Summary of Wildland Fire Issues Group Steering Committee Meeting

Washington, D.C.

April 22 - 23, 1997

I.	PURPOSE

The Wildland Fire Issues Group Steering Committee met on April 22 and 23, 1997 in Washington, D.C. to review report-outs generated by the Policy Issues, Science and Technology, and Communications Groups. Presentations on the Forest Service and State of Florida's prescribed burning plans for 1997 were also given to provide insight into the type of policy the Steering Committee may want to develop.

II.	PARTICIPANTS

Attendees

Dwight Atkinson, EPA

Bob Clark, BLM

Bill Dickerson, EPA

Jim Douglas, DOI

Claire Hong for Anita Frankel, EPA Region X

Donna Lamb, USDA Forest Service

Mary Jo Lavin, USDA Forest Service

Brian Mitchell, National Park Service

Mel Olmscheid for Ron Tickle, DOD Clean Air Act Services Steering Committee

Bob Palzer, Sierra Club

Margie Perkins, Colorado Department of Environment and Public Health

Earl Peterson, Florida Department of Forestry

Howard Rhodes, Florida Department of Environmental Protection

Gary Rothwell for Joe Williams, Washington State Department of Ecology

Sally Shaver, EPA

Sandra Silva, U.S. Fish and Wildlife Service

Dennis Thompson, USDA, NRCS

Arch Wells, Bureau of Indian Affairs

Ken Woodard, EPA

Steering Committee Members Not in Attendance

Les Rosenkrance, National Interagency Fire Center

James Hubbard, Colorado State University

William Becker, STAPPA/ALAPCO

Richard Hayslip, Salt River Project

Other Attendees: Don Arkell, Arkell Consulting Service (WESTAR), Gary Blais, EPA

Tom Stobert and Wendy Vit, EC/R Incorporated (EPA contractor support)

III.	ACTION ITEMS

Guiding Principles: Based on the April 22 discussion, Mr. Mitchell revised the Guiding Principles and distributed them on the morning of April 23. The first four principles (listed under principles related to policy development and costs in the April 8, 1997 draft) were moved to the givens section. A reference was made to the regional planning concepts being discussed in the Federal Advisory Committee Act (FACA) on NAAQS and regional haze implementation. In the next draft, Mr. Mitchell will enhance the air quality planning principles with language about criteria pollutants and toxics. The revised draft will be distributed to the Steering Committee.

Science and Technology group: Develop elements of a successful Smoke Management Plan (SMP) and criteria for each of the three tiers. Consider preparing a matrix for presenting the information in the SMP document. Assess the viability of an emissions- based policy similar to a SMP. If not, what is a more scientific approach. Identify which questions need further research and determine who will conduct the research. Determine what data are available and where gaps exist. The Steering Committee wants S&T to establish the levels of a successful SMP and the criteria for each level. Resources should be spent on understanding emissions from burns. S&T should gather all the studies and report on the status of their research effort.

Policy Issues group: Coordinate with the agricultural task force on defining grasslands/pastures. The policy should develop the process. It should address conflicting timeframes and consequences for failure. This policy must attempt to meet the NAAQS. The national policy should not distinguish among types of fire, but local agencies could distinguish among purposes. The policy should be crafted such that it defines a process for allowing areas to prioritize their prescribed burning plans as needed. The policy must develop mechanisms for addressing conflicting goals.

Communication and Outreach group: As soon as possible, develop a brief statement explaining the wildland fire policy group's mission and composition. A conference call will be scheduled to review the draft statement. Develop a press release, questions and answers for managers, and three or four talking points for officials. Formulate criteria for posting documents (e.g., final and interim work products, etc.) at various websites. Look into creating linkages among the appropriate websites. Mr. Blais will distribute instructions for gaining access to various websites, including STAPPA/ALAPCO, WESTAR, and FACA.

The next FACA Subcommittee meeting will be on June 10 and 11, 1997 in Durham, North Carolina. The C&O group could present an introduction of the prescribed burning and a discussion of fire's role and the wildland fire policy group's mission to the Coordination Group at their June 9 meeting. The Coordination Group would determine whether the presentation should be delivered to the Subcommittee. The policy itself could be presented at a later FACA Subcommittee meeting. Ms. Shaver will get feedback on this plan from the Coordination Group on their conference call scheduled for Friday, April 25.

The next Wildland Fire Issues Group Steering Committee meeting will be held on September 4 and 5, 1997 in Atlanta, Georgia. The following Steering Committee meeting is scheduled for October 21 and 22, 1997 in Washington, D.C. at the Department of Interior building.

IV.	MEETING SUMMARY

Overview of January WESTAR Workgroup Meeting in San Diego

Mr. Arkell summarized the January 27 - 29, 1997 workgroup meeting held in San Diego. The workgroup was divided into the following three groups: Policy Issues (PI), Science and Technology (S&T), and Communications and Outreach (C&O).

Work products from the three groups were distributed to the Steering Committee for review at their April meeting. The groups anticipate presenting their final work products to the Steering Committee in time for the Committee to submit a draft policy recommendation to the FACA Subcommittee in December, 1997.

