DRAFT

WILDLAND FIRE/AIR QUALITY POLICY

December 10, 1997

December 10, 1997

TABLE OF CONTENTS

DEFINITIONS

I.	PURPOSE

II.	SCOPE AND APPLICABILITY

III.	BACKGROUND

A.	Role of Fire in the Wildland

B.	Changes in Fire Management Policy

C.	Air Quality Considerations

D.	Air Contaminant Emissions

E.	Visibility Impairment

IV.	DESCRIPTION OF POLICY

V.	COLLABORATION AMONG LAND AND AIR QUALITY MANAGERS

A.	Land and Vegetation Management

1.	Alternative Vegetation Treatments

a.	Utilization and mechanical treatments

b.	Chemical treatments

c.	Prescriptive fires

2.	Role of Federal Land Managers

a.	Land use and fire management planning

b.	Evaluating alternative management tools

3.	Role of State and Other Public Land Managers

4.	Role of Private Land Managers

5.	Role of Indian Land Managers

6.	Role of Air Quality Managers

B.	Air Quality Management

1.	Role of State/local Air Quality Managers

2.	Role of Tribal Air Quality Managers

3.	Role of Public Land Managers

VI.	SMOKE MANAGEMENT PROGRAMS

A.	Authorization to Burn

B.	Minimizing Air Pollutant Emissions

C.	Smoke Management Components of Burn Plans

1.	Actions to minimize prescribed fire emissions

2.	Evaluate smoke dispersion

3.	Public notification

4.	Air quality monitoring

5.	Exposure reduction precautions

D.	Public Education and Awareness

E.	Surveillance and Enforcement

F.	Program Evaluation

G.	Additional Air Quality Protection (Optional)

VII.	ACCOUNTABILITY

A.	Role of State/Tribal Air Quality Managers

1.	Wildfires

2.	Prescriptive fires

a.	NAAQS violations without a SMP

b.	NAAQS violations with a SMP

i.	Burn plan authorized

ii.	Burn plan followed

iii.	Prescription failed

B.	Role of Wildland Owners/Managers

VIII.	DATA ON WILDLAND AND PRESCRIBED FIRES

IX.	MEETIING OTHER CLEAN AIR ACT REQUIREMENTS

A.	Demonstrate Conformity of Federal Activities

B.	Visibility/Regional Haze Requirements

C.	Prevention of Significant Deterioration

Appendix A Background on the Role of Fire

Appendix B What Wildland Fire Conditions Minimize Emissions and Hazardous Air Pollutants and Can Land Management Goals Still Be Met?

Appendix C Air Monitoring for Wildland Fire Operations

Appendix D Emissions Inventories for SIP Development

Appendix E Estimating Natural Emissions From Wildland and Prescribed Fire

DEFINITIONS

Air Quality Manager: The regulatory body responsible for managing the air quality protection program at the State or local level. The term may also apply to tribes.

Air Quality Related Values (AQRV): Those special attributes of a Class I area that deterioration of air quality may adversely affect. Some examples of AQRV include: flora and fauna, water, visibility, and odor among others.

Ambient Air: That portion of the atmosphere, external to buildings, to which the general public has access.

Administrative unit: A unit of land (Forest, Refuge, Park, etc.) under the administration of a public land management agency.

AP-42: The Environmental Protection Agency's Compilation of Air Pollutant Emission Factors for stationary point, area, and mobile sources. An emission factor is a representative value that attempts to relate the quantity of a pollutant released to the atmosphere with an activity associated with the release of that pollutant. Emission factors are then used to estimate the magnitude of a source's pollutant emissions.

Best Available Control Measures (BACM): Practices related to an emission source or activity which result in the maximum level of emission reduction practicable, considering effects on public health, safety, environmental and economic impacts and cost. BACM are the minimum measures required for serious non-attainment areas as prescribed in the Clean Air Act. For prescribed burning, BACM includes a smoke management program which reflects the specific conditions and requirements of a local area. Elements of a smoke management program that reflects BACM includes (1) smoke dispersion evaluation, (2) burn planning authorization and administration, (3) requirements for ensuring burner qualifications, (4) public education and awareness, (5) surveillance and enforcement, (6) emission inventories and emission reduction efforts, (7) appropriate governing authority oversight.

Class I Area:	An area set aside under the Clean Air Act to receive the most stringent protection of air quality from degradation. Mandatory federal Class I areas are (1) international parks, (2) national wilderness areas which exceed 5,000 acres in size, (3) national memorial parks which exceed 5,000 acres in size, and (4) national parks which exceed 6,000 acres and were in existence prior to the 1977 Clean Air Act Amendments.

Federal Implementation Plan (FIP): A plan (or portion thereof) promulgated by the Administrator to fill all or a portion of a gap or otherwise correct all or a portion of an inadequacy in a State or Tribal implementation plan, and which includes enforceable emission limitations or other control measures, means or techniques (including economic incentives, such as marketable permits or auctions of emissions allowances), and provides for attainment of the relevant national ambient air quality standard.

Federal Land Manager: With respect to any lands in the United States, the Secretary of the department with authority over such lands. Generally, the Secretaries delegate their authority to specific elements within each department. For example, the National Park Service and the Fish and Wildlife Service manage those areas under the authority of the Department of the Interior.

Fire dependent ecosystem: A community of plants and animals that must experience recurring disturbances by fire, in order to sustain its natural plant succession, structure and composition of vegetation, and maintain appropriate fuel loading and nutrient cycling to ensure proper ecosystem function.

Fire management plan: A strategic plan that defines a program to manage wildland and prescribed fires, and documents the fire management program to meet management objectives outlined in the approved land use plan. The plan is supplemented by operational procedures such as preparedness plans, prescribed fire (burn) plans and prevention plans.

Fuel: Includes combustible vegetative matter such as grass, trees, shrubs, limbs, branches, duff, and stumps.

Indian land: An inclusive term describing all land held in trust by the United States for individual Indians or tribes, or all land, titles to which are held by individual Indians or tribes, subject to Federal restrictions against alienation or encumbrance, or all lands which are subject to the rights of use, occupancy and/or benefit of certain tribes. [See 25 CFR Part 150.2(h).]

Land use plan: A broad scale, long range plan that identifies the scope of actions and goals for the land and resources administered by a land owner/manager.

Long-term Strategy: A Clean Air Act required element in SIP's (see below) and TIP's (see below) where a mandatory Class I federal area is located and for which the Secretary of the Department of Interior has determined visibility is an important value, or where emissions may reasonably be anticipated to cause or contribute to any impairment of visibility in any mandatory federal Class I area. [The Chief of the Forest Service has federal land manager authority to define visibility as an Air Quality Related Value.] A long-term strategy is a multi-year plan for making reasonable progress toward meeting the national goal of preventing future, and remedying any existing impairment of visibility in mandatory Class I federal areas, where such impairment results from man-made air pollution.

National Ambient Air Quality Standards (NAAQS): Standards for maximum acceptable concentrations of pollutants in the ambient air to protect public health with an adequate margin of safety, and to protect public welfare from any known or anticipated adverse effects of such pollutants (e.g., visibility impairment, soiling, materials damage, etc.) in the ambient air.

National Environmental Policy Act: Establishes procedures that Federal agencies must follow in making decisions on Federal actions which may impact the environment. Procedures include evaluation of environmental effects of proposed actions, and alternatives to proposed actions; involvement of the public and cooperating agencies.

Nuisance Smoke: Amounts of smoke in the ambient air which interfere with a right or privilege common to members of the public, including the use or enjoyment of public or private resources.

Particulate Matter: 1. Fine liquid or solid particles such as dust, smoke, mist, fumes, or smog found in air or emissions. 2, Very small solid suspended in water. They vary in size, shape, density, and electrical charge, can be gathered together by coagulation and flocculation.

Any liquid or solid matter except uncombined water, which exists as a liquid or solid at standard conditions.

Prescribed fire: Any fire ignited by management actions to meet specific objectives. Before Federal land managers can ignite a prescribed fire, an approved prescribed fire plan must exist, and the requirements of the National Environmental Policy Act must be met.

