what is managed as a wildfire by one person might be managed as a wildland fire by another. Ms. Shaver asked if what Mr. Patten meant was that a policy based on the Zones would be the fires that meet the NAAQS and would not be considered a wildfire. Mr. Patten replied that there would be times when wildfires met the NAAQS, but there would also be times when a wildfire would fall under the Natural Events policy. That point is not clear. Ms. Shaver then stated that there is an issue for the public in NAAQS. People won't be concerned about what kind of fire the fire is. There will be a problem with people buying into the policy.

Mr. Douglas asked about the consequences for managers when they classify a fire as a wildfire. He added that there is a need to create incentives to have managers actually control the fire. Mr. Patten suggested tightening the language for management. There is a need to avoid over-managing fire. Mr. Palzer argued that increasing the number of fires will expose greater amounts of people to the fire. Thus, if the number of fires increases over a national basis, then what are the consequences? Ms. Shaver replied that currently there are no corrective actions in place, but the NAAQS require some sort of action or plan to follow. Mr. Palzer stated that when relocating people for mitigation, then they could also lower emissions to help meet the safe levels. It is possible to let the language of the policy help the land managers meet their goals.

Mr. Douglas stated that it is impossible to create a system that limits all land management options. There needs to be a system with incentives. It would also be good to have an audit and review session in partnership with the EPA. Mr. Douglas was reluctant to have this policy say that it will reduce other emissions. If people say that if a forest has a fire, then they would not want it to have direct consequences. Mr. Palzer wanted a tougher policy that would protect the public and keep burning from happening. Mr. Thompson countered that if a burn area is suppressed, then a buildup of fuel would cause problems to continuously compound if the fuel caught fire. Ms. Shaver stressed the fact that there needs to be an accountability system. She wanted to make sure that not every fire that started could fall under the natural events policy.

Mr. Dunton stated that he wanted to avoid a policy that would be too strict. Ms. Shaver stated that a three year violation from three year's worth of data would tell EPA that something is wrong. Ms. Lamb added that when looking at a SMPr, there is a pretty important window of meteorology, It is important not to narrow and close that window. Also, there might be opposition to adjust the window to achieve the three year goals. In a SMPr, there would be opposition to making adjustments. Ms. Shaver said that a moratorium would not serve well. If a SMPr fails on a consistent basis, then there might be grounds to have a moratorium on burning in place until the plan is fixed. Mr. Douglas said that there are already short-term and long-term responses to exceedances, and there should also be a medium-term response. The moratorium could be a medium-term response. For example, a California community was "smoked" in the preceding year, so managers decided not to burn this year because they had violated the community trust the year before and wanted to show good faith. Ms. Shaver agreed that the public would be a good monitor, but a provision still needs to be in place in the policy. Mr. Dunton added that common sense cannot all be covered in policy. Ms. Shaver repeated that the EPA wants balances so that hand-tying will be avoided. Mr. Dunton countered that it all goes back to planning and trusting that the standard will be obeyed.

Ms. Perkins said that the public would want to know where to go in case a violation does occur. Ms. Lamb said that if the measures of PM are high and frequent, an exceedance would occur. Conformity is difficult when talking about reasonably progressive measures. Mr. Woodard stated that enforcement would be up to the States. He asked what the State agencies could do. Ms. Campbell provided an example. Colorado issued a notice of violation because it felt that negligence on the part of an agency resulted in smoking in a community. The agency was fined. Mr. Rhodes added that when fines have not worked, the dispute moved to the next level and usually needed to go no higher. There is a general sentiment for people to work together.

Mr. Hayslip asked about the possibility of drafting a policy that would require a SMPr to be based on a three- year rolling budget so that in a bad year, the budget would be revised instead of invoking the natural events policy. The budget could be SIP- or TIP-wide. Mr. Dutten suggested that an ecosystem (e.g., airshed) would be more appropriate. However, he objected to the practical difficulties faced in operating under such a banking system. Mr. Dunton added that self-regulating will occur on a yearly basis. Identifying blackened areas will help target areas for burning over the next year. The object is to use fire in its natural role. Finally, just because there is a fire does not mean there is any air quality impact. Ms. Perkins mentioned her concern that on a regional basis, FLMs would not be held accountable, and this approach does not address the equity issues between Federal and other sources. Mr. Douglas added that as the SIPs are developed, States will ask all emitters on what they are planning to do. The budget concept may be addressed through the SIPS. Care must be taken in developing the administrative system. Furthermore, the policy does not have an emissions tracking system. A tracking system should be added to the management system.