Presentation on Forest Service Prescribed Burning Plans

Ms. Lamb provided an overview of the Forest Service prescribed burning process. She illustrated the agency's multi-tiered planning process with a flow diagram which linked plans in succession from broad, regional plans down to site-specific ones. The Interagency Fire Policy (IFP) influences the RPAs, which are the large, strategic plans. RPAs have been developed every five years from 1980 through 1995. One or two Regional Assessments are prepared for multi-state, multi-forest areas. The Regional Assessments feed into Forest Plans, which are at the programmatic or forest level. 126 Forest Plans are developed, staggered from year to year. These feed into site-specific Project Plans. Around 20,000 Project Plans are prepared annually. Finally, the Project Plans feed into the Burn Plans. The Regional Assessments, Forest Plans, and Project Plans include Environmental Impact Statements (EIS).

The budget process impacts the planning process. A little less than 60% of the budget goes into the Forest Plans.

Forest Plans establish standards, guidelines, and general goals. The specifics to reach these goals are found in the Project Plans. For example, a Forest Plan could indicate that 10,000 acres of woodpecker habitat must be generated. It does not specify how or where this should be done. The Project Plan provides the specifics on how the 10,000 acre commitment will be met. One forest could end up with five different projects ranging from prescribed burning to other activities. The Burn Plan is the actual prescription for a burn. It contains resources to light the unit, soil moisture content, equipment, SMP, and other parameters.

Air quality was not initially considered in Forest Plans, but they now comply with air quality regulations and any existing SMP.

Long time lags between the planning stages and the actual burn are possible. Projects started seven to eight years ago are just now ready to be burned.

Several years ago, the Forest Service burned 500,000 acres per year. The agency projects that 750,000 acres and 850,000 acres will be burned in 1997 and 1998, respectively. These projections are based on assessments of the Plans, how many acres are ready to be burned, and the budget. SMPs make the process more difficult. For instance, an SMP may only allow 20% of the treated acres to be burned. Other methods of estimating levels of burning include surveys and assessments of information in SMPs.

The first round of Forest Plans were begun in 1976, and they were completed in about 20 years. The second round will begin in 1997. Assuming a best case scenario of five years to develop each Forest Plan, the second round of Forest Plans will be completed in 2021. Because of the time lag, the plans that are about to go through contain a lot of old information. Many of the old Forest Plans focus on commodity production. She suggested using some of the information from State Implementation Plan (SIP) milestones that will occur before the Forest Plans are completed. For example, Regional Haze SIPs are due in June/July, 1999, and PM-fine SIPs are due in June, 2003. PM-fine Federal Reference Method (FRM) monitors will be deployed between June, 1997 and June, 2000.

Ms. Shaver asked about opportunities for public input and the approval process. Ms. Lamb explained that the RPA is put up for review. The plans containing EIS involve the public. Environmental and industry groups have participated in Regional Assessments, and the public has been involved in Forest Plans and Project Plans. Burn Plans do not generally involve the public unless the state has a SMP. Mr. Douglas added that some level of coordination among federal agencies, neighbors, air quality agencies, and the private sector occurs throughout the multi-step process. Regional Foresters approve the Forest Plans, and District Rangers approve the Project Plans.

Mr. Palzer asked how many states have an SMP. Ms. Lamb replied that the S&T group is investigating this issue.

Noting the link between the budget and the Forest Plans, Mr. Atkinson asked if Congress has ever tried to influence this process. Ms. Lamb replied that this occasionally happens on a site-specific basis. A Senator earmarks dollars for a particular forest in his or her district. This results in less money for the other forests. Ms. Lavin said the Quincy Library group is a very active group that has succeeded in receiving substantial amounts of money in the past.

Ms. Hong asked how flexible the process is. What ability does the Forest Service have to increase or decrease prescribed burning? Ms. Lamb explained that while SIPs are revised chapter by chapter, Forest Plans must be completely redone. Opening up just one part of the Forest Plan is difficult. Prescribed burning strategies can be modified at the Project Plan level.

Mr. Olmscheid asked if there has been resistance to the increases in prescribed burning at the local or state level. Mr. Douglas replied that coordination with state and local officials and other stakeholders is critical to prevent this from happening.

Mr. Dickerson said this is a capacity problem. Projecting what everyone will do is difficult. Agencies often find that they cannot burn as much as the original Forest Plan projected. An umbrella view of capacity is needed. Mr. Douglas said the IFP is currently driving the process. The IFP concluded that prescribed burning has been excluded too much. Thus, the second round of Forest Plans will increase the emphasis on prescribed burning.

Ms. Shaver asked about the best opportunities for linking the forest management process with SIP development process. Several members noted that it is not clear. Ms. Lamb said one element of SIP development is knowing current emissions. Forest Service uses huge grids, on the order of a million acres, to project emissions from the planned number of acres to be burned. Until the Burn Plans are completed, emissions cannot be pinpointed on a smaller scale. The problem with conformity is that it deals on a site-specific basis. The Forest Service has been careful not to be site-specific in the Forest Plans. The million-acre scale is needed for consistent year-to-year SIP planning.

Mr. Palzer commented that Oregon has a number of nonattainment areas. In most cases, prescribed burning is not occurring within a nonattainment area. However, prescribed burning impacts the nonattainment areas. Oregon has a strong SMP, but an emissions budget is needed for conformity.

Ms. Hong said an emissions budget for burning could be created in the SIP. Ms. Lavin said GPRA requires outcomes rather than the number of acres treated. The concept of the million-acre unit makes sense. Ms. Lamb added that the Forest Plan can be accurate for a million acres. Conformity, however, requires this plus something else, such as an emissions budget for the SMP.

