Smoke Management Updates

• Air Quality Regulations Refresher– National Ambient Air Quality Standards (NAAQS)

• Non-Attainment Areas– Visibility Protection

• Class I areas– Nuisance Smoke

Federal Clean Air Act-Section 118:Federal Compliance

(in other words: yes the States can tell us what to do)

• Federal agencies must comply with all substantive and procedural federal, state and local air pollution standards and regulations.

• Compliance will be to the same degree and in the same manner as any non-governmental agency.

• Federal agencies must obtain permits and pay fees if required of other burners.

National Ambient Air Quality Standards (NAAQS) are established by EPA to protect human health.

National Ambient Air Quality Standards1

µg/m3= micrograms per cubic meterppm=parts per million

Pollutant Concentration Averaging Time

Particulate Matter (PM2.5)215 µg/m3 Annual Average

35 µg/m3 24-hr

Particulate Matter (PM10) 150 µg/m3 24-hr

Carbon Monoxide (CO)9 ppm 8-hr

35 ppm 1-hr

Ozone20.075 ppm 8-hr

0.12 ppm 1-hr1NAAQS are also set for sulfur dioxide, nitrogen dioxide, and lead but are not shown here since their significance to prescribed burning is negligible. 2The ozone and PM2.5 standards are under review. The NAAQS standards for these 2 pollutants may change soon.

Too many NAAQS exceedanceslead to “Non-Attainment Area”

• Pollutant sources in non-attainment areas are closely regulated.

• Is Federal Land in a non-attainment area in OR or WA?

Klamath, OR PM2.5 Non Attainment Area (red)Includes BLM lands (no FS)

Oakridge, OR PM2.5 Non-Attainment Area (yellow) Includes FS Lands

EPA FinalState Proposed

Tacoma, WA PM2.5 Non Attainment AreaNo Federal lands

Possible New Non-Attainment Areas if PM2.5 Standards are Lowered

Implications of Non-Attainment• Currently, Federal land in Non-attainment areas

(NAAs) in OR and WA is fairly minimal.• PM2.5 and ozone NAAQS are

to be updated and likely lowered in the next year which could mean more NAAs in the future.

• Emission sources within NAAs require extra “conformity analysis”.

• We may be able to avoid conformity analysis.

Possible Ways to Avoid Conformity Analysis

1. Burning under an EPA-approved state smoke management plan. (OR and WA are not formally EPA approved at this time ).

2. Quantify emissions from future burning in NAAs during ongoing planning efforts (eg. Forest Plans). Additional “conformity analysis” likely not needed.

3. Commit to using Basic Smoke Management Techniques (BSMPs) on every burn. (proposed)

Nationally Required Basic Smoke Management Techniques (draft)

1. Meteorological Scheduling and Smoke Impact Evaluation of Burning in Burn Planning and Burn Operations

2. Monitor the Effects of the Fire on Air Quality and Document Smoke Dispersion

3. Track Fire Activity on a Daily Basis4. Document the Event and Retain Relevant Records for 3.5 Years5. Share the Airshed / Air Basin6. Public Notification7. Exposure Reduction8. Use Emission Reduction Techniques9. Comply with State and Tribal Smoke Management Guidelines

and/or Programs.

Visibility Protection

• Visibility in Class I areas is protected“Congress hereby declares as a national goal

the prevention of any future, and the remedying of any existing, impairment of visibility in mandatory

class I Federal areas which impairment results from manmade air pollution.”

11 USFS Class I areas in Oregon(Crater Lake NP is also Class I)

5 FS Class I Areas in Washington(Mt. Rainier, Olympic, and N. Cascades NPs are also Class 1)

Visibility and Smoke• Currently, in OR and WA visibility is protected by

limiting burning when visitors may be in Class I areas– OR: Burning restricted July 1-September 15– WA: Burning restricted Friday-Sunday from

June 15-October 1• This could change as states seek ways to reach

ambitious visibility goals.

To Improve Visibility:Cause of Impairment on 20% Worst Days in Each Class I Area

Will Be Identified and Targeted for Clean Up

Plans for Improving Visibility and Determining the Haze Contribution from Prescribed Fires in Oregon

• An evaluation of smoke from prescribed burns is due in 2013.

• The evaluation will include identifying days with a “fire fingerprint” and review of data within a 100 mile radius to determine if there were fires that would cause it.

• Prescribed fire could be a contributing factor to the 20 worst days.

Nuisance Smoke• Smoke may cause

problems without violating air quality standards.• May interfere with

public’s activities.• Many burn programs are

more severely restricted by these impacts than from air quality regulations.

What is Nuisance Smoke?• “The amount of smoke in the ambient air that

interferes with a right or privilege common to members of the public, including the use or enjoyment of public or private resources (US EPA 1990)”.

• Not defined by NAAQS – no specificvalue or metric.

• NOV’s issued in Washington (Cub Creek ‘03, Kaboom ’09) were due to nuisance smoke.

Yakima Sept. 9, 2009

2010 Oregon IntrusionsHow are we doing?

• 3/20/2010 : CFPA 3 hour light intrusion into Cottage Grove and Springfield. • 6/15/2010 : CFPA had a 3 hour light intrusion into Roseburg. One complaint was received. • 6/18/2010: Intrusion into Grants Pass and Medford is still under investigation. Grants Pass

received 8 hours light smoke and 1 hour moderate. Medford received two hours light smoke. No complaints were received.

• 9/28/2010 : Residual smoke from a Deschutes National Forest burn drifted into Bend overnight. Bend received 1 hour moderate and 5 hours light smoke.

• 9/30/2010 : Fremont National Forest burn sent 3 hours moderate and 7 hours light smoke into Lakeview.

• 11/3/2010 : Private landowner put 3 hours heavy, 15 hours moderate and 5 hours of light smoke into Enterprise.

• 9/30-10/2 2010 : Umatilla National Forest sent smoke into three communities over several days. LaGrande received 5 hours moderate smoke and 12 hours light smoke. Cove received 5 hours moderate smoke and 17 hours light, while Enterprise received 20 hours of light smoke.

• 12/16/2010 – A Western Lane burn sent smoke into Veneta. The intrusion is still under investigation.

Smoke Summary 2011• Know the requirements

– NAAQS– Visibility Protection– Nuisance Smoke

• Follow the rules– Smoke management plan

• Get trained– RX410 Smoke Management Techniques– Univ. of Idaho/NWCG online training at:

http://www.cnr.uidaho.edu/smoc/• Stay up-to-date

– Air Quality and Fire Issues Forum at My Fire Communityhttp://www.myfirecommunity.net/Neighborhood.aspx?ID=279