# Appendix 10.4

Kansas Prescribed Fire EmissionsAppendix 10.4 Kansas Prescribed Fire Emissions

Kansas Agricultural and Prescribed Burning

Kansas is a largely agricultural state, with approx imately 47.2 million acres of land in farm production. The predominant crops grown in Ka nsas include winter wheat, corn, sorghum, soybeans, and hay. In 2009, cattle and ca lves totaled 6.3 million head; hogs totaled 1.74 million head in 2008. As the leading producer of wheat and third largest producer of beef cattle, Kansas is one of the most productive agricultural States in the United States. Total agricultural production value for livestock and products for the State
was estimated to be $7.21 billion for 2009 1 . As part of the State’s agricultural operations, approximately 5 million acres of land are burned ea ch year.

An emissions inventory for prescribed and agricultu ral burning activities in the CENRAP states for 2002 was prepared by Sonoma Technology, Inc. 2 The following tables and charts summarize the annual emissions from burning.

Table A10.4.1 2002 Kansas Nonpoint Fire Emissions, by Type of Burn and Pollutant

Burn Type Acres

Burned PM 10 PM 2.5 CO NO

x SO 2 NH 3 VOC

2002 tons

Rangeland 3,625,270 75,943 52,901 652,250 23,185 10,160 7,487 43,483

Cropland 1,390,520 23,227 22,156 153,313 5,909 777 3,950 11,401

Prescribed 38,106 1,450 1,226 14,424 228 114 143 881

Totals 5,053,896 100,620 76,283 819,987 29,322 11,052 11,579 55,765

Table A10.4.2 2002 Kansas Crop Residue Burning Emis sions, by Crop and

Pollutant

Crop residue
type Acres

Burned PM 10 PM 2.5 CO NO

x SO 2 NH 3 VOC

2002 tons

Wheat 1,058,014 17,420 16,610 118,902 4,523 603 3,216 8,194

Hay/Alfalfa 189,085 2,252 2,148 12,701 408 54 290 1,143

Corn 126,956 3,039 2,906 18,902 880 107 373 1,760

Soybeans 9,996 210 200 1,252 34 5 24 154

Other 6,469 306 292 1,557 65 9 46 150Figure A10.4.1 2002 Acreage Burned in Kansas

38,106 1,390,520

3,625,270

0 500,000 1,000,000 1,500,000 2,000,000 2,500,000 3,000,000 3,500,000 4,000,000

Prescribed Burning Rangeland Burning Cropland Burnin gAcres

Figure A10.4.2 2002 Cropland Burning in Kansas

1,058,014

189,085

9,996 6,469 126,956

0 200,000 400,000 600,000 800,000 1,000,000 1,200,000

Wheat Hay/Alfalfa Corn Soybeans OtherAcresFigure A10.4.3 2002 Emissions from Fires in Kansas

0 100,000 200,000 300,000 400,000 500,000 600,000 700,000 800,000 900,000

PM10 PM2.5 CO Nox SO2 NH3 VOCEmissions (tons/yr)

Flint Hills Rangeland Burning The impacts from agriculture burning are especially a concern in the Flint Hills region of Kansas. The approximately 4.1 million acre Flint H ills region is a band of typically flattopped hills in eastern Kansas that extend from Mar shall County in the northernmost part to Chautauqua County in the southernmost part of th e state. The Flint Hills region contains some of the last remaining tall grass prai rie in the world. Soils in the Flint Hills are rich but thin on alternating layers of limeston e and shale, and have essentially remained unplowed. The dominant grass species foun d in this region include big bluestem (

Andropogon gerardii ), switchgrass ( Panicum virgatum ), and Indian grass ( Sorghastrum nutans ) 3 . Other species that are not endemic to Kansas but that have become naturalized include Kentucky bluegrass ( Poa pratensis ) and Japanese brome ( Bromus japonicus ).

Historically, the grasslands of central North Ameri ca experienced fire, drought, and heavy grazing by bison and other ungulates. Fires were initiated by lightning and by Native inhabitants, which influenced the developmen t of fire-tolerant grasses and suppressed woody vegetation. Today, ranchers in Ka nsas continue to use fires to manage rangelands, and research conducted by Kansas State University supports these practices. The burning cycle mirrors natural burns that mainta ined the quality of the grasslands historically. Fire serves to control undesirable i nvasive species, and improves the quality of forage for cattle production 4

.

Wheat Stubble Burning Wheat farmers have traditionally burned stubble fie lds before fall planting in order to remove residue for easier planting, while at the sa me time providing control of some disease organisms and weed species 5

.

The following map, Figure A10.4.4, shows how emissi ons of particulate matter, thepredominant haze-related pollutant from fires, vary in relation to geography, particularly the Flint Hills region. Note that the source of thi s data is EPA’s National Emissions Inventory, which does not track fine particulates ( PM 2.5 ), but rather PM 10 . As Figure A10.4.3 above shows, however, the majority of grass fire particulate emissions are PM 2.5

.