Ms. Lavin explained that Forest Service is prioritizing areas closer to populated areas. Although burns are more difficult at wild-urban interfaces, they have a bigger payoff. Air quality is generally more important at wild-urban interfaces than in more remote areas.

Mr. Douglas said a scale that is reasonable for both forest management and air quality planning should be determined. The scale of projected acres needs to be reduced to give air quality managers a better idea of how to estimate emissions. DOI has smaller lands than the Forest Service. Emissions inventories should be consistent on an inter-agency basis. Ms. Shaver reported that FACA is considering Areas of Violation (AOV), Areas of Influence (AOI), and Regional Air Management Partnerships (RAMPs). AOVs and AOIs could be multi-state areas, and RAMPs will be larger. Five or six RAMPs could be established. She asked if these scales were appropriate.

Presentation on State of Florida's Prescribed Burning Plans

The Florida Division of Forestry is a strong proponent of prescribed burning. 1.5 million acres are burned annually. The private sector contributes to approximately 75% of the burning. No acreage quotas are used.

Florida's process is not as formal as the that of the Forest Service. Florida has Burn Plans but no formal SMP. The Division of Forestry issues permits with smoke management practices in mind. Burns can be conducted by calling the Division of Forestry. The burner is absolved of liability, but this has not been fully tested in court. The right to burn is a property right.

Coordination with the public is critical. The panhandle, for instance, is dotted with military bases. The Division of Forestry has developed a good working relationship with them.

Prescribed burning is not expected in increase in Florida or the Southeast in the next few years because fuels have not been allowed to build up. Ms. Lavin said the Southeast has many years of experience with prescribed burning. These states can burn inexpensively, and the fires have lower temperatures.

Florida does not have any PM nonattainment areas. Mr. Rhodes indicated that based on estimates of PM-fine fractions of PM-10 data, Florida does not expect a PM-fine problem.

Mr. Rothwell asked about realistic alternatives to burning. Mr. Peterson replied that burning is the best alternative. Any method should be cost-effective.

Mr. Rhodes said ecosystem management and air quality can be divergent but not incompatible goals. Florida has a strong desire to go back to its natural ecosystem of 200 - 300 years ago. This objective can be accomplished by mimicking natural processes, such as lightning.

Summary of Guiding Principles

Mr. Mitchell reviewed the April 8, 1997 draft of the Guiding Principles. In order to simplify the initial list, the Guiding Principles were categorized into givens and principles related to policy development, costs, air quality planning, and fire planning. Some minor word changes were made, and a few principles were merged.

Mr. Hayslip, who could not attend the Steering Committee meeting, submitted a written suggestion for an additional principle regarding fire and smoke management planning in the context of the AOI/AOV construct.

The Committee generally agreed that the re-organization of the principles is helpful.

Ms. Shaver reported that a new agricultural task force comprised of the farming community has been formed under the Farm Bill. EPA is participating on the task force. The task force may be the forum for addressing agricultural burning issues.

Mr. Dickerson observed that some principles relate to policy development and others pertain to implementation. Mr. Mitchell explained that all of the principles are guiding principles except for the givens. He suggested moving the first four principles (under policy development and costs) to the givens section.

Ms. Lamb commented that the givens are working assumptions: they are needed in order to proceed. Although the PM-fine standard or the magnitude of increased burning are not known exactly, they will become more clear as the policy development process proceeds.

Mr. Palzer commented that the re-organization of the principles helped him see the shortcomings of the initial list. He requested that the air quality planning section be enhanced. Criteria pollutants and toxics should be mentioned. Ms. Silva asked how detailed the principles should be. Each one of the principles could be expanded. Ms. Shaver said the original intent of the policy was to develop a process. She envisions about ten pages of policy that refer to Forest Plans, SIPs, etc. without providing detail. The policy could recognize that further guidance may need to be developed later. The principles should serve as a checklist which ensures that major thoughts are not omitted from the policy.

Ms. Lamb said Mr. Hayslip's suggestion should be considered, although the AOI/AOV language may not be necessary. Mr. Woodard thought the regional planning concept in principle 7 captures the idea. Ms. Shaver recalled that the Steering Committee discussed having a draft document at the end of this year. EPA anticipates the draft Phase I policy in July, 1997. The AOI/AOV concept could be captured in general terms in the wildland fire policy with a caveat indicating that the concept may change. She wanted a policy that stands alone. The air quality and forest management principles in the policy should be protected regardless of what happens with the standards.

Ms. Lamb said FACA seems to emphasize nonattainment areas and emission reductions rather than growth. Allowing for prescribed burning increases may not sit well with FACA.

Mr. Douglas said defining the baseline for pre-settlement level of burning is critical. Mr. Rothwell said emissions budgets could be established without this. Short-term increases could be allowed if long-term decreases are ensured. Mr. Palzer said restoring ecosystems to pre-settlement conditions is unrealistic. The differing land-use policies across the country should be recognized.

Mr. Douglas commented that in many cases the Clean Air Act (CAA) baselines were set artificially low because they did not include fire emissions.

