Comments Regarding the Draft Wildland Fire/Air Quality Policy

Submitted by Paula Seamon, Assistant Director; Fire Management & Research Program, The Nature Conservancy; Route 1, Box 678; Tallahassee FL 32312; phone 850-668-0827.

I am writing on behalf of The Nature Conservancy, a private non-profit conservation organization dedicated to preserving biodiversity. The Conservancy is also a private landowner which conducts about 350 prescribed fires per year, burning about 380,000 acres. Our burns are usually conducted to meet ecological management goals, such as restoration of rare plant populations and rare animal habitat, and maintenance of superior examples of natural communities.

In general, The Nature Conservancy would have little difficulty complying with the terms of the program outlined in the Draft Policy. Our prescribed fire managers routinely take many of these suggested actions for better smoke management. The proposed consideration of air quality violations from prescribed fires seems quite reasonable. There are several points which raise my concern, however, and I will detail those by referencing specific sections of the text.

Section IIIA - Background: The Role of Fire (p. 9)

The explanation of the natural role of fire is good, but the description of unintended negative effects of fire exclusion misses a key point, from our perspective. Fire exclusion leads to an alteration in natural community types, and a tremendous loss of biodiversity. Many plant and animal species are on the decline because they exist in fire-dependent habitats that haven't burned in decades. Also, the catastrophic fire scenario doesn't play out in the southeast, where fire exclusion will eventually lead to a change to vegetation types that are less flammable. After several decades, an area may not carry fire at all. Again, the loss of ecosystem types or species is the greater risk from fire exclusion in this area.

This may seem like a fine point to you, but it is frequently the significant argument we must make when we have to persuade state air regulators or the public that fire is essential for management of our preserves. I'm sure there are also federal and state land managers who burn for similar ecological goals. It would be better to state it up front, and not try to justify all burning via the scare tactics of potential catastrophe.

Suggestion: Add a sentence - "The lack of fire also has unintended ecological effects, leading to the loss of habitat for rare species and the decline of ecosystems."

Section V.A.1 - Land and Vegetation Management (p 14-15)

Good section. The language is clear, and reflects well the diversity of land management goals met with fire. Section V.A.1.c. is especially good in that it points out there are scenarios where alternative treatments won't substitute for fire.

Section V.A.6 - Role of Air Quality Managers (p 19, line 5)

I question whether air quality managers have the knowledge, time, or interest to help identify when fire is the appropriate land management tool. That decision should reside with the land owner/manager.

Suggestion: Strike the sentence beginning with "They can also help identify...

Section VI.A. Authorization to Burn (p 21)

The Conservancy requires burn plans for all its burns, so requiring a plan does not bother us. However, I am sure a plan would be viewed by many private landowners as a costly imposition.

I strongly feel that the detail of the plan components (i.e. the list beginning on line 39) should be removed, and left up to the individual states. There are specific problems with many of the items (e.g. burn date - fire managers cannot predict exactly which day will present good burning conditions), and regional issues that should be considered. Also, some of these issues may be taken into consideration in the authorization process, making them unnecessary in the burn plan itself.

Suggestion: Remove the itemized list of burn plan components.

Section VI.B. Minimizing Air Pollutant Emissions (p 22)

I am very concerned by the implications of granting priority authorization to burn to owners/managers who use alternative treatments. The document acknowledges earlier that there are situations where fire is the most appropriate, or only, tool available. Now it suggests penalizing managers for using the most appropriate tool. What does "among other things" mean (ln 23)? I suspect these couple of sentences don't say what you really mean.

Suggestion: Change first sentence to: "The SMP should provide incentives for wildland owners/managers to consider alternative treatments or emission reduction techniques before, during or after the burn." Eliminate the sentence beginning "Incentives may include... Then leave it up to the states to decide what the incentives will be.

Section VI.C. Smoke Management Components of Burn Plans (p 23)

Again, this is not a concern for the Conservancy since we require smoke management plans within our burn plans, but many private landowners will be alarmed by the prospect of doing this.

My only real concern here is with point VI.C.2. We would routinely prescribe parameters for dispersal conditions, but in most states we cannot get this information on the day of the burn. The National Weather Service cannot provide private landowners with this sort of specific meteorological information (although they did in the past - this is a policy change). We want to prescribe and use these parameters to make go/no-go decisions, but we can't get the information!

Suggestions: Strike the last sentence of VI.C.2. Or, specify that authorization to burn will be granted based on favorable dispersion conditions on the day of the burn. The state would then be responsible for evaluating these parameters.

Better suggestion: Get the NWS to provide private landowners with dispersion forecasts!

Section VI.C.5 Exposure reduction precautions (p 24)

Few private landowners will have the resources to take many of the actions listed in lines 16-29.

General comments on the document

The document does not accurately reflect the flexibility Ms. Shaver and Mr. Woodard spoke about during the meeting in Atlanta. The language is much more stringent than what I was hearing during the meeting. I suggest reviewing the plan overall to look for instances where this can be addressed.

I think some of the people at the Atlanta meeting were confused because they didn't understand the flow of the proposed process, and who did what. I suggest a flow chart or diagram outlining who (feds, state, FLM's, private landowners, etc.) is responsible for which actions. This should make the document clearer, and serve as a key for communications between interested parties.

Thank you for the opportunity to comment.