Mr. Woodard asked how prescriptive the requirements should be with respect to the SMPr. For example, would a SMPr only be required subsequent to a NAAQS violation, or should one be required earlier? Mr. Palzer suggested that at minimum the States should have a "bare bones" SMPr. Mr. Douglas asked if concerns existed that requiring all States to develop SMPr's would place a burden on States that don't have a lot of contributions. Mr. Woodard added that Texas does not want to have to develop a SMPr. Mr. Dunton asked why States violating the NAAQS should have to develop a SMPr, and that they should wait for EPA to make a SIP call. Ms. Shaver replied that the overall reaction time to a violation is slow, which is not in the best interest of the public. Thus, unhealthy consequences result. Designation as a nonattainment area could take up to a year, and then it could take three years to develop a SMPr. In addition, the downside to a designation is that it would affect all other emission sources in the area as well. She suggested on option would be to require the States to manage "smoke", but not formally require development of a SMPr.

Mr. Hubbard suggested that the EPA could recommend that SMPr's be in place. If they are not and a violation occurs, EPA would move directly to redesignate the area. Others argued that this approach does not address areas where smoke-related emissions are insignificant. Ms. Frankel stated that the process could be tiered to require a basic SMPr. Then if a burn occurs that results in a violation, another action plan would be possible. Mr. Rhodes suggested that it would be hard to mandate a uniform SMPr. However, if a State has a SMPr and subsequently violates the NAAQS, EPA could exercise its discretion under section 107(d)(3) to allow the State to adjust the program before a nonattainment designation. In the absence of a SMPr, the designation would occur without the opportunity for an alternative remedy. He added that Florida would probably require legislation to make a mandatory program enforceable, and he would prefer a voluntary program. Ms. Campbell said the subgroup assumed some de minimis activity in a State before a full SMPr would be implemented. She is in the process of writing a paper that would go beyond the broad policy requirements and give specific examples of requirements, menus, mechanisms to take a State to the next tier, inventory requirements, burn plans, etc. Ms. Shaver agreed there should be some minimum requirements.

Mr. Palzer asked if any of the requirements have parameters for when ignition occurs and when ignition ends. Ms. Campbell replied that States are protective of what they are doing because they want to continue to use what works. Mr. Palzer stated that ramifications could take place many miles away or many days later. Mr. Douglas added that different States have different levels of rigor. Everyone should talk more in terms of performance criteria because it is a way of accommodating people who already have burning methods. She was also concerned about a stepped approach and how the triggers would be defined. Mr. Palzer added that the policy should consider the "areas at risk" approach considered by the NAAQS implementation FACA committee.

Mr. Douglas said that the technical details should not be made a part of the formal policy, because they will continue to evolve. Mr. Blais stated that he planned to include the tiered approach in the appendices. However, tying the triggers to individual emission levels is very difficult. Ms. Campbell commented that would be difficult to distinguish between tier 1 and tier 2 programs in every situation. Ms. Shaver stated that she felt more comfortable with the air quality data as the trigger. Mr. Hayslip was concerned that this approach was inadequate for regional haze, because strategic planning may be more difficult to mitigate regional haze impacts. Ms. Shaver asked if it would be possible to assume that the more acres burned would result in more emissions. Mr. Palzer suggested that maybe it would be more appropriate to go by tons burned, and Ms. Silva agreed that this measure tracks emissions more closely than a measure based on acres burned. Mr. Douglas objected, because it would be easier to measure acres burned. As a principle, he suggested that the more general the plan, the more general the trigger should be. Ms. Shaver stressed the need for a simple trigger.

Mr. Woodard asked about putting a time frame on the States to assess the increase in burning, and that if increases exceed a specified amount, then mitigation measures would follow. Ms. Shaver asked if the increase should be measured as an increase in prescribed burning or as the difference between natural burning vs. prescribed burning. Mr. Patten suggested that they could measure the difference between historic (presettlement) vs. current conditions vs. planned future conditions. Mr. Palzer then asked how changes in land use would be accounted for. Mr. Patten replied that computer modeling could do the job. Mr. Palzer asked if there would be a problem in using current conditions. Mr. Patten said that a baseline could already exist and then expand outward. Ms. Frankel said that the point of the trigger should be to anticipate potential air quality problems in communities and use the data to provide a feedback loop on the process. She sees a need for minimum monitoring requirements, and the FLM should be responsible for short-term monitoring.