Mr. Rhodes said the policy should focus on an outcome of ecosystem improvement. It is naive to think that an emissions budget for prescribed burning can be developed. The policy should not set up a process for failure. A national package is also unrealistic. Compared to many other states, Florida will probably be able to do more burning without impacting air quality. Ms. Shaver agreed that the policy could establish a process which could be tailored to meet states' needs.

Mr. Arkell asked if EPA is taking into account future prescribed burning increases in its planning. Ms. Shaver replied that EPA recognizes the possibility of accommodating prescribed burning increases. Planning periods for burns should be more closely lined up with air quality/SIP development timelines.

Ms. Hong asked if a national SMP is needed. Mr. Douglas said the sub-bullets under principle 7 offer guidance to burners. The DOI and other FLMs are participating in an effort to assess how GCVTC recommendations can be implemented on a national scale. The federal agencies are sending out the message that they are doing their part. Ms. Silva added that their draft document addresses planning, smoke management, inventories, etc. It comes closer to outcomes.

Based on the April 22 discussion, Mr. Mitchell revised the Guiding Principles and distributed the changes on the morning of April 23.

Mr. Palzer commented that the revised draft did not address his concern about the air quality planning principles. This section should be enhanced with language about criteria pollutants, toxics, etc. Ms. Shaver suggested repeating some of the air quality language in the givens section. Mr. Mitchell will revise the Guiding Principles and distribute them.

Policy Issues Group Report-Outs

Mr. Douglas distributed a draft copy of a plan to address the fire-related recommendations of the GCVTC. The table lists activities and tasks under various GCVTC recommendations. He suggested that the GCVTC response work be folded into the efforts of the PI and S&T groups. Many of the same issues are being addressed by the two processes. Merging these two efforts would ensure that messages from the federal agencies and the wildland fire policy group would be consistent.

Although the GCVTC only looked at the Colorado Plateau, this effort is addressing how the recommendations could be implemented nationally. GCVTC addressed FLM, tribes, states, and other stakeholders, and the response group is currently addressing only FLMs. Ultimately other stakeholders will be included.

The response to GCVTC recommendations was commissioned by Interior Secretary Babbitt. The aim was to get the core group of DOI and Forest Service together. Ms. Lamb added that GCVTC addressed Class I areas. It made sense for Forest Service to respond to GCVTC recommendations, because it has responsibility for Class I areas.

The timeframes listed in the table are internal estimates. The tasks in the table will be bumping up against other agency priorities.

Mr. Douglas said right now the budgets for the 1999 cycle are being prepared. Some tasks in the table will be costly. He asked the group to think about what can be done to put markers in the budgets for the next few years.

Mr. Douglas gave a status update of the PI group. The San Diego meeting had a lot of "start-up" costs. Time was spent getting everyone up to speed on the issues. The PI group developed an outline for the policy consisting of the following sections: scope and applicability, planning, implementation, ambient air monitoring, response to impacts/contingency, and follow-up evaluation.

The PI group discussed the definition of "ambient air." The issue was whether air might not be considered ambient in cases where public access was restricted. In other words, could it be argued that whatever occurs inside a restricted area does not count? Ms. Hong said legally ambient air is everywhere.

Ms. Shaver asked what the group was trying to accomplish. Some policy options which would not require tinkering with the legal definition of ambient air might be available.

Mr. Palzer said secondary standards would cover other things besides human access.

The PI group also discussed agricultural lands. Mr. Douglas said although agricultural burning will be addressed by the agricultural task force, this process still must define agricultural burning. The PI group generally defined wildland burning as non-agricultural burning. Pasture and range lands, however, are gray areas. FLMs consider these areas wild, but privately owned pastures are considered agricultural land. Ongoing coordination with the agricultural task force is needed.

Responding to questions from several members, Ms. Shaver explained why the agricultural task force was better equipped to deal with the agricultural burning issue. The wildland fire process does not have representation from the agricultural community. It is a question of how the stakeholders are organized. The hope is that the work products emerging from the agricultural task force and the wildland fire group will be similar.

Ms. Hong commented that equity is the connection between the two groups. Will the wildland fire policy be more or less prescriptive than the agricultural burning policy?

Ms. Hong thought a group had been set up to look at the different purposes for burning. Requirements may be flexible depending on the purpose for burning. Mr. Woodard replied that the PI group has not received specific recommendations from the group. The PI group's initial approach was to look at all types of fire. Ms. Shaver asked how a state regulator would balance agricultural burning, which is a commodity issue, with burning to protect human health. Mr. Peterson explained that Florida has consistent standards and policies for all types of burning.

Mr. Wells asked who makes the call for tribal lands. The majority of tribes are eager to cooperate, but a few feel that it is their land and they will burn if they desire. Ms. Shaver responded that Tribal Implementation Plans (TIPs) have to comply with a process similar to that of SIPs. She was not sure how tribes are affected by sanctions. The CAA offers mechanisms for dealing with non-cooperation. The political will to apply sanctions is another issue.

Ms. Douglas said one element of the planning process should be a good analysis of the tradeoffs. All entities should engage in the best management practices, and there will be consequences when something goes awry. Local air agencies must sign-off on Burn Plans. One hook could be that the Burn Plan is not approved.

Ms. Lamb suggested assessing the roles of the various stakeholders. An understanding of the relationships among the different entities involved in burning and consequences for failure would be helpful to develop the policy. Ms. Shaver agreed that the assessment would be helpful. EPA would like to know what happens when a Forest Plan is not carried out.

