Western Regional Air Partnership Policy 

on 

Enhanced Smoke Management Programs 

 for Visibility 

Approved by the Western Regional Air Partnership 

November 12, 2002 

 

Prepared by: 

the Enhanced Smoke Management Program Task Team 

of the Fire Emissions Joint Forum 
i 

WRAP Policy on 

Enhanced Smoke Management Programs 

for Visibility 

Executive Summary 

The Western Regional Air Partnership (WRAP) is charged with developing technical and 

policy tools to assist states (or the delegated regulatory authority) and tribes with 

implementing the Regional Haze Rule (Rule). 

The WRAP Policy on Enhanced Smoke Management Programs for Visibility (WRAP 

ESMP Policy) has been developed over an eleven-month period through a stakeholderbased consensus process to assist the WRAP region states and tribes in addressing 

emissions from fire sources. In this Policy, the WRAP seeks to provide a consistent 

framework that states and tribes can use to efficiently develop their individual 

implementation plans. The WRAP recognizes states’ and tribes’ authority and 

responsibility to develop, adopt and implement their regional haze implementation plans, 

and recognizes the Rule as the principal document on which states and tribes should rely. 

The Rule requires states to develop implementation plans 

(SIPs) for addressing regional haze in the Nation’s 156 

mandatory Class I areas.1

 Additionally, the Rule requires effective 

management of fire sources. The Rule provides two pathways for western states to follow 

as they implement the requirements of the Rule: 1) develop their regional haze 

implementation plans per the nationally applicable provisions of Section 308, or 2) 

Transport Region states may choose to incorporate the Grand Canyon Visibility 

Transport Commission (GCVTC) recommendations into their regional haze 

implementation plans under Section 309 of the Rule. 

Enhanced smoke management programs are specifically required in Section 309 of the 

Rule. However, if a state, under Section 308, has determined that fire emissions are 

contributing to visibility impairment and that smoke needs to be addressed in its SIP, then 

an enhanced smoke management program is a viable tool to accomplish this goal. 

Therefore, the WRAP is advancing the WRAP ESMP Policy for states under both 

Section 308 and 309 to meet the requirements of the Rule. 

Tribes are not subject to the same requirements of the Rule as states, but tribes wishing to 

assume the regional haze requirements outlined in the Rule may, according to the CAA, 

seek approval to be treated in the same manner as states, under the Tribal Authority Rule 

(TAR), 40 CFR 49. The intent of this Policy is to assist both states and tribes with the 

 

1

 The Rule is only applicable to mandatory Class I areas (see Appendix A & Appendix B for additional 

information on mandatory Class I areas). States/tribes in the WRAP region may utilize the WRAP ESMP 

Policy to protect visibility in non-mandatory Class I areas. 
ii 

development of their regional haze implementation plans (SIPs/TIPs), and therefore, 

tribes are included in all references to states, except where specific requirements and/or 

deadlines of the Rule are cited. 

The WRAP ESMP Policy defines the enhanced smoke management program as smoke 

management efforts that specifically address visibility. It is the position of the WRAP 

ESMP Policy that there are nine elements of an enhanced smoke management program 

that are necessary to meet the requirements of the Rule. According to the Rule, enhanced 

smoke management programs are to be included in implementation plans based on the 

criteria of efficiency, economics, law, emissions reduction opportunities, land 

management objectives, and reduction of visibility impacts. 

Smoke management efforts/programs currently in place (sometimes referred to as “basic 

smoke management programs”) may not specifically address visibility effects in 

mandatory Class I areas. The WRAP ESMP Policy explicitly addresses visibility effects 

from fire that contribute to visibility impairment in mandatory Class I areas. Fortunately, 

smoke management efforts/programs, regardless of the purpose (e.g., visibility 

protection, avoidance of National Ambient Air Quality Standards [NAAQS] violations, 

or prevention of nuisance smoke impacts), have many common elements. It is anticipated 

that the enhanced smoke management program elements outlined here will integrate well 

with current and future smoke management efforts/programs. 