Ms. Lamb states that two cases exist that should be addressed by the policy. In the first case, where a SMPr already exists because intermittent controls are needed and large increases in burning might occur, the FLM should talk to the State about their individual position. In the second case, there are no SMPr's in place, and the issue is who initiates the discussion in the case of a problem. If the State realizes a PM- 2.5 problem exists, they would need to talk with the FLM. On the other hand, if the FLM foresees large increases in burning, they should initiate the discussion with the State. Ms. Shaver added that on the regulation side, RACM and BACM could be used. She also suggested a letter from the EPA stating that a threshold might be triggered would lead to an incentive by the State to reevaluate their existing SMPr and augment it. While the system should provide incentives for better coordination, EPA cannot dictate it. However, EPA can consider whether a program is adequately implemented. Mr. Douglas stated that the State should collect the basic, "coarse" data and then should take action without a letter coming from the EPA.

The trend appears to be toward setting minimum data elements collected across the country. Mr. Rhodes stated that philosophically and scientifically this is a good idea, but in reality it is more difficult. If States are going to try and establish an emissions tracking program, it will not happen uniformly across the country. Ms. Shaver asked if any efforts were underway to track emissions. Mr. Douglas replied that the data collected have not been very helpful. Ms. Shaver then said that the burden should rest on the land management agency. Mr. Woodard added that the S&T work group feel that emission factors are looking good. Mr. Clark added that they need to look at fuel loading and fuel consumption because they are the weak links, not emission factors. Mr. Douglas added that if there were failures, then having a record of what got burned when would be helpful to try and figure out what happened. The FLMs need to know what the consequences are, especially what the emission factors are. Thus, there is use for the data. Ms. Shaver added that the policy could encourage the collection of data to be in a compatible database.

Mr. Rhodes raised a concern that the scope of a mandatory program may need to be different than the scope of a voluntary program. Mr. Woodard said the current draft envisions a voluntary program, but a wide applicability. The group agreed that this section of the policy should address the incentive nature of the program.

The group then discussed the definition of wildlands and the effects of the definition on the scope of the related USDA FACA effort. One approach discussed was to specifically exclude in this policy some or all of the following classes of land use: CRP lands, cattle lands, private woodlots, rangeland, etc and present the definition to the agricultural group. Another approach was to leave the definition as currently structured and discuss areas of overlap or concern with the other group. Ms. Lamb added that any lands excluded by the EPA policy should be addressed by the USDA policy. Mr. Dunton noted that separating rangelands out of the EPA policy would pose serious problems for the management of BLM lands is some areas. The group decided to flag the definition in the EPA policy as matter of discussion between the two groups regarding proper jurisdiction.

Mr. Hubbard asked that if all States have different air quality programs, then wouldn't it make sense for the States that are different to make their own air quality recommendations. He suggested that the wildland fire policy should be limited to FLMs. Mr. Dunton added that the FLMs follow State policy, therefore it would be a good idea for the policy to be consistent with the States. Mr. Palzer said that the NAAQS are national standards and the States need to be prepared to meet them. Mr. Woodard said the goal of the national policy recommendation is to encourage a coordinated approach.

Mr. Woodard said that EPA had conducted internal discussions with the group developing the regional haze standards and was informed that the efforts of this group to address the regional haze aspects related to a fire policy would be considered. Mr. Mitchell added that the current conditions are being assessed, and it will be at least four years before the methodology has to be put together. He did not feel that this issue would be necessary to get the policy written. The Regional Haze proposal does provide default values for regional haze in the East and West. The S&T group is developing an issue paper on what is to be considered natural emissions. Mr. Douglas recommended keeping the issue on the table and that the concept of naturalness should be explored.

Another Clean Air Act issue is one of the PSD program. Mr. Rhodes stated that the PSD approach did not seem to be applicable, because emissions increase on a temporal basis and then will drop once the season is finished. Mr. Woodard replied that the OAQPS PSD approach is not that restrictive. So long as the burning can be viewed as a temporary source, there would be no restrictions. Mr. Dunton added that burning would not take place in the same place every year. Conditions will dictate where the burning takes place. Mr. Douglas stated that initially, a lot of emissions will occur because there will be a lot of fuel. But once the burning begins to take place on a regular basis, the emissions will decrease because the amount of fuel will be less. Ms. Lamb concluded that what to do under PSD still needs to be addressed by the policy.