Mr. Clark said the last bullet ("The land is under fire management jurisdiction of a land management agency.") should be stricken from the definition of "wildland" in the April 3, 1997 draft because some wildlands are not under anyone's jurisdiction.

The group discussed the definitions of "wildland" and "agricultural land." The Committee generally agreed that crops and tillable lands are agricultural lands. Grasslands/pastures are more difficult to categorize. The issue of grasslands/pastures will be flagged for coordination with the agricultural task force.

Ms. Hong recalled that the issue was initially raised because, assuming higher temperature and more fuels, wild fires have greater emissions than prescribed burning. This emissions tradeoff is not evident with burning on grasslands/pastures . Ms. Douglas asserted that emissions tradeoff is not the only goal of this process.

Ms. Lamb said many states are not allowed by law to reflect emissions from agricultural lands. The wildland fire policy is addressing areas where emissions information is available and mitigation can be conducted.

Mr. Woodard said types of burning has been discussed in several contexts. The PI group has stayed away from judging some purposes as being more "pure" than others. However, he is hearing that there may be other reasons for distinguishing among purposes for burning. Perhaps the issue is not closed. Ms. Hong said some PI group members were concerned that some purposes would be exempt from complying with NAAQS.

The group discussed the situation in South Coast, California, which is a nonattainment area but has recently faced the need to burn. Ms. Shaver said this policy must attempt to meet the NAAQS. Some areas may do everything they can do and still violate the NAAQS. These situations must be addressed. A national policy cannot be crafted based on South Coast. Mr. Rhodes said the system should be kept very simple. The entire country should not be treated as the South Coast. South Coast will be constrained and will have more difficult decisions. Mr. Palzer explained that the South Coast has reduced its emissions tremendously. The area is concerned about transported pollution. South Coast would have to take extraordinary measures to address transported pollution because of its unique meteorology conditions. Mr. Douglas cautioned against establishing a short time horizon. South Coast worries about each air quality increment when the bigger problem is building. Fuels are growing every day.

Ms. Lamb said the difficulty with crafting a national policy is that the result is a common denominator type of policy. Ecosystems differ greatly across the country. She suggested that distinctions among ecosystem types be developed locally. Perhaps a placeholder is sufficient for now. Ms. Shaver suggested that the policy develop mechanisms for addressing conflicting goals.

Mr. Palzer said an emissions budget strategy could accommodate all types of areas. A national policy based on emissions budgets could be developed.

Mr. Douglas said managers should look at purposes, objectives, and tradeoffs. Good, honest planning and public participation is the way to go. If differences in requirements are created based on purposes for burning, people will start doing what is allowed.

Ms. Hong said one issue is equity across the various entities with a need for burning.

Mr. Palzer said prioritization of purposes may be needed if emissions budgets are used. A hierarchy of burning could be established. If an area is restricted from burning, protecting human life or property may be a priority. Mr. Douglas said there will always be some kind of budget constraint: money, resources, emissions, etc. Budgets must be allocated on a regional basis. The group looking at GCVTC recommendations has discussed improving planning guidelines so that people account for these things and assess all alternatives when developing plans.

Mr. Palzer explained that the FACA process is discussing differing control requirements across the AOI. One criterion for control requirements could be the contributing source's distance from the violation. Mechanical methods may be preferable at the forest- urban interface, and prescribed burning could be conducted elsewhere.

Ms. Lamb said the requirement for long-term strategies in the regional haze rules could indicate that short-term problems are o.k. if the long-term outcome is acceptable.

Ms. Hong summarized the discussion. The issue of grasslands/pastures will be coordinated with the agricultural task force. The national policy should not distinguish among types of fire, but local agencies could distinguish among purposes. Ms. Shaver added that the policy should develop the process. It should deal with conflicting timeframes, and it should address consequences for failure. The policy should be crafted such that it defines a process for allowing areas to prioritize their prescribed burning plans as needed.

Mr. Douglas wanted to flag the issue of National Weather Service scaling back its support to states. This information is critical to burners. How can the National Weather Service be reengaged in this process?

Mr. Wells asked if the PI group has considered lessening air quality restrictions for prescribed burning in the short-term (on the order of ten years), realizing that air quality will not improve in the short term. If forest health is going to improve, prescribed burning must be ramped up now. Ms. Shaver responded that the "givens" in the Guiding Principles address this. The charge of this group is to meet both goals wherever possible and to address consequences when both goals cannot be met. Many techniques for managing burns are available.

Mr. Douglas raised the issue of nuisance. Local managers must deal with calls about smoke. The outline recognizes that nuisance is not a national issue. The Committee agreed this was sufficient.

Mr. Wells said he needs a way of dealing with Senators who call him and ask about flexibility in the PM-fine standard. Ms. Shaver said violators will have to make a strong showing that they did the only thing that could be done and the best thing that could be done. Violators will need to explain the rationale for their strategy and the steps they took, and they will need to demonstrate that the policy was followed.

Mr. Douglas asked if RAMPs would take a national policy and tailor it for the region or would national policies overlay regional ones. Ms. Shaver responded that implementation will occur at the state/tribal level. RAMPs will address inter-state issues. RAMPs could be established by early 1998. They could have an active lifetime of about three years, after which they could go dormant for a time. Many members of FACA are concerned that RAMPs will become an additional layer of bureaucracy.