Figure A10.4.4 PM 10 Emissions from Rangeland and Wheat Stubble Burning in

Kansas, by County (2002 National Emissions Inventor y)

Prescribed Burning As interpreted by EPA for emissions inventory purpo ses, prescribed burning means setting fire to vegetation in order to prevent the buildup of fuel that, if left unburned, could lead to dangerous wildfires. Considering the frequency of rangeland burning (three out of every five years is average), prescribed bur ning is not a major source of emissions in Kansas. As indicated in Table A10.4.1 above, pr escribed burning accounts for only

0.8% of the total acres burned.Discussion of Data

According to the STI baseline inventory estimates, a total of 5,053,896 acres were burned in the State of Kansas in 2002. The largest percen tage of acres burned (71.7%) was rangeland. Cropland burning is the second largest percentage of burning in Kansas (27.5%), and is primarily attributed to residue bur ning of wheat stubble, with burning of alfalfa, corn, and soybean residue making up the ba lance. Prescribed burning accounts for the smallest percentage of total acres burned ( 0.8%). Heavy rangeland burning occurs primarily in eastern Kansas in the Flint Hills regi on, where as much as 80% of the total acreage of rangeland is burned in several counties. Western Kansas accounts for a much smaller percentage of rangeland burning. Crop resi due burning in continuous wheat is primarily an issue in central Kansas.

Future Emissions from Agricultural Burning

According to Walt Fick, Associate Professor in the Department of Agronomy at Kansas State University, the emissions from rangeland burn ing in the State of Kansas will likely

remain constant in the future. 6 Significant land use changes are not expected to reduce the acreage currently used for cattle grazing and t he beef cattle industry is not expected to

decline in Kansas.

Regulation of Agricultural Open Burning

Agricultural open burning in Kansas is regulated by Kansas Air Regulation (K.A.R.) 28- 19-648, which exempts open burning for agricultural purposes from other open burning regulations so long as certain conditions are met. Such conditions include contacting local fire officials if required by the local gover ning body, contacting local traffic control and airport authorities if conditions exists that w ould create safety hazards, and supervising the fire until it is extinguished. The regulation allows for local jurisdictions to adopt more restrictive ordinances governing agri cultural burning.

The Kansas State Fire Marshall’s office keeps a dat abase of fire incidents as reported by local fire departments. However, prescribed burns in Kansas may or may not be reported to the local fire departments, depending on the spe cific regulations within each township.

Historical Impacts of Agricultural Burning

While agricultural burning is beneficial to farming and ranching operations, it also has negative impacts that must be addressed. Agricultu ral burning can present safety hazards, contribute to ozone and particulate matter pollution in downwind areas, and impair visibility in Class I areas.

Public safety has been the largest concern of lando wners and public officials. This has been particularly true for smoke causing visibility impairment on highways and near airports. Outreach efforts by the Kansas State Uni versity Cooperative Extension emphasize proper burn practices that minimize fire danger. These practices include burning when wind speeds, cloud cover, relative hum idity, and temperature are at desirable levels. Landowners are also encouraged t o notify neighbors and local fire departments before they burn.Monitoring evaluations have confirmed that rangelan d burning increases the level of air

pollutants in Kansas, but the levels rarely exceed the federal air quality standards. One such exceedance occurred in April 2003. On April 1 2 and 13, 2003, three monitors in the Kansas City ozone monitoring network recorded readi ngs in excess of the federal 8-hour ozone standard. The Kansas Department of Health an d Environment (KDHE) also received numerous complaints from other cities and states as far away as Tennessee about high ozone and particulate matter readings at tributed to the burning in Kansas during this time.

After receiving the complaints, KDHE contacted Kans as State University (KSU) range management researchers and learned that due to seve re drought conditions persistent in that region, a burn ban had been placed by the Kans as Fire Marshal’s office. Just prior to April 10, 2003, a small yet sufficient amount of pr ecipitation was received that allowed the local fire officials to temporarily lift the bu rn ban. This resulted in many fires occurring on April 10, 11, and 12. This compressed time schedule for burning, coupled with weather conditions that kept smoke and air pol lutants from dispersing, caused large amounts of air pollutants to be trapped in the lowe r layers of the atmosphere and transported downwind across the Kansas City metro a rea and eastward into the Tennessee Valley. Together, these factors resulted in Kansas City monitors exceeding the ozone standard and high readings of particulate matter in monitors across eastern Kansas and neighboring states. While the 2003 event was excep tional, burning in the Flint Hills continues to pose a concern to downwind areas.