.	Prescription: Measurable criteria which guide selection of appropriate management response and actions. Prescription criteria may include the meteorological conditions affecting the area under prescription, as well as factors related to the state of the area to be burned such as the fuel moisture condition and other physical parameters. Other criteria which may be considered include safety, economic, public health, environmental, geographic, administrative, social or legal considerations, and ecological and land management objectives.

Prescriptive fires: Management ignited and naturally ignited fires that are managed within a prescription to meet land use planning objectives.

Prevention of Significant Deterioration (PSD): A requirement in the Clean Air Act, which establishes the maximum allowable increases in ambient air concentrations of selected air pollutants above baseline concentrations in areas designated as Class I, Class II, or Class III.

Regional Haze: Generally, concentrations of fine particles in the atmosphere extending up to hundreds of miles across a region and promoting noticeably hazy conditions; wide-spread visibility impairment, especially in mandatory Class I federal areas, where visibility is an important value. The EPA Administrator is required to conduct studies and promulgate regulations to include measures to make reasonable progress to reduce man-made emissions which contribute to regional haze.

Sensitive receptors: Population centers such as towns and villages, camp grounds and trails, hospitals, nursing homes, schools, roads, airports, Federal Class I Areas, etc. where smoke and air pollutants can adversely affect public health, safety and welfare.

Smoke Management Program (SMP): Establishes a basic framework of procedures and requirements for managing smoke from prescriptive fires. The purposes of SMP's are to mitigate the nuisance and public safety hazards (e.g., on roadways and at airports) posed by smoke intrusions into populated areas; to avoid significant deterioration of air quality and potential NAAQS violations; and to mitigate visibility impacts in Class I areas.

State implementation plan (SIP): A Clean Air Act required document in which States adopt emission reduction measures necessary to attain and maintain National Ambient Air Quality Standards, and meet other requirements of the Act.

Suppression: A management action intended to protect identified values from a fire, extinguish a fire, or alter a fire's direction of spread.

Tribal implementation plan (TIP): A document authorized by the Clean Air Act in which Tribes adopt emission reduction measures necessary to attain and maintain National Ambient Air Quality Standards, and meet other requirements of the Act.

Volatile Organic Compounds (VOC): Any organic compound which participates in atmospheric photochemical reactions, which are measured by a reference method, an equivalent method, or an alternative method. Some compounds are specifically listed as excepted due to their having negligible photochemical reactivity.

Wildfire: An unwanted wildland fire.

Wildland, as used in this document, means an area where development is generally limited to roads, railroads, power lines, and widely scattered structures. The land is not cultivated (i.e., the soil is disturbed less frequently than once in ten years), is not fallow, and is not in the USDA Conservation Reserve Program. The land may be neglected altogether or managed for such purposes as wood or forage production, wildlife, recreation, wetlands or protective plant cover. [The distinction between wildlands, to which the fire policy recommendations in this document apply, and agricultural lands is subject to further discussion.]

Wildland Fire: Any non-structural fire, other than prescribed fire, that occurs in the wildland.

Wildland Fire Situation Analysis (WFSA): A real time decision-making process carried out by federal land management agencies to select an appropriate management response to wildland fire. The WFSA considers fire fighter and public safety, risk to property and resources, fire fighting resources available, land management objectives and environmental, social economic and political constraints. The environmental and social constraints considered include, among other things, how air quality and/or visibility will be affected at sensitive receptors by each alternative fire management strategy

Wildland/Urban interface: The line, area or zone where structures and other human development meets or intermingles with the wildland.

I.	PURPOSE

This policy statement has been prepared in response to plans by Federal, tribal and State wildland managers to significantly increase the use of fire as a resource management tool in the wildlands. These land managers consider their wildlands to be unhealthy as a result of past management strategies. The absence of fire effects has allowed plant species (e.g., trees and shrubs) that would normally be eliminated by fires to proliferate, vegetation to become dense and insect infestations to go unchecked. Wildland managers plan to significantly increase their use of fires to correct these unhealthy conditions and to reduce the risk of wildfires to public and fire fighter safety.

This policy statement integrates two public policy goals, (1) to allow fire to function, as nearly as possible, in its natural role in maintaining healthy wildland ecosystems, and (2) to protect public health and welfare by mitigating the impacts of air pollutant emissions on air quality and visibility. This document provides guidance on minimizing air pollution impacts caused by fires in the wildlands and the wildland/urban interface. It identifies the responsibilities of wildland owners/managers and State/Tribal air quality managers to work together to coordinate burning activities, minimize air pollutant emissions and manage smoke from wildland and prescribed fires. The goal of such planning is to minimize adverse air quality and visibility impacts, and establish emergency action programs to respond to unavoidable impacts on public health.

II.	SCOPE AND APPLICABILITY

This policy applies to all wildland and prescribed fires that occur on public, Indian and privately owned wildlands, regardless of the cause of ignition (e.g., lightning, arson, accidental, land management decision, etc.) or purpose of the fire (e.g., natural, resource management, hazard reduction, etc.). The term "prescriptive fires" is used in this document to refer to all fires (both management and naturally ignited) that are managed within a prescription to meet land use planning objectives. Planning for naturally ignited fires is obviously limited, but a fire plan must be included in the land management plan for the area ignited, otherwise the naturally ignited fire cannot be used to meet management objectives. Naturally ignited fires in areas without a fire plan are wildfires. The interface between this policy and the Natural Events Policy regarding ambient PM-10 concentrations caused by wildfires is addressed in section VII.

This policy does not apply to other open burning activities, such as burning at residential, commercial or industrial sites; open burning of land clearing waste or construction debris. It also does not apply to open burning of agricultural waste, crop residue or land in the USDA Conservation Reserve Program. The EPA is working with the USDA Agriculture Air Quality Task Force to develop equitable policies for emissions from activities that could be classified as agricultural burning.

This policy addresses impacts of air pollutant emissions from wildland and prescribed fires on public health and welfare. Ambient air quality impacts, in terms of particulate matter concentrations above the NAAQS for fine particles with an aerodynamic diameter less than or equal to a nominal 2.5 micrometers (PM-2.5), and particles with an aerodynamic diameter less than or equal to a nominal 10 micrometers (PM-10), are used as the primary indicators of public health impacts. Emissions of nitrogen oxides (NOx), volatile organic compounds (VOC), and carbon monoxide (CO) from wildland and prescribed fires can also impact the NAAQS for nitrogen dioxide (NO2), ozone (O3), and CO. However, the actions required to reduce NOx, VOC and CO emissions are the same as those recommended in this document to mitigate impacts on the PM-2.5, and PM-10 NAAQS.

The effects of wildland and prescribed fire emissions on the public welfare aspects of the NAAQS for particulate matter are addressed in terms of visibility impairment and regional haze. The policy also addresses the treatment of wildland and prescribed fire emissions to meet other Clean Air Act requirements, such as prevention of significant deterioration (PSD) and conformity with State implementation plans (SIPs) or Tribal implementation plans (TIPs). This policy recommends that States/Tribes implement smoke management programs to mitigate the public health and welfare impacts of wildland and prescribed fires. While smoke management programs will also mitigate nuisance smoke intrusions, nuisance issues have been left for the individual air quality agencies to address.

III.	BACKGROUND

This section is a summary of information found in Appendix A on the natural role of fire in North American ecosystems, changes in federal fire management policies which partially prompted this EPA policy, and the air quality considerations of smoke from fire. Background material on the role of fire was gleaned from several Forest Service publications and from magazine and journal articles on the subject. Please refer to Appendix A for more complete background information and a list of references used in compiling this information.

A. The Role of Fire

The role of fire in North American ecosystems has been undergoing change since man began to play a more active role in managing our natural resources. Native Americans actively used fire to alter vegetative patterns, to ease travel, or for hunting purposes. Prior to European settlement, fire played a natural role as a necessary disturbance phenomena, keeping forest fuels in check as well as insects and the diseases they carry, thereby maintaining north american forests in a healthy state. After European settlement and the introduction of grazing herds of cattle and sheep, and the practice of fire suppression, public land management agencies have recognized that not allowing fire to play its natural role in our wildlands has had unintended negative effects. When forests and grasslands are not allowed to burn naturally (lighting serving as the principal source of ignition) the result can be heavy accumulation of dead vegetation which provides fuel for unwanted fires (wildfires). Because of this unhealthy build-up of fuels, the risk of catastrophic wildfires is much greater as evidenced by several recent fires in our national forests and other public lands. These fires put firefighters and the general public in danger while destroying millions of acres of forests and costing millions of dollars to suppress. This situation has led to a rethinking of federal land management and fire management policy.