The WRAP ESMP Policy document is comprised of four major sections. Section 1 is the 

eight WRAP ESMP Policy statements. Section 2 provides overall background for the 

WRAP ESMP Policy, including a discussion of the regulatory environment, the current 

context of smoke management in the WRAP region, and details of the Rule that are 

germane to the WRAP ESMP Policy. Section 3 is an annotation of each of the eight 

policy statements, further explaining and defining them, and including a description of 

the nine enhanced smoke management program elements. Finally, Section 4, the 

Appendices, include (A) a glossary of terms, (B) a related documents listing, and (C) 

specific examples for states/tribes on the implementation of the nine enhanced smoke 

management program elements. 
iii 

WRAP Policy 

Enhanced Smoke Management Programs 

for Visibility 

TABLE OF CONTENTS 

Executive Summary i 

1. The WRAP Policy on Enhanced Smoke Management Programs 

for Visibility: Policy Statements 1 

2. Background 2 

 

2.1 Clean Air Act and Grand Canyon Visibility Transport Commission 2 

2.2 Western Regional Air Partnership 3 

2.3 Regional Haze Rule 3 

2.4 Existing Guidanceon Smoke Management 4

3. Annotated Policy 5 

 

3.1 Introduction 5 

3.2 Visibility Effects 6 

3.3 All Fire Sources 7 

3.4 Section 309 7 

3.5 Section 308 8 

 3.6 Elements of an Enhanced Smoke Management Program 9 

 3.6.1 Element 1 Actions to Minimize Emissions from Fire 10 

 3.6.2 Element 2 Evaluation of Smoke Dispersion 10 

 3.6.3 Element 3 Alternatives to Fire 10 

 3.6.4 Element 4 Public Notification of Burning 11 

 3.6.5 Element 5 Air Quality Monitoring 11 

 3.6.6 Element 6 Surveillance and Enforcement 11 

 3.6.7 Element 7 Program Evaluation 11 

 3.6.8 Element 8 Burn Authorization 11 

 3.6.9 Element 9 Regional Coordination 11 

 3.7 Criteria 12 

 3.8 Application 13 

3.8.1 Source Sector Option 13 

3.8.2 Situational Option 14 

3.8.3 Impact Based Option 15 

 3.9 Collaborative Development 15
iv 

 

TABLE OF CONTENTS 

4. Appendices 17 

 

Appendix A. Glossary 18 

Appendix B. Related Documents Listing 25 

Appendix C. Enhanced Smoke Management Program: 

Implementation Guidance 26 

C.1 Regional Haze Rule Implementation Plan Process 26 

C.2 Elements of an Enhanced Smoke Management Program 27 

C.2.1 Element 1. Actions to Minimize Emissions from Fire 27 

C.2.1.1 Emissions Reductions Techniques 27 

C.2.1.2 Burn Manager Qualification 28 

 C.2.1.3 Incentives 29 

C.2.1.4 Emissions Goal/Target 30 

C.2.2 Element 2. Evaluation of Smoke Dispersion 30 

C.2.3 Element 3. Alternatives to Fire 31 

C.2.4 Element 4. Public Notification of Burning 32 

C.2.5 Element 5. Air Quality Monitoring 33 

C.2.6 Element 6. Surveillance and Enforcement 33 

C.2.7 Element 7. Program Evaluation 35 

C.2.8 Element 8. Burn Authorization 36 

C.2.8.1 Permit by Rule 36 

C.2.8.2 Burn Permitting System 37 

C.2.8.3 Centralized Burn Authority 37 

C.2.8.4 Regional Burn Authority 37 

C.2.9 Element 9. Regional Coordination 37 

C.2.9.1 Source Sector Authority Coordination 38 

C.2.9.2 Centralized Authority Coordination 38 

C.2.9.3 Regional (Multi-State/Tribe) Coordination 39 

C.3 Responsibilities Under an Enhanced Smoke Management Program 39 

C.4 Funding Mechanisms for Enhanced Smoke Management Programs 40 
1 

1. The WRAP Policy on Enhanced Smoke Management 

Programs for Visibility: Policy Statements

Policy Statement A. Enhanced smoke management programs under this Policy are 

defined as those smoke management efforts that specifically address visibility effects, 

and therefore, may need to be augmented to address public health and welfare issues. 

Policy Statement B. Enhanced smoke management programs apply to all fire sources. 

Policy Statement C. Enhanced smoke management programs are required for states under 

Section 309 of the Regional Haze Rule.2

Policy Statement D. Enhanced smoke management programs are a viable tool for all 

other states and tribes in the WRAP region to use in the development of their 

implementation plans. 

Policy Statement E. Enhanced smoke management programs include nine elements that 

are necessary to meet the requirements of the Regional Haze Rule, as follow: 

Element 1. Actions to Minimize Emissions from Fire 

Any burning techniques that reduce the actual amount of emissions produced. 