During the spring of 2006, KDHE conducted a special monitoring project in which monitors were placed in the towns of Admire and Dwi ght, Kansas to measure particulate matter and to collect samples for carbon analyses. During the seven week study, the monitors did not measure levels of particulate matt er that exceeded the federal 24-hour average of 150 μg/m 3 . However, there were four recorded short-term spi kes in the hourly data during high burn days, with particulate matter levels reaching over 850 μg/m 3 during one of the recorded episodes. The carbon analyses resulted in high organic carbon to elemental carbon ratios, which indicated that the m ajority of carbon sampled originated from vegetation fires 7

.

Visibility Impacts at Class I Areas

The impact of planned burning to visibility at Clas s I areas was evaluated by Sonoma Technology, Inc. during the development of both the planned burning emissions inventory and the causes of haze assessment for the CENRAP region. To view these documents in their entirety visit http://www.kdheks.gov/bar/index.html

The July 30, 2004 study conducted as part of the pl anned burning inventory analyzed ambient speciated PM 2.5 data from the IMPROVE network at two Class I areas (Caney Creek and Upper Buffalo Wilderness Areas) to determ ine which chemical compositions characterize prescribed burning activity. The stud y found that levels of elemental carbon and non-soil potassium were elevated on days during or after agricultural burning in the area. However, the contribution of elemental carbo n, the primary marker of smoke, is asmall part of the PM 2.5 mass. While elemental carbon has relatively high extinction

efficiency, the mass concentrations are small and d o not contribute significantly to light extinction. Ammonium sulfate is typically the larg est contributor to light extinction and does not tend to originate from burns. 2

Figure A10.4.5 Species Contributing to Light Extinc tion at Hercules-Glades

Wilderness Area

Figure A10.4.6 Back Trajectory Map for Hercules-Gla des for April 12, 2003

As part of the causes of haze assessment completed August 31, 2005, STI assessed the aerosol components that contribute to poor visibili ty in the CENRAP region. The study found that fires infrequently contribute to visibil ity impairment observed on the 20% worst days. The receptor modeling tool Positive Ma trix Factorization (PMF) was used to KS fires – April 12, 2003establish factors to characterize ambient data. Th ese factors were inferred to represent

specific source types. Data analyzed at Hercules-G lades on two days when the biomass burning factor was highest (April 12, 2003 and May 9, 2003) showed the factor only accounted for 7% of the median mass, and 6% of the mass on the worst visibility days. The study concluded that the biomass burning factor was substantially less important to visibility than coal burning and other factors. 8

Outreach and Mitigation Efforts

In the fall of 2003, KDHE staff presented informati on regarding the effects of the Flint Hills burning on ozone levels to agricultural repre sentatives at a conference at Kansas State University. KSU range management researchers , KSU Research and Extension, the Kansas Department of Agriculture, the Kansas Livest ock Association, and other agricultural representatives were all present at th e meeting. With the help of the organizations present, KDHE launched a public outre ach campaign to address impacts from fires. KDHE provided information prior to the burn season to local fire departments, the Kansas Livestock Association, and the Kansas Farm Bureau. In addition, the KSU Media Department sent out news re leases. Following the outreach efforts in 2004, KDHE and EPA Region 7 have continu ed to meet with the parties

mentioned above on an annual basis to address burni ng impacts.

Research and Model Development

The National Weather Service (NWS) office issues a rangeland fire danger index for six regions across the State of Kansas and is updated a utomatically as weather conditions change. The danger index ranges from low, moderate , high, very high, to extreme and is determined by temperature, humidity, and wind speed . In addition to the fire danger index, NWS provides a fire weather planning forecas t and fuel moisture data, and an experimental weather activity planner to assist lan downers in planning burns.

EPA Region 7 is working on a customized version of the BlueSky RAINS model for the State of Kansas. Blue Sky RAINS is a web-based inf ormation system to help manage prescribed and agricultural burning. The model mer ges the technology of BlueSky, developed by the U.S. Department of Agriculture, an d the Rapid Access Information System (RAINS) developed by EPA Region 10. BlueSky estimates the cumulative impacts of smoke from prescribed, wildland, and agr icultural burning. RAINS uses geographical information system (GIS) technology to provide an internet mapping service. The combination of these two applications provides land managers with the ability to analyze potential smoke impacts from reg ional burning activities. County

extension officials in two counties used the model on a trial basis during the burning season of 2006. Efforts to expand the use of the m odel to other counties in the state are underway for 2007.