B. Changes in Fire Management Policy

In 1995, a Federal Wildland Fire Management Policy and Program Review was conducted in response to the unhealthy condition of our public wildlands, and the increase in unplanned fires that occurred in 1988 and 1994. As a result of this review, the five principal Federal fire/land management agencies (the Forest Service (FS) under the Department of Agriculture; and the Bureau of Land Management (BLM), National Park Service (NPS), Fish and Wildlife Service (FWS), and the Bureau of Indian Affairs (BIA) under the Department of Interior agreed on need for several changes to existing fire/land management practices. Their recommendations include the reintroduction of fire (allowing it to play its natural role) into federal land management programs in "an ongoing and systematic manner, consistent with public health and environmental quality considerations." The goals of this change in land management policy are to reduce unnatural fuel densities that contribute to increasing unplanned fire hazards, and to restore wildland ecosystems to their healthy natural states. The Federal agencies previously mentioned began increasing the use of fire in their most vulnerable wildlands in 1997. Annual treatment targets will be increased to a projected 3 million acres per year by 2003.

C. Air Quality Considerations

Wildland and prescribed fires can release thousands of tons of air contaminants into the atmosphere, including Particulate Matter (PM) and organic and inorganic gaseous compounds. Fine particulate matter from such fires can present threats to public health, along with nuisance and safety concerns. These adverse impacts can be widespread, since smoke can travel hundreds of miles and affect large areas. Fine particles in smoke represent a health concern because they remain suspended in air for a long period of time, and can easily penetrate deep into the lungs. A number of recent health and air quality studies in communities throughout the U.S. and other countries have associated significant public health effects in populations with exposure to present-day concentrations of PM. These studies are the basis for the July, 1997 promulgation of new National Ambient Air Quality Standards for PM2.5 , which are designed to protect public health, with an adequate margin of safety.

Not only are fine particles associated with serious health effects, but are also a major reason for visibility impairment in such places as national parks that are valued for their scenic views and recreation.

D. Air Contaminant Emissions

Burning wildland vegetation causes emissions of many different chemical compounds, including gases, fine particles, whose quantities and components depend in part on the types of fuel, moisture content, and the temperature of combustion. Complex organic materials which are absorbed into or on condensed smoke particles are also released by burning vegetation. Tests indicate that most smoke particles from wildland fires (90 percent) are PM10, and 70 percent are PM 2.5.

Historically, EPA's standards for Particulate Matter have often tended to focus emission control efforts on "coarse" particles--those larger than PM 2.5. Before 1987, EPA's particulate matter standards focused on "Total Suspended Particles," including even larger-sized particles. In 1987, responding to new science showing that it was the smaller particles capable of penetrating deeply into the lungs that were associated with the most adverse health effects, EPA revised the standards to control only those particles equal to or smaller than 10 micrometers in diameter (or PM10). For comparison, a human hair is about 70 micrometers in diameter.

The most recent scientific review focused attention on the need to better address the "fine" fraction particles - those equal to or smaller than 2.5 micrometers in diameter. These more recent studies provide consistent and coherent, "evidence that serious health effects (mortality, exacerbation of chronic disease, increased hospital admissions, etc.) are associated with exposures to ambient levels of PM found in contemporary urban airsheds even at concentrations below current U. S. PM standards" (Criteria Document-U.S. EPA 1996a, p. 13-1). PM concentrations found now in many communities are associated with adverse health effects in the general population, including increased mortality and morbidity, altered lung function, increased respiratory symptoms, aggravated respiratory and cardiovascular disease. Sensitive sub-populations, such as children, the aged and those with existing cardiopulmonary or infectious respiratory disease, may experience effects at lower levels of PM than the general population, and the severity of effects might be greater.

E. Visibility Impairment

Visibility is an important welfare consideration because of its significance to public enjoyment of daily activities in all parts of the country. This is particularly true in the 156 mandatory Federal Class I areas, "Areas of Great Scenic Importance," protected by the visibility provisions of the Clean Air Act. Visibility conditions are determined by light scattering and absorption by particles and gases. Fine particles most responsible for visibility impairment are sulfates, nitrates, organic matter, soot and soil dust. Fine particles are more efficient per unit mass at scattering light than coarse particles. Light scattering efficiencies go up as humidity rises, due to water adsorption on fine particles, which allow the particles to grow to sizes comparable to the wavelength of light. There are distinct regional variations in visibility between Eastern and Western States, due, it is thought to generally higher relative humidities in the East. Naturally occurring visual range in the East may be between 105 to 190 Kilometers, while natural visual range in the West is between 190 to 270 Kilometers. EPA is proposing to deal with differences in visibility impairment through the Regional Haze program, which, according to the Clean Air Act should ensure that "Reasonable Progress" is made toward meeting the National goal of improving visibility in the Class I Federal Areas..

IV.	DESCRIPTION OF POLICY

The following statement of policy and guidance urges owners/managers of public, private and Indian wildlands to collaborate with State/Tribal air quality managers (air regulators) to achieve their goals of: (1) allowing fire to function in its natural role in the wildlands, and (2) protecting public health and welfare by minimizing smoke impacts.

The policy urges air quality managers to participate in public land management planning activities which involve selecting appropriate resource management treatments, including the use of fire, and to help identify air quality criteria for fire management plans. Air quality managers are urged to help evaluate the potential impacts of alternative resource treatments and assure that air quality/visibility concerns are adequately addressed in the public land management planning process. They are urged to solicit information from private and Indian wildland owners/managers on plans to use fire for resource management, to encourage them to consider appropriate alternative treatments, and to assist them in evaluating the potential air quality/visibility impacts of alternatives to meet particular management objectives.

Wildland owners/managers are urged to: (1) notify air quality managers of plans to significantly increase their future use of fire for resource management, (2) consider the air quality/visibility impacts of prescriptive fire and take appropriate steps to minimize those impacts, (3) consider appropriate alternative treatments, (4) and participate in the development and implementation of State/Tribal smoke management programs.

The policy allows States/Tribes flexibility in their approach to regulating wildland and prescribed fires. The policy also provides an incentive for States/Tribes to certify to EPA that they have adopted and are implementing a SMP that includes the basic elements identified in this policy. The main incentive for States/Tribes to implement a SMP is that, so long as the NAAQS are not violated, participation by burners in the basic SMP may be voluntary and the SMP does not have to be adopted into the SIP. Another incentive is the commitment by EPA to use its discretion not to redesignate an area as nonattainment when wildland and prescribed fires cause or significantly contribute to PM-2.5 or PM-10 NAAQS violations, if the State/Tribe required those fires to be conducted within a basic SMP. If high PM concentrations arise from fires, States/Tribes will be required to review the adequacy of the SMP, in cooperation with wildland owners/managers, and make appropriate improvements.

If States/Tribes do not certify that adherence to a basic SMP is required, no special consideration will be given to high PM concentrations attributed to wildland and prescribed fires. Rather, EPA will call for a SIP revision to incorporate a basic SMP and/or notify the governor of the State or the Tribal government that the area should be redesignated as nonattainment. The SMP adopted in response to the SIP/TIP call would require mandatory participation for greater than deminimis fires, and would be adopted into the SIP/TIP so that it is Federally enforceable. Also, the SIP/TIP would have to meet all other CAA requirements applicable to nonattainment areas.

Guidance for meeting Clean Air Act requirements to show conformity of Federal fire activities with SIPs, to prevent significant deterioration of air quality, to address visibility/regional haze impacts, and fire data requirements for SIPs/TIPs are also addressed in sections VIII and IX of this policy.

The following are guiding principles for implementing this policy:

Air quality and visibility impacts from wildland and prescribed fires should be treated equitably with other source impacts.