Science & Technology Group Report-Outs

Ms. Lamb said the SMP group of S&T has balanced representation and expertise. The group is developing the elements of a successful SMP. It has proposed a three-tiered process. Tier I would apply to all areas, and tiers II and III would successively add more rigorous requirements. The three-tiered system was based on an assessment of existing SMPs across the country. S&T has discussed developing incentives for tiers II and III. She asked if the Steering Committee wanted the SMP group to look at Best/Reasonably Available Control Measures (BACM/RACM).

Mr. Arkell asked if the SMP would be mandatory. What happens in states that are comfortable with their SMP, but their SMP does not contain all of these elements. States should have broad guidance. Principles are appropriate, but the SMP should not be mandated. Mr. Peterson added that the SMP should be flexible to accommodate programs already in place. Mr. Palzer supports flexibility, but he is concerned about voluntary programs. Voluntary programs may not be adequate. Mr. Rhodes cautioned against unfunded mandates. Unless there is a compelling reason, an SMP cannot be mandated.

Ms. Shaver agreed that states with successful SMPs should not have to change. She asked how a state would justify violating a NAAQS by increased burning if it did not opt-in to a SMP. Such states might not receive the same treatment as states in similar situations that did choose to institute a SMP.

Ms. Lamb thought S&T should not address policy issues. Mr. Douglas said S&T should not say "should," "will," etc. S&T should provide science, data, and capabilities. They should be a resource for the PI group to draw upon. The Committee agreed. The Steering Committee wants S&T to establish the levels of the SMP and the criteria for each level. Policy issues should be addressed by the Steering Committee or the PI group.

Ms. Lamb said one approach could be for the basic or tier I SMP to be the regional SMP. Local problems could be addressed with the additional measures required in tiers II and III.

Mr. Palzer said some burns will impact other states, and other burns will have immediate impacts within the same state. A regional planning process is needed.

Mr. Palzer asked how SMPs would treat burns on foggy days. Fog is associated with poor dispersion. Impacts are likely to be higher. One goal of any SMP should be to minimize impacts and account for meteorology.

Ms. Shaver observed that the terminology is inconsistent. She was not sure if there was some technical basis for mixing the terms up, particularly in the notification part.

Ms. Perkins commented that the organization of the paper is confusing. Is S&T saying that SMPs should have these seven elements, and three levels are contained within each of the seven elements? The Committee agreed that S&T should develop a matrix to display the information. The first step for the paper should be to determine if these are the correct seven elements for SMPs.

Mr. Clark said SMP should be distinguished from smoke management techniques.

The questions for the S&T group were organized into three categories: 1) ecosystem health and safety questions and issues; 2) air modeling and general air quality questions and issues; and 3) emissions data and air monitoring questions and issues.

Ms. Lamb suggested that the Steering Committee decide which questions are needed to formulate the policy and which are needed for implementation. Should any of the questions be addressed by an entity outside the S&T group?

Ms. Lavin said the National Wildfire Coordinating Group (NWCG) should answer some of the questions. NWCG addresses longer-term issues, but once they reach a standard it is accepted by everyone sitting at the table. Any "burn boss" standards should definitely be taken to the NWCG. The express group of NWCG is an ad hoc group comprised of Forest Service representatives and one Nature Conservancy representative. Mr. Palzer was concerned about a select group of FLMs addressing these issues. Although they are familiar with the issues, states should have representation.

Mr. Douglas observed that many questions overlap. Three or four core issues are evident in the list of questions. For instance, improved emissions inventories would help answer many of these questions. He suggested a strategy for answering the questions. The first step is to determine which questions need to be answered to develop the policy and which ones need to be answered to implement the policy. Then, S&T should determine who will answer the implementation or longer-term questions.

Ms. Shaver would like S&T input on whether a policy based on emissions budgets is feasible. Even if other sources are not known, the contribution of prescribed burning to PM- fine would be known. If prescribed burning contributes 30 percent to PM-fine, there could be equity issues. She asked if S&T could develop an emissions-based plan similar to a SMP. If not, what is a more scientific approach. Mr. Palzer thought question II - 3 (What is the airshed capacity for prescribed burning and how does this vary from location to location factoring in background air quality?) addressed this.

Ms. Hong said GCVTC specifically recommended an emissions budget. Industry was going to walk away from the table if they did not receive equitable treatment. Mr. Rhodes says the range of accuracy of emissions budgets troubles him. He would be comfortable with a strategy based on monitored effects. Ms. Perkins agreed but cautioned that a process based on impacts runs the risk of becoming a data collection/modeling exercise. She understands the issue about accuracy and maintaining credibility.

Several members were concerned about a lack of emission factor and monitoring data. Ms. Lamb said S&T can assess what data are available. The Science and Technical Support work group of FACA is doing some of this work.

Mr. Douglas suggested that S&T determine the issues associated with a national emissions inventory. The issues could include fuel loading, ease of data collection, frequency of updates, grid size, etc. Someone would then be responsible for collecting and maintaining the data. The data could be used for prioritizing or for other purposes.

Ms. Lamb said part of S&T role is to be realistic in terms of balance among monitoring, inventories, and modeling.

Mr. Dickerson said perhaps resources should be spent on understanding emissions from burns. Ms. Lamb said some good studies are available. S&T should gather all the studies and report on the status of their research effort.