Element 2. Evaluation of Smoke Dispersion 

Using meteorological conditions to assess the ability to minimize smoke impacts. 

Element 3. Alternatives to Fire 

Any method of removing or reducing fuels by mechanical, biological or chemical 

treatments. 

Element 4. Public Notification of Burning 

Any method that communicates burn information to the burn community, to air 

regulators and to the general public. Also includes public education and media 

relations. 

Element 5. Air Quality Monitoring 

Observations and/or equipment that enable an assessment of air quality impacts of 

smoke from fires. 

Element 6. Surveillance and Enforcement 

An oversight mechanism that assures adherence to smoke management efforts as 

defined by the regional haze implementation plan. 

 

2

 Published in the Federal Register on July 1, 1999, 64 FR 35714. 
2 

Element 7. Program Evaluation 

A mechanism to assess the adequacy of the enhanced smoke management program in 

meeting the requirements of the Rule. 

Element 8. Burn Authorization 

The management approach used to facilitate burn decision-making. 

Element 9. Regional Coordination 

Communication and information sharing across state/tribe jurisdictional lines. 

Policy Statement F. Enhanced smoke management programs will be based on the criteria 

of efficiency, economics, law, emission reduction opportunities, land management 

objectives, and reduction of visibility impact,3

 which will determine the rigor applied to 

the nine elements. 

Policy Statement G. Enhanced smoke management programs may be applied uniformly 

to source sectors throughout a state’s or tribe’s jurisdiction or they may be tailored to 

source sectors and/or geographic areas to address presumed or confirmed visibility 

impairment. 

Policy Statement H. The development and application of enhanced smoke management 

programs, including the consideration of the criteria (F), will be done collaboratively with 

state, tribal, local and federal agencies, and private parties. 

2. Background 

2.1 Clean Air Act and Grand Canyon Visibility Transport Commission 

In 1990, Congress amended the Clean Air Act (CAA), and as part of these amendments 

created the Grand Canyon Visibility Transport Commission (GCVTC).4

 The GCVTC 

was charged with assessing the current scientific information on visibility impacts and 

making recommendations for addressing regional haze in the western United States. The 

GCVTC signed and submitted more than 70 recommendations to the Environmental 

Protection Agency (EPA) in a report dated June 1996 that indicated that visibility 

impairment was caused by a wide variety of sources and pollutants, and that a 

comprehensive strategy was needed to remedy regional haze. 

Fire sources were among those specifically acknowledged in the GCVTC Report as 

contributors to visibility impairment on an episodic basis: 

 

3

 64 FR 35771, §51.309 (d) (6) (iv). 

4

 The Grand Canyon Visibility Transport Commission (GCVTC) was composed of the governors of eight 

western states (AZ, CA, CO, NM, NV, OR, UT, WY), four tribes (Acoma Pueblo, Hopi, Hualapai, and 

Navajo), four Federal land management agencies (Bureau of Land Management, U.S. Fish and Wildlife 

Service, U.S. Forest Service, National Park Service), the Columbia River Inter-Tribal Fish Commission, 

and the Environmental Protection Agency. 
3 

All types of fire (prescribed fire and agricultural burning) must be addressed 

equitably as part of a visibility protection strategy. 5

The GCVTC Report acknowledged 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 exclusion.6 The GCVTC Report cited the need for minimizing 

the increase in emissions from all fire programs to the maximum extent feasible.7 One of 

the Report’s recommendations called for: 

...the development and implementation of criteria and requirements for the use of 

enhanced smoke management programs (including alternative management 

practices) and emission reduction strategies.8

2.2 Western Regional Air Partnership 

The Western Regional Air Partnership (WRAP) was established in 1997 as the successor 

organization to the GCVTC. The WRAP is a voluntary organization comprised of 

western governors, tribal leaders and federal agencies,9 and is charged “to identify 

regional or common air management issues, develop and implement strategies to address 

these issues, and formulate and advance western regional policy positions on air 

quality.”10 These policies and technical tools are developed through inclusive, 

stakeholder-based processes and approved by consensus of the WRAP. 

WRAP participants include state air quality agencies, tribes, federal/state/private land 

managers, the EPA, environmental groups, industry, academia and other interested 

parties. There are over 400 tribes within the WRAP region. The large number of tribes 

limits the participation of all of them in WRAP activities, and accordingly, in the 

development of this Policy. Therefore, the tribal representatives involved in the 

development of this Policy may not represent all tribal concerns. 