Kansas State University is performing a study to sp atially and temporally map seasonal burning of the Flint Hills. The study is being spo nsored by EPA Region 6 and will be led by Douglas Goodwin, a professor in the KSU Geograph y Department. Maps of the Flint Hills annual burning for 2001-2006 will be prepared using remote sensing data from the Moderate Resolution Imaging Spectroradiometer (MODI S) instrument. MODIS data was selected as appropriate for this study because of t he large coverage, high temporalfrequency, and low cost. MODIS data will be obtain ed, free of charge, from NASA for

each of days of the burning season (March–June) for the project years 2001-2006. Remote sensing and GIS analyses will be used to pro duce weekly maps and composite maps of burned areas for each of the years. The st udy will also provide tabulated values of total acreage burned, and the dates of burning. This study will be useful for smoke management efforts in the future because it will ai d the development of improved emissions inventory from Flint Hills burning.

Smoke Management Initiative

The Kansas Department of Health and Environment (KD HE) is developing the Kansas Smoke Management Initiative, a comprehensive plan t o address the negative impacts of open burning in the state. The Kansas Smoke Manage ment Initiative is an effort to coordinate with a variety of partners to address al l types of open burning in the state including rangeland, cropland, residential, and com mercial/industrial burning. The goals of the Smoke Management Initiative are outlined bel ow.

While the Kansas Department of Health and Environme nt recognizes the importance of fire as a range management tool, our goal is for la ndowners to manage burning in a way that reduces the impacts of smoke. KDHE is working towards developing a better understanding of the impact of rangeland burning on air quality by improving the emissions inventory, and performing ambient air mon itoring in the vicinity of heavy burning activity. KDHE is partnering with the Cent er for Disease Control to study the health impacts of burning. KDHE will also coordina te with the agricultural community to develop best management practices (BMPs) to redu ce the smoke impacts and support an expanded time window for burning. The Departmen t will also support the development of tools that ranchers and local offici als can use to determine proper burning conditions. Finally, the department is reviewing t he possibility of changing the State’s regulations to require local governments to address burning in their local ordinances.

The state will also address crop residue burning an d will work with the agricultural community to set a goal to reduce the acreage of cr oplands burned each year and to develop outreach materials outlining possible incen tives not to burn, and alternatives to burning.

In addition to addressing agricultural burning in t he State, KDHE has set a goal to eventually eliminate all residential burning of hou sehold trash and yard wastes in the state. The short-term objective will focus on the elimination of open burning of household wastes within municipalities. Outreach m aterials will be developed and distributed through local agencies to educate the p ublic on the health impacts of residential trash burning.

A mid-term objective will focus on the elimination of the burning of yard waste in municipalities. This will entail developing and pr omoting incentives and alternatives to burning such as mulching, composting, and establish ing drop-off centers. Finally, a longterm objective will focus on the elimination of hou sehold trash and yard waste burning in

rural areas.Each of these efforts to reduce residential burning will require coordination with the

Bureau of Waste Management (BWM). The BWM is respo nsible for approving solid waste management plans which are submitted every 5 years. These plans could incorporate provisions to develop the infrastructur e needed to provide the services or alternatives necessary to reduce open burning.

Lastly, the Initiative will address the issue of co mmercial and industrial open burning which is prohibited in the State of Kansas. Commer cial and industrial open burning persists in some cases because it is an inexpensive and convenient means of disposal. The existing regulations are adequate to regulate b urning. However, more effort is

needed to educate business owners and to enforce th e current regulations.

Addressing smoke management in Kansas will be an on going effort that will require the support of many groups including the agricultural c ommunity, local fire and police officials, and local government officials. KDHE wi ll pursue a Memorandum of Understanding with these groups by March of 2008. These partnerships will help guide the process and ensure that the resulting Smoke Man agement Initiative meets the needs of the communities impacted by burning. The Initia tive will not only provide benefits of improved health and air quality in Kansas communiti es, it will support the regional efforts to reduce visibility impairment in Class I areas.References

1. U.S. Department of Agriculture National Agricultura l Statistics Service. Kansas

Farm Facts 2009 . Kansas Field Office. 2009.

2. Sonoma Technology, Inc. Research and Development of Planned Burning Emission Inventories for the Central States Regiona l Air Planning Association

. July 30, 2004.

3. Ricketts, T., Dinerstein, E., and Olson, D. Terrestrial Ecoregions of North

America: A Conservation Assessment . Washington DC: Island Press. 1999.

4. Owensby, C. et al. 50 Years of Range Research Revisited . Kansas State University Cooperative Extension Service. 1995.

5. Kansas State University Extension Agronomy. Agronomy e-Update No. 40 . July 12, 2006. http://www.agronomy.kstate.edu/DesktopModules/ViewDocument.aspx?Document ID=1538

6. Fick, Walt. Associate Professor, Department of Agr onomy, Kansas State University. Personal Communication. March 15, 2007

. 7. Kansas Department of Health and Environment Bureau of Air and Radiation. Ambient Air Monitoring Project: Prairie Burning in the Flint Hills, Kansas

. 2007.

8. Sonoma Technology, Inc. Analyses of the Causes of Haze for the Central Stat es (Phase II) . August 31, 2005.