The Committee began discussing each question to determine whether the question was a priority issue.

Ms. Lavin said question I.1 ("How much will prescribed burning increase, when will it occur, and where?") is a management decision that is inappropriate for S&T. She suggested that S&T develop criteria to be used for identifying how much prescribed burning could increase with available resources. Ms. Lamb said this question could be coordinated with the response to GCVTC's recommendations. Estimates might be sufficient in the short term, and a process for collecting data could be established for the long term. Ms. Silva said agencies can indicate how much they would like to burn, but if wildfires occur, funding is used to put them out. Mr. Palzer said the question has already been raised in FACA. Ms. Shaver added that FACA does not know much about prescribed burning. This issue could be important for communication and outreach.

Members marked on each question whether it should be a high priority/short-term issue or a lower-priority/longer-term issue.

The input from the Steering Committee members was summarized in a table which listed the number of "drop/keep" and "short-term/long-term" responses, as well as any additional comments. Ms. Lamb reported the results on the morning of April 23. She will interpret the results as meaning "keep" or "short-term" responses should be first priority issues and "drop" or "long-term" responses should be second-order priority issues. No questions will be dropped.

The Committee discussed the geographic information system referred to in question III.1. Mr. Palzer said an emission-based system is in place. The prescribed burning element could be incorporated. Mr. Rothwell said maps are the most basic information he would need as an air quality regulator. Ms. Lamb said the S&T group could brainstorm for the second priority issues. For instance, fuel maps and ozone nonattainment area maps are available.

Mr. Douglas said the two issues that are not captured are: 1) what does the regulatory community need to have? and 2) what is practical to provide?

Mr. Howard asked if PM sizes, NOx levels, and other characteristics of emissions from various types of burns are known. Ms. Lamb said a 1989 study that estimated Total Suspended Particulate (TSP), PM-10, PM-2.5, toxics, and NOx on a state-by-state basis is available. It also included some information on how emissions relates to fuel types. The study was based on a survey of land managers. She could provide this information. The Steering Committee could critique the assumptions that were used in the study. The assumptions would indicate how well emission factors are known.

Mr. Clark said the AP-42 contains wildland fire emission factors that are fairly extensive. They account for fuel type, humidity, and other parameters. Ms. Shaver would be interested in knowing if the fire community accepts the emission factors.

Ms. Lamb suggested developing a diagram or flow chart outlining the information needed for air quality analyses, including emission factors, fuel loading, acres, modeling, monitoring, background levels, etc. This would help highlight where the uncertainties are and prioritize the issues. A lot of time should not be spent assessing the AP-42 when the real uncertainty is with fuel loading. In addition to the information gaps, the real needs of the user groups could be another factor used to prioritize the issues.

One of the comments listed in the table was to focus on HAP emissions. Mr. Palzer said focusing solely on criteria pollutants would be short-sighted. Information on toxics and surrogates for measuring toxic releases from burning is available. In addition, mechanical treatment is often argued to be a costly alternative to burning, but factoring in health cost due to toxics could make mechanical treatments more cost-effective. Ms. Lamb said the 1989 study has some information on HAP emissions. Ms. Lavin commented that the question is valid, but more expertise lies outside the S&T group. Perhaps S&T should identify which questions require outside research efforts. Ms. Shaver added that HAP is covered under different authorities of the CAA. She said the Steering Committee wants to hear from S&T how the question of HAP emissions should be posed. Mr. Howard said addressing HAP emissions from burns would be difficult. Florida does not log in conditions for burns when it issues permits. Mr. Palzer said an appropriate element for SMPs could be surrogate measures for HAPs.

Mr. Douglas said S&T needs to present a plan for how to address longer-term issues and who will address them. A continuing dialog between S&T and the group addressing GCVTC recommendations is needed. Ms. Shaver added that "long-term" could mean three months or three years after the policy is developed. EPA can amend the policy.

The Committee discussed modeling and monitoring. Mr. Howard said states will not model every burn no matter what the policy is. States are doing well to maintain their existing monitoring networks. Unless someone will be monitoring independently, data are limited. Mr. Woodard said one issue is that someone could place a mobile monitor next to a prescribed burn. Mr. Rothwell said Washington has an SMP that uses models. He is concerned about their monitoring and modeling protocols being thrown out. Ms. Shaver asked what the role of monitoring and modeling are in the policy.

Communications Plan

Ms. Silva presented an overview of the Communications Plan developed by the C&O group.

Ms. Lavin suggested sending out a communication that explains the mission and composition of the wildland fire policy group. The message should emphasize that all agencies are sitting around the table working on the issue together. Ms. Silva agreed. She said the C&O group initially wanted to prepare an information kit containing all the briefing statements, but some kind of communication about this effort is needed now. Ms. Shaver suggested that once the statements are drafted, Mr. Rhodes and Ms. Perkins could coordinate this communications effort with the states, perhaps through STAPPA/ALAPCO.

Ms. Shaver said the message about the cooperative effort among federal agencies is needed as soon as possible. A draft statement will be distributed, and a conference call will be scheduled to review it.

The Committee agreed that the C&O group should review all communications statements as they are developed.

Ms. Lavin said Orlando could be an opportunity for a press release. Mr. Douglas cautioned against putting out a press release before the meeting. This could invite a bunch of people to look over their shoulders. The Committee agreed that the press release should be after the Orlando meeting. Ms. Silva will coordinate with Polly Hunter, EPA, on a press release.