2.3 Regional Haze Rule 

Following the issuance of the GCVTC Report, the EPA issued the Regional Haze Rule 

(Rule) in July 1999 to improve visibility in 156 national parks and wilderness areas 

across the country. The Rule outlines the requirements for states and tribes to address 

 

5

 GCVTC Report, p. 47. 

6

 GCVTC Report, p. 23. 

7

 GCVTC Report, Recommendation 7, p. 50. 

8

 GCVTC Report, Recommendation 4, p. 49. 

9

 The WRAP members include the governors of thirteen western states (AK, AZ, CA, CO, ID, MT, ND, 

NM, OR, SD, UT, WA, and WY). Tribal nations selected as WRAP members include Pueblo of Acoma, 

Campo Band of Kumeyaay Indians, Cortina Indian Rancheria, Hopi Tribe, Hualapai Nation of the Grand 

Canyon, Nez Perce Tribe, Northern Cheyenne Tribe, Salish and Kootenai Confederated Tribes, Pueblo of 

San Felipe, and Shoshone-Bannock Tribes of Fort Hall. Federal WRAP members are the Department of the 

Interior, the Department of Agriculture, and the Environmental Protection Agency. 

10 WRAP Charter, Purpose, p. 1. 
4 

regional haze in these mandatory Class I areas. EPA incorporated all of the GCVTC 

recommendations into Section 309 of the Rule, which may be used by some of the 

WRAP states/tribes. The remaining WRAP states must, and tribes may, utilize the 

nationally applicable Section 308 provisions of the Rule. 

Tribes are not subject to the same requirements of the Rule as states, but tribes wishing to 

assume the regional haze requirements outlined in the Rule may, according to the CAA, 

seek approval to be treated in the same manner as states, under the Tribal Authority Rule 

(TAR), 40 CFR 49. In these cases, EPA still recognizes that “unlike States, tribes are not 

required by the TAR to adopt and implement CAA plans or programs, thus tribes are not 

subject to mandatory deadlines for submittal of implementation plans.”11 Although 

provision for flexibility in the submission of programs and implementation plans for 

tribes is made under TAR, EPA does “encourage tribes choosing to develop 

implementation plans to make every effort to submit by the deadlines to ensure that the 

plans [TIPs] are integrated with and coordinated with regional planning efforts.”12 

EPA recognizes the WRAP as the Regional Planning Organization that is developing the 

necessary policy and technical tools to implement the Rule in the WRAP region. A 

WRAP policy, once approved, represents the WRAP's consensus position on the 

best means for states and tribes to implement the portion of the Rule at issue. The WRAP 

recognizes states’ and tribes’ authority and responsibility to develop, adopt and 

implement their regional haze state and tribal implementation plans, and the seminal 

guidance to do this is the Rule.13

2.4 Existing Guidance on Smoke Management 

The elements of an enhanced smoke management program as outlined in this Policy are 

based upon careful review and consideration of the Rule and the existing guidance on 

smoke management: the EPA’s Interim Air Quality Policy on Wildland and Prescribed 

Fires (EPA Interim Policy)14 and the Agricultural Air Quality Task Force’s (AAQTF) 

Recommendation on Air Quality Policy on Agricultural Burning (AAQTF 

Recommendation on Air Quality Policy).15 However, these documents do not specifically 

provide guidance for smoke management programs that address visibility effects. The 

WRAP ESMP Policy goes beyond the EPA Interim Policy and the AAQTF 

Recommendation on Air Quality Policy to address visibility effects and regional haze, as 

required by the Rule. 

 

11 64 FR 35758. 

12 64 FR 35759. 

13 WRAP Charter, p.1. 

14 U.S. EPA, Office of Air Quality Planning and Standards, Interim Air Quality Policy on Wildland and 

Prescribed Fires, April 23, 1998 (hereafter referred to as “EPA Interim Policy”). 15 Agricultural Air Quality Task Force, Air Quality Policy on Agricultural Burning, Recommendation to the 

U.S. Department of Agriculture, November 10, 1999 (hereafter referred to as “AAQTF Recommendation 

on Air Quality Policy”). 
5 

3. Annotated Policy 

3.1 Introduction

The WRAP ESMP Policy is the result of the WRAP region-wide multi-state/tribe 

stakeholder planning and coordination effort focused on addressing the development of 

enhanced smoke management programs that address visibility effects. The intent of the 

WRAP ESMP Policy is to assist states (or the delegated authority) and tribes to address 

visibility effects associated with fire in a way that is adequate for SIP/TIP 

implementation. 

