Annual Emissions Goal 

For Fire 

As required by 40 CFR 51.309(d)(6)(v), an annual emissions goal will be established 

yearly to minimize emission increases from fire, excluding emissions from wildfire. This 

requirement is a result of federal and state land managers’ projection of “significant 

increases in prescribed fire in order to reduce the effects of wildfire resulting from past 

decades of fire suppression.”1

 The emissions goal will be determined by quantifying the 

emission reductions obtained through the use of emission reduction techniques (ERT) on 

a project specific basis. The emission goal will be established for the upcoming fire 

projects prior to the beginning of the fire season, either at the beginning of the calendar 

year or before the year begins. In addition, the emission goal will be established in 

cooperation with states, federal land management agencies, and private entities. 

Prescribed Fire

To establish the Annual Emissions Goal, the State of Utah will follow the following 

process. Firstly, the UDAQ will organize an annual meeting with Land Managers and 

will work collaboratively with the Land Managers to establish the goal. A review of the 

upcoming prescribed fire projects that is listed on the Annual Burn Schedule, a 

requirement of state administrative rule R307-204, will be made to determine appropriate 

ERT for each fire project using the feasibility criteria listed below. Once appropriate 

ERT are determined, then the benefit from using the techniques will be quantified. An 

assessment will be made of the ERT applied per project during the previous fire season to 

verify application and to improve the information base. 

The Annual Emissions Goal is based on the use of ERT to minimize emissions from 

prescribed fire. An ERT is a technique for controlling emissions from prescribed fires to 

minimize the amount of emissions produced per acre or unit burned. Research has shown 

that fire emissions can be minimized through the use of ERT that increase combustion 

efficiency and reduce the smoldering stage of burning. There are six general categories 

of ERT: reduce the area burned, reduce fuel load, reduce fuel production, reduce fuel 

consumed, schedule burning before new fuels appear, and increase combustion 

efficiency. Information on available ERT will be gathered from the National Wildfire 

Coordination Group’s (NWCG) Smoke Management Guide for Prescribed and Wildland 

Fire2

, Environmental Protection Agency’s (EPA) Prescribed Burning Background 

 

1

 Grand Canyon Visibility Transport Commission ‘s Recommendations for Improving Western Vistas, June, 

1996, page 23. 

2

 NWCG’s Smoke Management Guide For Prescribed and Wildland Fire, 2001 Edition. 
Document and Technical Information Document for Prescribed Burning Best Available 

Control Measures3

, policy documents issued by WRAP, and related field experience. 

The benefit from using the technique(s) will be quantified either by quantifying the 

emissions averted through the use of ERT using available emission factors or quantifying 

the percent of total acres on which ERT are applied for all projected fire projects. The 

quantification of the emission reductions achieved through the use of the ERT constitutes 

the emissions goal. 

During the annual meeting, an assessment will be made of the techniques applied during 

the previous fire season to verify application. Information on the types of ERT applied 

for each implemented prescribed fire project will be gathered from the Daily Emissions 

Report, a requirement of state administrative rule R307-204, to complete the assessment. 

Feasibility Criteria

The following feasibility criteria will be used to evaluate ERT for potential use: 

economic, safety, technical, environmental, and land management objectives. Examples 

of how to apply the feasibility criteria are listed below. 

Economic: What are the economic costs of applying a certain ERT? Is a specific ERT 

more economical than others? Any ERT that significantly reduces crop yields or exceeds 

the cost of a crop is not likely to be accepted by farmers or growers. The same concern is 

relevant to the application of ERT on wildlands. 

Safety: Are certain ERT not feasible due to public and firefighter safety concerns? Are 

certain ERT not feasible due to concerns related to containment of the fire, i.e. keeping 

the fire within certain boundaries? Do certain ERT minimize the possibility of nuisance 

and hazard smoke? 

Technical: Are the equipment and resources available to utilize a specific ERT? Are 

sufficient training programs available in the use of ERT for the Land Managers? 

Environmental: Are there specific air quality and non-air quality environmental 

limitations (e.g., vegetation/crop type, fire type, time of year, area in WRAP region, soil 

compaction, water quality, etc.) that influence the use of certain ERT? 

Land Management Objectives: Is a certain ERT not feasible due to conflicts with land 

management objectives? Do certain ERT maximize the likelihood of achieving the land 

management objective of the burn? 

 

3

 EPA’s Prescribed Burning Background Document and Technical Information Document for Prescribed 

Burning Best Available Control Measures, September 1992. 
Agricultural Burning

According to 40 CFR 51.309(d)(6)(v), an annual emissions goal will be established 

yearly to minimize emission increases from fire. Since the term “fire” includes 

agricultural burning, the UDAQ worked collaboratively with the Utah Farm Bureau 

Federation and Utah State University Extension to determine whether emissions from 

agricultural burning are indeed increasing. Results from a survey conducted in 2003 by 

the Utah State University Extension4

 demonstrated that agricultural burning has 

decreased by 48% from 1996 to 2002. Therefore, an annual emission goal is not needed 

at this time for agricultural burning. In the future, if emissions tracking activities show 

an increase in agricultural burning emissions, then UDAQ will evaluate whether an 

Annual Emissions Goal is needed. 

 

4 Agricultural Burning in Utah and the Regional Haze Rule, Utah State University Extension, in 

collaboration with the Utah Farm Bureau Federation. Logan, Utah. July, 2003.