Land and vegetation management practices should be promoted that are best for wildland ecosystems, yet protect public health and avoid visibility impairment.

States/Tribes should foster collaborative relationships among wildland owners/managers, air quality managers and the public to develop and implement smoke management programs.

States/Tribes will be allowed the flexibility (prior to measuring violations of the PM-2.5 or PM-10 NAAQS attributable to wildland and prescribed fires) to decide when a smoke management program is needed and how the program will be designed to prevent adverse air quality/visibility impacts. This does not preclude wildland owners/managers from including smoke management components in burn plans for fires they conduct in the absence of an applicable State/Tribal program.

All parties (wildland owners/managers, air quality managers and the public) are expected to act in good faith and will be held accountable for implementing their respective parts of fire and smoke management programs.

V.	COLLABORATION AMONG LAND AND AIR QUALITY MANAGERS

Wildland owners/managers and air quality managers can overcome the barriers to achieving their goals of: (1) returning fire to its natural role in the wildlands and (2) protecting air quality and visibility, by working together toward those ends. Wildland owners/managers should notify State/Tribal air quality managers if they are planning to significantly increase the use of fire to manage wildland resources. Air quality managers with Federal/State/ local public wildlands within their jurisdictions have a responsibility to participate in the public planning processes conducted for the management of those public lands. To arrive at the best choice of resource treatments and response to fire, it is essential that the air quality impacts of planned land management activities are adequately addressed. Air quality managers, by participating in the public land management planning process, can participate in selecting the scope of land uses; participate in evaluating alternative management tools and identifying when fire is appropriate; and review projected air quality and visibility impacts. Air quality managers should also consult with private wildland owners/managers to determine long-range resource management objectives and assist them in evaluating the applicability of alternative treatments based on air quality and visibility considerations.

Wildland owners/managers also have a responsibility to participate with the other stakeholders and State/Tribal air quality managers in developing rules and smoke management programs for prescribed fires. Air quality managers that intend to develop or revise regulations, plans or policies applicable to prescribed fires should solicit the early participation of all affected wildland owners/managers in making those revisions.

A.	Land and Vegetation Management

Wildlands are managed by Federal, State and local public agencies (referred to in this document as public land management agencies), Tribal/Bureau of Indian Affairs authorities and private land owners. The goals of public land management agencies vary, but are generally to develop, maintain and enhance wildlife habitat; protect endangered plant and animal species; preserve and protect cultural resources, scenic vistas and wilderness; provide for recreation; and to sustain production of natural resources. The goals of private land owners/managers may be sustained production of natural resources, preservation of wildlife habitat, improved grazing conditions, etc. The goals of Tribal wildland managers are generally similar to public land management agency goals, but may also include aspects of private land owners. Another common goal of all wildland managers is to minimize the potential for catastrophic wildfires that could result from heavy accumulations of vegetative fuels.

1.	Alternative Treatments

Wildland owners/managers have an array of tools, including fire, that can be used to accomplish land use plans, depending on the goals to be achieved. Owners/managers should consider the environmental impacts of the alternative tools

and whether combinations of alternative treatments will meet management objectives while minimizing the environmental impacts.

a.	Utilization and mechanical treatments

Mechanical treatments may be appropriate tools when management objectives are to reduce fuel density to reduce a wildfire hazard, or to remove logging waste materials (slash) to prepare a site for replanting or natural regeneration. On-site chipping or crushing of woody material, removal of slash for off-site burning or biomass utilization, whole tree harvesting, and yarding (pulling out) of unmerchantable material may accomplish these goals. Mechanical treatments are normally limited to accessible areas, terrain that is not excessively rough, slopes of 40 percent or less, sites that are not wet, areas not designated as national parks or wilderness, areas not protected for threatened and endangered species and areas without cultural or paleological resources.

b.	Chemical treatments

When the management objective is to preclude, reduce or remove live vegetation and/or specific plant species from a site, chemical treatments may be appropriate tools. Other potential environmental impacts caused by applying chemicals must also be considered, however.

c.	Fire

Fires are one of the basic tools relied upon by land owners/managers to achieve a myriad of management objectives in fire dependent ecosystems. Most North American plant communities evolved with recurring fire and, therefore, are dependent on recurring fire for maintenance. The natural fire return interval may vary from 1-2 years for prairies, 3-7 years for some long-needle pine species, 30-50 years for species such as California chaparral, and over one hundred years for species such as lodgepole pine and coastal Douglas fir. When the management objective is to maintain a fire dependent ecosystem the effects of fire cannot be duplicated by other tools. Fire can also be used to reduce heavy fuel loads and prevent catastrophic wildfires.

When fire is the most appropriate management tool, the air quality/visibility impacts of its use should be considered. Appropriate steps should be taken to minimize those impacts and comply with applicable SIP/TIP requirements. Appropriate actions may include mechanically or chemically pretreating an area to thin the fuel load prior to the use of fire.

2.	Role of Federal Land Managers

The major Federal agencies with land management responsibilities include the United States Department of Agriculture (USDA) Forest Service (FS), the Department of the Interior (DOI) National Park Service (NPS), Fish and Wildlife Service (FWS), Bureau of Land Management (BLM), and Bureau of Indian Affairs (BIA). These agencies manage national parks, forests, monuments, wilderness areas, prairie grasslands, sea shores, Indian lands, wildlife refuges, etc. The Department of Defense (DOD) and Department of Energy (DOE) also manage millions of acres of Federal land at military bases, training centers and for other purposes.

a.	Land use and fire management planning

Federal land use planning is an open process for setting land use and management goals and objectives. The planning process is designed for public participation, and must comply with the National Environmental Policy Act (NEPA). State/Tribal air quality managers are given the opportunity to participate in land use planning as part of normal intergovernmental consultation procedures. It is important for air quality managers to participate in public land use planning decisions to ensure that air quality concerns are adequately addressed. Through the public participation process, issues are identified and alternatives are discussed regarding methods for implementing land management activities such as trail building, improvement of wildlife habitat, timber harvesting, use of fire, etc. The environmental impacts of these activities are analyzed including, among other things, impacts on cultural resources, wildlife, vegetation, soils, riparian areas, wetlands, water quality, air quality, and visibility. Consideration of the air quality and visibility impacts of land management activities is essential to arriving at the best choice of treatments and response to fire.

Two or more levels of land use planning are conducted by Federal land managers (FLMs) to achieve management goals. First, broad scale and long-range land use plans must be developed for the administrative unit(s). The land use plan identifies the scope of actions and goals for the land and resources administered, and typically covers a 10 to 15-year period.

In addition to land use plans, there are other shorter term (typically 1-5 years) planning efforts where decisions are made concerning specific activities and programs, including the use of fire in the wildlands. These may include specific project plans or programmatic plans such as Fire Management Plans (FMPs). Project plans may involve decisions regarding tradeoffs between using mechanical and fire treatments for vegetation management to accomplish land use and resource management goals.

Fire Management Plans are developed by FLM's for each administrative unit to define how wildland and prescribed fires will be managed. FMPs must contain prescriptive criteria which are measurable and will guide selection of appropriate management actions in response to fires. The criteria can relate to suppression actions or describe when fire can be managed to gain resource benefits. This allows the use of a full range of appropriate management responses to fire, which may include: full suppression of a wildfire; suppression on part of a wildfire while allowing another portion of the fire to continue playing a natural ecological role; or the use of prescribed fire to achieve land use objectives. Burn plans prepared by FLMs should include smoke management components to minimize air quality/visibility impacts.

b.	Evaluating alternative treatments

Federal agencies evaluate the environmental impacts of the tools used for resource management on public lands using NEPA. They generally consider the impacts on, among other things, plant and animal species in the area, aquatic life, cultural resources, soil conditions, riparian areas, wetlands, water quality, air quality and visibility. Such analyses should be undertaken at both the individual project planning level and at the regional planning level if warranted by the extent of similar activities over a large area.

The impacts of resource management activities, particularly fire, on air quality can vary significantly by region. The impacts can be strongly affected by meteorology; existing air quality; the size, timing and duration of the activity; and other activities occurring in the same airshed at the same time. State/Tribal air quality managers can provide technical assistance with evaluating potential air quality/visibility impacts, thus aiding FLM's in their selection of tools and evaluation of the environmental impacts.