Ms. Lamb said a plan for communicating among the workgroup and Steering Committee members is needed. Interim work products should be accessible to everyone. The FACA process posts works-in-progress on its website. Conference calls may be needed in between face-to-face meetings. Ms. Silva asked if the Communications group or WESTAR should be responsible for internal communications. Mr. Douglas differentiated between management information and substantive information. He felt the C&O group should help disseminate substantive information and was not sure what their role should be in distributing management information.

WESTAR and FACA have websites. Ms. Lamb said criteria for placing wildland fire policy group documents on the WESTAR and FACA sites should be developed, along with protocols for moving documents from one to the other. There may be reasons for placing a document on the WESTAR site rather than on the FACA site and vice versa. Mr. Blais said he has sent out an e-mail message explaining how to gain access to various websites, including WESTAR, FACA, STAPPA/ALAPCO, and others. He will re-transmit it to Steering Committee and work group members. Mr. Palzer suggested developing linkages among all the sites.

When examples of messages were presented, several members noted that types of wildland fire is a contentious issue. Ms. Silva explained that these are simply examples. The C&O group will hold off on this issue. C&O is uncertain if they should wait for the PI group to develop the issues or if they should start drafting briefings and statements immediately. The Committee agreed that C&O should begin working on communications immediately.

Ms. Lamb commented that draft communications messages needing scientific justification would help focus the S&T group.

Mr. Clark suggested compiling some commonly asked questions and answers for the benefit of managers.

Mr. Douglas said the issue of mechanical treatment versus prescribed burning is frequently raised. He has a two-page paper written by Mr. Clark that explains the issue in a clear way. Mr. Woodard said people often say mechanical treatment is an excuse to log. This should also be addressed.

Ms. Lavin said answering Congress's inquiries is a significant part of the communications piece. Forest Service, DOI, and NASF people who run that line for them are on the C&O group.

Mr. Douglas noted that the environmental community has interest in both sides of the issue: air quality and forest health. How can communication with the environmental community be increased? Mr. Palzer suggested the grassroots Clean Air Network for disseminating information about air quality. He is on the steering committee and is willing to serve as a liaison.

Mr. Wells requested that tribes be included in the list of target audiences. He can serve as a communications link to the Native Fish and Wildlife Council, the Indian Agricultural Council, and the Indian Tribal Timber Council. Mr. Palzer suggested communicating with tribal air quality officials also. The Western Governors' Association Air Initiative Committee has good tribal representation.

Mr. Douglas commented that all of the opportunities for public involvement in the forest management planning process outlined in Ms. Lamb's presentation could serve as opportunities for communication and outreach. Ms. Lavin agreed and suggested developing three or four talking points for elected officials.

Mr. Rothwell suggested posting informational notices prior to prescribed burnings at the sites themselves.

Ms. Silva emphasized that inviting co-chairs of work groups to Steering Committee would be an important means of internal communication. Mr. Palzer was concerned that the Steering Committee meetings would have too many participants to run efficiently. Ms. Perkins said maintaining an active communications link between the Steering Committee and the workgroups is critical.

Ms. Silva clarified that "funding for staff work and per diem" referred to allocating resources for a contractor to put together the information packet and other work products. Ms. Shaver said EPA will provide support for the packet, questions and answers, and other products.

Mr. Douglas said work will need to continue past the end date of this process. Who will have responsibility for ongoing activities? Memoranda of Understanding (MOUs) are one approach. Ms. Shaver liked the idea of MOUs. The message from all federal agencies should be consistent.

Ms. Lamb suggested developing a schedule of important dates between now and the end of the project. For instance, the promulgation of the standards and regional haze rules could be dates where lots of questions will be asked. Communications could be prepared for each of the key dates.

The group discussed the scope of the press releases. Ms. Shaver said the communications should focus on the Steering Committee instead of FACA in order to prevent sending mixed messages about the two efforts. The two groups have different missions and compositions.

Ms. Shaver said the Steering Committee should think about how to update FACA and bring them along in the process. The next opportunity will be the June 10 and 11, 1997 FACA Subcommittee meeting in Durham, North Carolina. The C&O group could present an introduction of the prescribed burning and a discussion of fire's role and the wildland fire policy group's mission to the Coordination Group at their June 9 meeting. The Coordination Group would determine whether the presentation should be delivered to the Subcommittee. The policy itself could be presented at a later FACA Subcommittee meeting. She will get feedback on this plan from the Coordination Group on their conference call scheduled for Friday, April 25.

Ms. Lamb said area source emissions are addressed in several papers. This effort could feed into the development of those issues. She noted that the FACA Subcommittee has not seen a lot of presentations from the perspective of a single source sector.

Ms. Perkins suggested having a diagram illustrating the forest management process. It would be helpful to know where the SIP and forest management processes link. This would help to identify the gaps between air quality management and forest management. Mr. Woodard agreed and suggested adding more detail on the environmental impacts. Ms. Shaver thought this presentation would also be useful at the fall STAPPA/ALAPCO meeting.

Mr. Douglas distributed an issue paper on appropriations hearings, the DOI response to Senator Alard's letter, and a two-page overview of mechanical treatment as an alternative to prescribed burning written by Bob Clark.