Air quality and visibility impact evaluations made of fire activities should:

-	include recent historic (e.g. 10 years) and projected (life of the plan) annual or seasonal emissions from wildland and prescribed fires. Emission projections should be based on estimates provided by land managers of acres burned, pre-burn fuel loading by vegetation type and consumption,

-	be related to analyses of cumulative impacts of fires on regional and subregional air quality, when possible.

-	identify applicable regulations, plans or policies (e.g. burn plans, authorization to burn, conformity, etc.),

-	identify sensitive receptors,

-	include description of planned measures to reduce smoke impacts,

-	identify the potential for smoke intrusions into sensitive areas, and model air quality and visibility impacts, when possible,

-	describe ambient air monitoring plans for prescribed fires, when appropriate.

3.	Role of State and Other Public Land Managers

State and local land management agencies manage public lands similar to Federal lands. These agencies differ from State to State, but can include forestry, conservation, park service, or fish and game agencies, as well as State or local fire protection agencies. Many agencies prepare long-range land use plans as well as project specific plans. Fire management plans, similar to those prepared by Federal agencies, may also be prepared. Public land management agencies generally assess the environmental impacts of proposed projects, such as prescribed fires, although the impacts evaluated vary from agency to agency.

Some State/local land managers also have responsibilities for private lands. Such responsibilities may include conducting prescribed burns and other fuels reduction programs aimed at reducing the potential for wildfires in the wildland/urban interface.

Land use planning for State/local public wildlands, although somewhat different from the Federal process, also requires preparation of written documents that are subject to public review.

State/local land managers should notify air quality managers of long-range plans to use fire for resource management. They should consider alternative management tools and evaluate the potential air quality/visibility impacts of wildland and prescribed fires. State/local land managers should also participate in the development of State smoke management programs.

4.	Role of Private Land Managers

Private land owners/managers may or may not prepare written land use or project plans depending on the organization and the size of the property. Land use plans for private lands are also not subject to public review, but activities on private lands must meet all applicable State and Federal requirements. State requirements include any specific SIP requirements applicable to private land owners which are designed to ensure that the State complies with CAA requirements. Private land owners/managers should provide information to the State on long- range plans to use fire for resource management and should participate in the development of State smoke management programs.

5.	Role of Indian Land Managers

Land use plans for Indian lands are not subject to review by the general public and are not subject to State regulations. Activities on Indian lands must meet the requirements of the CAA and the Tribal implementation plan (TIP), however, if one has been adopted. It is important that Indian land managers consider alternative wildland vegetation management tools and consider the air quality/visibility impacts of the management practices chosen both on and off of Indian lands. They should collaborate with other near-by wildland managers and air quality managers on regional smoke management programs to assure that combined wildland and prescribed fire activities will not cause adverse air quality/visibility impacts at sensitive receptors in the region.

6.	Role of Air Quality Managers

State air quality managers which have public wildlands within their jurisdiction, have the responsibility to participate in the public planning process conducted for those lands to be assured that air quality concerns are adequately addressed and they can meet the goals of their SIPs. They can participate in selecting the scope of land uses, identify air quality/visibility issues, and participate in evaluating and selecting alternative resource management tools. They can also help identify when fire is the appropriate tool and review the projected air quality and visibility impacts. They can also participate in identifying basic air quality criteria for fire prescriptions. To accomplish, this air quality agencies should heed solicitations of public participation from land managers and contact public land management agencies within their jurisdiction

State/Tribal air quality managers should also encourage private and Indian wildland owners/managers to consider alternative treatments and assist in evaluating the potential air quality/visibility impacts of alternatives for the particular management objective.

B.	Air Quality Management

State/Tribal air quality managers are responsible for adopting plans and rules sufficient to attain and maintain national and State air quality standards, prevent significant deterioration of air quality, remedy existing visibility impairment and prevent future impairment in mandatory Federal Class I areas caused by manmade sources of pollution. This is accomplished mainly by developing SIPs and TIPs. SIPs/TIPs include all programs and rules required by the CAA to meet and assure maintenance of Federal standards. SIPs/TIPs are frequently amended as State/Tribal rules are revised and new rules are adopted to meet changing CAA requirements. The EPA has the authority to adopt and implement Federal Implementation Plans (FIPs) to address air quality/visibility protection in areas where States or Tribes do not adopt plans.

1.	Role of State/Local Air Quality Managers

SIPs are developed in an extensive public process involving workshops and public hearings in which all stakeholders are invited to participate in developing the technical components of the plans including: (1) emission inventories; (2) modeling analyses; (3) attainment demonstrations; (4) transportation and general conformity emission budgets; (5) analyses of air quality data; and (6) control strategy development. State/local air quality managers should solicit information on the planned use of fire for resource management from all wildland owners/managers, just as they obtain information on other significant emission sources within their jurisdiction.

2.	Role of Tribal Air Quality Managers

Tribes may develop Tribal implementation plans (TIPs) to administer CAA requirements on Indian lands. EPA recognizes Tribal governments as the most appropriate parties to regulate the environment on Indian lands and has the authority to approve Tribal programs. EPA retains responsibility for implementing CAA requirements if Tribes do not adopt TIPs.

Tribal air quality managers should determine the potential for wildland and prescribed fires within their jurisdiction and the potential for air quality/visibility impacts on or from adjacent jurisdictions.

3.	Role of Public Land Managers

Public land managers have the responsibility to participate with the other stakeholders and air quality managers in developing SIPs. Public land managers, as experts in what is needed to meet land management and other environmental objectives, need to provide information on the areas that are to be treated with fire, air pollutant emissions estimates, and assistance in developing programs to track emissions, monitor air quality and visibility, and minimize air quality/visibility impacts.

Federal land managers of mandatory Class I areas must participate in the development of SIPs for regional haze and visibility impairment. Congress gave FLMs a key consulting role in the administration of visibility protection and "affirmative responsibility to protect air quality related values (including visibility) in Class I areas." [See section 165 of the CAA.]

VI.	SMOKE MANAGEMENT PROGRAMS (SMP's)

SMP's establish a basic framework of procedures and requirements for managing smoke from prescriptive fires and are typically developed by States/Tribes with cooperation and participation by land owners/managers. The purposes of SMP's are to mitigate the nuisance and public safety hazards (e.g., on roadways and at airports) posed by smoke intrusions into populated areas; to avoid significant deterioration of air quality and potential NAAQS violations; and to avoid visibility impacts in Class I areas. Some strong indications that an area needs a SMP are: (1) citizens increasingly complain of smoke intrusions; (2) the trend of monitored air quality values is increasing (approaching the daily or annual NAAQS for PM-2.5 or PM-10) because of significant contributions from prescriptive fires; (3) prescriptive fires cause or significantly contribute to monitored air quality that is already greater than 85 percent of the daily or annual NAAQS for PM-2.5 or PM-10; (4) prescriptive fires in the area significantly contribute to visibility impairment in Class I areas.

When a State/Tribe determines that a SMP is needed based on the above criteria, a basic program (described in the section) should be adopted. The complexity of a State/Tribal SMP should depend on the significance of prescriptive fires as sources of air pollutant emissions and/or visibility impairment in the State, region, and on Indian lands. General fire regulations may establish basic parameters, such as wind speed, direction, location and distance to sensitive receptors, etc., within which fires can be ignited or naturally ignited fire can be allowed to continue to burn, Such regulations leave much discretion to land owners/managers as to when to ignite fires, and what management strategy to follow with naturally ignited fires. States/Tribes may exercise enforcement authorities when land owners/managers are found to have ignited the fire outside of the parameters of the rule, or not to have appropriately responded to air quality impacts caused by naturally ignited fires.

General fire regulations may be adequate for areas where prescriptive fires rarely cause or contribute to air quality /visibility problems. However, when plans to use fire on a large scale could cause significant air quality/visibility impacts, or several land owners/managers within an airshed are expected to use prescriptive fires concurrently, a more structured SMP requiring cooperation and coordination of fire activities may be required to minimize air quality/visibility impacts.

State/Tribal air quality managers, public wildland managers, private and Indian wildland managers, and the general public should collaborate in the development and implementation of State/Tribal SMP's. Initially, States/Tribes may allow participation in a basic SMP to be voluntary and the program does not have to be adopted into the SIP/TIP or be Federally enforceable. The State/Tribal air quality manager must certify in a letter to the Administrator of EPA that at least a basic program has been adopted and implemented in order to receive special consideration of air quality data resulting from prescriptive fire impacts as explained in section VII. The following describes the basic components of a SMP.

A.	Authorization to Burn

The SMP should include a process for authorizing or granting approval to conduct prescribed fires (burns) within a region, State, or on Indian lands and identify a central authority responsible for implementing the program. The SMP central authority must promptly review fire applications and provide comments, if necessary. When authorizing a burn, the authority must consider all open burning activities (land clearing and construction wastes, agricultural wastes, etc.) allowed within an airshed. Neighboring States/Tribes are encouraged to create partnerships to coordinate fire projects when inter-jurisdictional air quality/visibility impacts are expected, so as to meet air quality and prescribed fire objectives. The air quality/visibility impacts of each fire project should be minimized regardless of political boundaries.

A burn plan should be required for greater than deminimis prescribed fires (fires that will consume greater than ... ton fuel or emit greater than ... tons of particulate matter, as established in the State/Tribal rule). The burn plan should be prepared by the wildland owner/manager and include, at a minimum, the:

-	location and description of the area to be burned,

-	personnel responsible for managing the fire,

-	start date and end date of fire,

-	type of vegetation to be burned,

-	area (acres) to be burned,

-	amount of fuel to be consumed (tons/acre),

-	fire prescription including smoke management components (discussed below),

-	criteria for making burn/no burn decisions,

-	safety and contingency plans addressing smoke intrusions.

Authorization to burn should be based on the smoke management components of the burn plan (section C, below), existing air quality/visibility and the ability of the airshed to disperse emissions (e.g., meteorological conditions) from all burning activities on the day of the burn. Predicted meteorological conditions for several days should be considered, especially for fires lasting longer than one day, to avoid aggravating existing problems. Wildland owners/managers must receive authorization from the central authority prior to conducting prescribed burns. Persons receiving authorization to ignite fires must comply with all applicable local, State, Tribal and Federal requirements. Persons responsible for managing greater than deminimis fires should be adequately trained in fire and smoke management. Fire managers should be required to follow the authorized burn plan or explain why it was necessary to deviate from the plan.

B.	Minimizing Air Pollutant Emissions

The SMP should provide incentives for wildland owners/managers to consider the alternative treatments discussed in section V.A.1., above. Incentives may include priority approval to burn, among other things, when the burn plan shows that steps to reduce emissions have been taken prior to the burn or steps will be taken during and after the burn. Public land managers typically consider and evaluate alternative means of achieving management objectives and the environmental impacts of each method. When prescribed fires are selected as the best means to accomplish management goals, however, there are several ways to reduce emissions from a single fire. The approaches fall into four categories and their applicability varies by fuel type, (1) minimize the area burned, (2) reduce the fuel loading in the area to be burned, (3) reduce the amount of fuel consumed by the fire, (4) minimize emissions per ton of fuel consumed. These emission reduction techniques rely almost exclusively on reducing the amount of fuel consumed by a particular fire. The excluded fuels could be consumed by a subsequent fire, however, unless they are removed from the area or biologically decompose. Also, generally these techniques cannot be used to reduce emissions from naturally ignited fires.

Emission reduction techniques are discussed further in Appendix B.

[Peterson/Leenhouts - What Wildland Fire Conditions Minimize Emissions and Hazardous Air Pollutants and Can Land Management Goals Still be Met?]

C.	Smoke Management Components of Burn Plans

Burn plans for prescriptive fires must include smoke management components. The term "prescriptive fires" is used in this document to refer to all fires (both management and naturally ignited) that are managed within a prescription to meet land use objectives. When public land management agencies have included a fire plan in the land use plan for an area, a naturally ignited fire in the area will be managed to meet the management objectives. If fire is not planned for the area, a naturally ignited fire is a wildfire requiring appropriate suppression action. Planning for naturally ignited fires is obviously limited, but a fire prescription with smoke management components is a minimum requirement. The following basic components that must be included in burn plans for prescribed fires. Appropriate components must also be included in prescriptions for wildland fires use to meet land use objectives.

1.	Actions to minimize prescribed fire emissions

The burn plan should document the steps taken prior to the burn and actions that will be taken during and after the burn to reduce air pollutant emissions. This includes measures that will be taken to reduce residual smoke, such as rapid and complete mop-ups, mop-ups of certain fuels, etc.

2.	Evaluate smoke dispersion

The burn plan should evaluate potential smoke impacts at sensitive receptors and time fires to minimize exposure of sensitive populations and avoid visibility impacts in Federal Class I areas. The plan should identify the distance and direction from the burn site to local sensitive receptor areas and to regional/interstate areas where appropriate. The fire prescription included in the burn plan should specify minimum requirements for the atmospheric capacity for smoke dispersal such as minimum surface and upper level wind speeds, desired wind direction, minimum mixing height, and dispersion index.

3.	Public notification

The plan should identify actions that will be taken to notify populations and authorities (e.g., local air quality managers) at sensitive receptors, including those in adjacent jurisdictions, prior to the burn.

4.	Air quality monitoring

The plan should identify how the effects of the burn on air quality and visibility at sensitive receptors will be monitored. The extent of the monitoring plan should match the size of the burn. For small burns, visual monitoring of the direction of the smoke plume and monitoring nuisance complaints by the public may be sufficient. Other monitoring techniques include posting personnel on vulnerable roadways to look for visibility impairment and initiate safety measures for motorists; posting personnel at other sensitive receptors to look for smoke intrusions; using aircraft to track the progress of smoke plumes; and continued tracking of meteorological conditions during the burn. For large burns expected to last more than one day, locating real-time particulate matter/visibility monitors at sensitive receptors may be warranted to facilitate timely response to smoke impacts.

For additional guidance on monitoring wildland fire impacts see Appendix C.

5.	Exposure reduction precautions

The plan should identify contingency actions that will be taken to reduce the exposure of people at sensitive receptors if smoke intrusions occur. Appropriate short-term (less than 24- hour) actions may, among other things, include:

-	Notifying the affected public (especially sensitive populations) of elevated pollutant concentrations,

-	Suggesting actions to be taken by sensitive persons to minimize their exposure (e.g., remain indoors, avoid vigorous activity, exposure to tobacco smoke and other respiratory irritants),

-	Providing clean-air facilities for sensitive persons,

-	Halting ignitions of any new open burning that could impact the same area,

-	Analyzing the fire situation and identifying alternative management responses upon becoming aware that a fire is out of prescription with regard to the air quality criteria, (Federal land management agencies perform a Wildland Fire Situation Analysis),

-	Consulting State/Tribal air quality managers regarding appropriate short-term fire management response to abate verified impacts,

-	Implementing management responses that will mitigate the adverse impacts to public health,

-	Reporting the steps taken to mitigate adverse impacts to the public and appropriate State/Tribal agencies after they have been completed.

D.	Public Education and Awareness

The SMP should establish criteria for issuing health advisories when necessary, and procedures for notifying potentially affected populations, including those in adjacent jurisdictions, of planned fires. A program should be implemented to explain the use and importance of prescribed fire for ecosystem management, the implications to public health and safety, and the goals of the SMP. Wildland and air quality managers should work with the press to announce pre-burn health advisories, and post-burn results including such things as the vegetation management objectives met; smoke intrusions observed, and/or successful minimization of air quality/visibility impacts.

E.	Surveillance and Enforcement

The SMP should include procedures to ensure that wildland owners/managers will comply with the requirements of the SMP. Burn managers must follow the burn plan, including the fire prescription and smoke management components, or explain any deviations from the plan. Memorandums of understanding may be used to specify the responsibilities of each State/Tribal agency in implementing the SMP.

F.	Program Evaluation

The SMP should provide for periodic review by all stakeholders of its effectiveness and revision of the program as necessary. The effectiveness review should be based on observations such as reports of smoke intrusions, nuisance complaints, and monitored air quality/visibility impacts. Post-burn reports should be required for fires that exceed their prescription and/or fires that cause smoke impacts at sensitive receptors. Post-burn reports for escaped fires should describe the incident, describe the contingency plan implemented, and provide recommendations to prevent future smoke related problems.

State/Tribal SMPs should include procedures for re-evaluating the adequacy of rules and regulations every 3 to 5 years. Such procedures should involve all the original participants (e.g., wildland owners/managers, air quality managers, the public, etc.) and should review the:

-	Amount of managed fire planned for the next 5 years,

-	Need to expand the scope of the program to include authorization of other open burning,

-	Need for changes in the smoke management program.

G.	Additional Air Quality Protection (Optional)

States/Tribes may adopt more stringent SMPs or include additional smoke management requirements for "special protection zones" to provide better protection against smoke impacts. Special protection zones could be buffers (e.g., 10-25 miles) around wildland/urban interface areas, nonattainment areas, or Federal Class I areas. Additional requirements for burns within a special protection zone may include no burning if high pollution levels already exist in the area. Also, special protections may only be required for burns that will last overnight, for multi-day burns or burns during specific seasons.

States/Tribes may also establish "performance standards" that would trigger implementation of additional smoke management requirements if exceeded in an area. The performance standards could set limits on the frequency and intensity (e.g., hours/day, particulate matter concentration, visibility impairment) of smoke intrusions. Implementation of performance standards may require real-time monitoring of air quality. Additional requirements for burns after the performance standards are exceeded may include better dispersion parameters (e.g., increased wind speed, mixing height, dispersion index, etc.).

VII.	ACCOUNTABILITY

A.	Role of State/Tribal Air Quality Managers

High particulate matter concentrations attributable to wildland and prescribed fires are valid air quality data that can be used to determine the attainment status of the area represented by the data. State/Tribal air quality managers are responsible for monitoring citizen complaints and air quality trends attributable to wildland and prescribed fires to determine when a SMP is needed to mitigate air quality/visibility impacts. Air quality managers should initiate the collaborative process needed to develop and adopt regulations for a SMP. If the State/Tribal air quality manager certifies in a letter to the Administrator of EPA that at least a basic program (described in section VI) has been adopted and implemented, special consideration will be given under this policy to air quality data resulting from prescriptive fire impacts.

1.	Wildfires

High particulate matter concentrations attributable to wildfires (unwanted wildland fires) can be treated as due to a natural event under EPA's Natural Events Policy. The Natural Events Policy provides that when areas violate the PM-10 NAAQS due to a natural event, EPA will: (1) exercise its discretion, under section 107(d)(3) of the Act, not to redesignate areas as nonattainment if the State develops and implements a plan to respond to the health impacts of natural events; and, (2) redesignate nonattainment areas as attainment by applying appendix K, on a case-by-case basis, to discount [ambient air quality] data in circumstances where an area would attain but for exceedances that result from uncontrollable natural events. The elements of a State/Tribal action plan to respond to the health impacts of natural events are described in the Natural Events policy statement. The EPA plans to revise the Natural Events Policy to also cover PM-2.5 NAAQS violations.

2.	Prescriptive Fires

Even when regulations applicable to prescriptive fires, including a SMP, are in-place, unanticipated events or conditions can result in adverse air quality/visibility impacts. Under this policy, high particulate matter concentrations attributable to prescriptive fires will be given special consideration, as described in section VII.B., if the State/Tribe has certified to EPA that it is implementing a basic SMP. Therefore, such air quality data should be flagged.

To assure compliance with their SMP, State/Tribal air quality managers must investigate the cause of high particulate matter concentrations attributable to prescriptive fires. Initially, the air quality manager should contact the wildland owner/manager responsible for managing the fire(s) to determine the probable cause of the impacts. The air quality manager has two goals: (1) to reduce immediate impacts on public health, and (2) to take appropriate steps to mitigate future impacts.

To reduce immediate impacts, the air quality manager should verify that contingency actions included in the burn plan to reduce exposure are being implemented. To assure compliance with current regulations and mitigate future impacts from prescriptive fires, air quality managers should determine whether, (i) a burn plan was submitted and the fire was authorized, (ii) the burn plan (including the dispersion prescription) was followed, (iii) the prescription failed and why.

If requirements of the SMP were not met, the State/Tribe can exercise various enforcement authorities to address the problem. If the fire manager complied with the SMP, the adequacy of the requirements should be reviewed. If air quality data are frequently flagged as resulting from failure of the fire prescription, EPA will call on the State/Tribe to work with wildland owners/managers to improve future burn plans and the SMP.

B.	Role of the Environmental Protection Agency

a.	Impacts with a SMP

If prescriptive fires cause or significantly contribute to PM-2.5 or PM-10 NAAQS violations, the State/Tribe must submit the following documentation to EPA to avoid redesignation of the area to nonattainment:

Evidence supporting the finding that flagged air quality values were due to prescriptive fires,

Evidence that the fires were subject to a State/Tribal certified SMP.

If the evidence is convincing, EPA will exercise its discretion under section 107(d)(3) not to redesignate the area as nonattainment. Rather, EPA will call on the State/Tribe to review the adequacy of the SMP in collaboration with wildland owners/managers (following the first NAAQS violation based on three calendar years of data) and make appropriate improvements to mitigate future air quality/visibility impacts. The same procedure will be followed if a NAAQS violation occurs based on the subsequent three calendar years of data. If a third violation of the NAAQS is attributed to prescriptive fires, however, EPA will call for the SMP to be made part of the SIP/TIP and be Federally enforceable.

b.	Impacts without a SMP

If a certified SMP has not been implemented, EPA will not give special consideration to the high particulate matter concentrations attributed to prescriptive fires that cause or significantly contribute to: (1) violations of a PM-2.5 or PM-10 NAAQS, (2) visibility impairment in mandatory Federal Class I areas, or (3) failure to achieve reasonable progress toward the national visibility goal. Rather, EPA will call for adoption of the basic SMP, described in section VI, as part of the SIP/TIP for particulate matter and visibility. EPA will also notify the State/Tribal government that the area should be redesignated as nonattainment. The SMP adopted in response to the SIP/TIP call must require mandatory participation for greater than deminimis fires, must be adopted into the SIP/TIP, and must be Federally enforceable. The SIP/TIP will also have to meet all other CAA requirements applicable to nonattainment areas.

C.	Role of Wildland Owners/Managers

Wildland owners/managers are responsible for following State/Tribal regulations applicable to prescriptive fires, obtaining authorization to burn when required, and following the approved burn plan. Owners/managers are responsible for taking appropriate actions to control the fire and reduce exposure to smoke when adverse air quality/visibility impacts result from a failure of the prescription or an escaped fire.

There is a special need for prescriptive fires managed by Federal agencies to have burn plans that include smoke management components. Fires managed by Federal agencies are most likely to impact air quality in recreation areas (national parks, forest, etc.) and impair visibility in mandatory Class I areas. The EPA encourages Federal agencies to include smoke management components in all burn plans, regardless of the existence of a State/Tribal SMP.

VIII. DATA ON WILDLAND FIRES

Most of a State/Tribal program to protect air quality/visibility is contained in a SIP or TIP. Since the use of prescriptive fires for vegetation management is expected to increase substantially, especially on Federal lands, State/Tribal air quality managers will need information to develop potential annual or seasonal air pollutant emission estimates for SIP/TIP planning. As for any source, emissions for prescriptive fires can be estimated by multiplying the estimated level of activity by an emission factor. For prescriptive fire, the level of activity is the mass of biomass (fuel) consumed, usually expressed in tons; and an emission factor (from AP-42) expressed in pounds per ton of fuel consumed. Emission factors for criteria pollutants are derived from an estimate of overall combustion efficiency (i.e. stoichiometric ratio). The mass of fuel consumed is the product of fire size (acres), pre-burn fuel loading (tons per acre), and fuel consumption (percent of pre-burn loading). An emission inventory can be compiled by the affected air agency for an individual fire, a statistical class of fires, a burn program, or a population of fires in a given area over a period of time based on this information.

Federal land management agencies currently collect data on some wildland and prescribed fires, however, no standard reporting format is followed. Emissions from wildfires will generally not be needed by air quality managers, however, FLM's usually have individual report data for large wildfires (greater than 100 acres), if needed. These raw data are usually limited to the time and approximate location of the fire, fire perimeter area, weather (occasionally) and a qualitative description of fuels at the point of ignition. Data on medium-size wildfires (10 to 100 acres) are often available, also, and occasionally data are available for small wildfires (less than 10 acres).

A National Interagency Fire Statistics Information Project has been initiated to develop an easily accessible system for storing a set of commonly agreed upon fire data. Post-burn data, such as that described above, on future wildland and prescribed fires would be stored in this database. The database will be accessible by air quality managers to estimate past, current, and future emission trends from this source category.

EPA encourages the Federal land management agencies to develop the fire statistics database and FLM's to report fire data to the system. These fire data will be required for air quality managers in regions where most wildland and prescribed fires occur on Federal lands. Air quality managers should request similar fire data for wildland and prescribed fires on State, private and Indian wildlands as well as information on other types of open burning to complete their emission inventories.

Statewide emissions from prescribed fire activity in all 50 states during 1989 have been estimated based on a survey of [Federal, State and private] land owners/managers. [Ref. Peterson/Ward] Also, a spatially resolved inventory of prescribed burning by county for 1990 and by 50km grid for 1995, 2015 and 2040 was prepared for 10 western States as part of the GCVTC activities. [Ref. Peterson/Lahm] The emission estimates are based on fuel models derived from 14 types of vegetative cover spatially mapped throughout the area and estimates of fuel loadings as low, medium or high. The procedures followed by Peterson and Lahm to estimate emissions for the western states provide a good model for developing prescribed fire emissions estimates for other areas, also.

Further guidance on developing emissions estimates and the information required can be found in Appendix D [Emission Inventories for SIP Development].

IX.	MEETING OTHER CLEAN AIR ACT REQUIREMENTS

1.	Demonstrate Conformity of Federal Activities

Activities on Federal lands must meet the requirements of the Clean Air Act and be shown to "conform" with the purpose of the State implementation plan (SIP) where the activity is taking place. Conformity rules apply to Federal actions taken within a nonattainment or maintenance area. The rules require a federal agency to demonstrate, prior to initiating a project, that its action conforms to all applicable requirements in a SIP and will not cause NAAQS to be violated. The conformity demonstration usually takes the following forms: (1) a modeling demonstration to show that emissions from the project will increase the frequency or severity of a NAAQS violation, (2) obtaining emission reductions that offset the new project emissions, or (3) showing that the project's emissions are already included in the emissions inventory of that nonattainment or maintenance area.

The above procedures can be followed to demonstrate conformity of fire projects for a Federal land management agency's administrative units based on the Fire Management Plan for a unit. The demonstration can be made on an annual basis for all burns within the airshed of a nonattainment or maintenance area. Alternatively, the demonstration can be made for each individual fire project conducted at the administrative unit.

The above methods of demonstrating conformity of Federal fire projects require substantial agency resources. As an alternative, EPA will presume that the FMP for an administrative unit conforms to the SIP if the fires are managed within a "stringent" SMP (if this presumption is acceptable to the affected States). For this purpose, a "stringent" SMP requires regional coordination (cooperation of all jurisdictions in an airshed) of burn plan authorization and real-time air quality monitoring at sensitive receptors, in addition to the basic program elements discussed in section VI.

If EPA or a State finds that exceedances of the NAAQS are occurring due to Federal fire projects, even with the implementation of a stringent SMP, the above policy of presumed conformity will be revoked, or additional measures and performance standards will be added to the SMP.

2.	Visibility/Regional Haze Requirements

EPA's visibility regulations (45 FR 80084, December 2, 1980) protect mandatory Federal Class I Areas from manmade impairment that is "reasonably attributable" to a single emission source or small group of sources. A new regulatory program to protect these areas from "regional haze" impairment was proposed by EPA on July 31, 1997 (62 FR 41137). FLMs for Class I Areas have a key consultative role and responsibility to participate in the development of SIPs for visibility impairment that is reasonably attributable to specific sources. In Part C of the Clean Air Act which includes the visibility protection mandate, Congress assigned FLMs the "affirmative responsibility to protect air quality related values (including visibility)" in Federal Class I Areas.

The regional haze proposal and visibility protection regulations require States to develop a long-term strategy (LTS) to make reasonable progress toward the CAA's national visibility goal (See CAA Section 169A). That goal specifies "the prevention of any future, and the remedying of any existing, impairment of visibility in mandatory Federal Class I Areas which impairment results from manmade air pollution". Consideration of "smoke management techniques for agricultural and forestry management purposes including such plans as currently exist within the State for these purposes" is one of several factors States are required to address in developing their LTS. The proposed regional haze rule, as well as existing visibility regulations, provides flexibility for States to include all "other reasonable measures" in their LTS to deal with air pollution sources in order to make reasonable progress toward the national visibility goal. Effective long-term strategies will require source emission reductions commensurate with the degree (magnitude, timing, etc.) of their contribution to manmade visibility impairment in mandatory Class I Areas.

Current monitoring information on visibility in the mandatory Federal Class I areas is readily available, with summaries published by EPA in its annual assessments of air quality and emission trends. In the development and implementation of LTSs for regional haze, States are encouraged to review this information periodically to ensure that smoke emissions from prescribed fires do not jeopardize reasonable progress toward the national goal of remedying or preventing manmade visibility impairment.

Under EPA's 1980 visibility regulations, States must take appropriate actions to address all sources of visibility impairment, including prescribed fire, in response to a FLM's certification of reasonably attributable impairment in Class I areas. After the proposed regional haze rule becomes final, States will also need to address the impacts of these sources on meeting reasonable progress during the periodic progress assessments to be required by the rules. Appendix E presents a range of options for defining natural wildland and prescribed fire emissions that may or may not be consistent with the final regional haze rule. EPA will issue further guidance on developing LTSs in the future.

3.	Prevention of Significant Deterioration

The PSD program applies primarily to new stationary sources and modifications of existing sources that will cause major increases in air pollutant emissions in "clean airsheds" (those currently designated as attainment or unclassifiable). Major new or modified stationary sources are required to minimize emissions by using best available control technology (BACT). Also, before obtaining a permit to construct, the proposed source must demonstrate that its emissions increase will not cause the air quality in the clean airshed to deteriorate beyond an amount or level known as an "increment." Increments for PM -10 were adopted in June 1993. The PM-2.5 NAAQS became effective September 16, 1997, and no increments have yet been adopted. Emissions from stationary sources are considered permanent since they occur either continuously, seasonally or intermittently, year after year, as part of an ongoing activity.

Prescribed fires do not require construction permits under the PSD program, and the emissions resulting from these fires have generally not been viewed as consuming increments because of their temporary nature. The air quality manager's goal is to limit new, permanent emission increases in clean airsheds through the PSD program. Emissions from prescribed fires occur very infrequently at a particular location (e.g., once in 5 to 20 years) and their duration is usually short (one day). States/Tribes with EPA-approved PSD programs are allowed to exclude "constuction or other temporary emission-related activities" from increment consumption. Under some EPA policies, emission-related activities lasting as long as five years have been treated as "temporary." [See Transportation Conformity rule.]

The purpose of this policy statement, however, is to address issues raised by projected significant increases in the use of fire as a resource management tool. While prescribed fires may cover larger areas and last longer (several days) than past fires, they will reduce the risk of catastrophic wildfires. EPA believes that it is essential to consider the overall benefits associated with a fire program, rather than to focus simply on the temporary nature of the emissions resulting from these fires. Therefore, the reduction of "normal" wildfire emissions achieved by prescribed fire programs should also be considered in evaluating the overall environmental effect of the program.

States/Tribes should assess the potential increases and decreases in emissions from prescribed fires and wildfires, respectively, to determine the expected overall environmental effects of prescribed fire programs. Where the benefits of an expanded fire program can be shown, EPA believes that the emissions resulting from the increased frequency of such burning activities be exempted from PSD increment consumption calculations.