The WRAP ESMP Policy identifies for states/tribes in the WRAP region the elements of 

an enhanced smoke management program to address visibility effects from all types of 

fire that contribute to visibility impairment in mandatory Class I areas. Although the Rule 

is only applicable to mandatory Class I areas, state/tribes in the WRAP region may utilize 

the WRAP ESMP Policy to protect visibility in non-mandatory Class I areas.16 

Most states/tribes in the WRAP region address fire source sectors differently, as does 

EPA in its guidance documents. Consequently, fire sources in the WRAP region are 

currently regulated at various and inconsistent levels, from rigorous regulation to 

regulation with exemption applied, to no regulation. This variability emphasizes the need 

for the development and application of an enhanced smoke management program 

framework that is predictable and flexible while meeting the requirements of the Rule. 

The WRAP ESMP Policy has been developed to embody appropriate regulatory and 

policy requirements and to provide a predictable framework for enhanced smoke 

management programs that can be reasonably implemented by states and tribes. The 

WRAP believes that states, tribes, or EPA on behalf of the tribes maintain the ultimate 

responsibility for the implementation of the enhanced smoke management program. 

The WRAP recognizes states/tribes authority and responsibility to develop, adopt and 

implement their regional haze state and tribal implementation plans. The WRAP further 

recognizes that the implementation plans will be revisited and revised, per the schedule 

specified in the Rule, giving opportunities to refine individual enhanced smoke 

management programs to reflect technical advances and policy updates. 

3.2 Visibility Effects

Policy Statement A. Enhanced smoke management programs under this Policy 

are defined as those smoke management efforts that specifically address visibility 

effects, and therefore, may need to be augmented to address public health and 

welfare issues. 

Most current smoke management efforts and programs to date in the WRAP region have 

been developed to address public health and/or nuisance concerns, and do not have 

 

16 See Appendix B for the reference to a map of Class I areas. 
6 

procedures to address visibility effects that contribute to regional haze. The enhanced

smoke management program adds visibility impairment/regional haze considerations to 

existing smoke management efforts. 

States/tribes are currently addressing NAAQS and/or nuisance to the extent they deem 

appropriate through existing smoke management efforts. Some states/tribes have certified 

their smoke management programs under EPA’s Interim Policy, both inside and outside 

the SIP/TIP process.17 The EPA certified programs include those mandated by rule, state 

statute, and programs based on voluntary measures.18 However, few, if any, states/tribes 

have smoke management programs that address all fire sources, (e.g., prescribed fire on 

wildlands, wildland fire use, wildfire and agricultural burning), in one unified program. 

The WRAP ESMP Policy assumes that states/tribes will maintain their current smoke 

management efforts and/or smoke management programs for NAAQS and/or nuisance. 

The WRAP ESMP Policy can be used to establish new programs to address visibility 

concerns even if there are no other smoke management efforts currently in place. While 

the WRAP ESMP Policy provides a framework for visibility/regional haze, states/tribes 

may choose to do more in their smoke management programs to protect NAAQS, prevent 

nuisance and/or address visibility. 

The WRAP ESMP Policy facilitates the integration of visibility protection with NAAQS 

and nuisance protection, in accordance with the Rule: 

The regional haze program is being promulgated in a manner that facilitates 

integration of emission management strategies for regional haze with the 

implementation of programs for new NAAQS for Ozone and PM.19

The elements included in the enhanced smoke management program as outlined by this 

Policy have been selected in an attempt to address direct visibility effects and regional 

haze in mandatory Class I areas. It is possible that states/tribes may encounter conflicts 

between managing smoke for visibility considerations and smoke management efforts for 

NAAQS and/or nuisance. It is therefore recommended that states/tribes coordinate their 

efforts to protect visibility with existing or future efforts to address NAAQS and/or 

nuisance smoke. 

3.3 All Fire Sources 

Policy Statement B: Enhanced smoke management programs will apply to all fire 

sources. 

The WRAP ESMP Policy applies to all fire, and maintains the previously established 

definitions: 

 

17 A state/tribe certifies “to EPA that they have adopted and are implementing a smoke management 

program that includes the basic components identified in this policy.” EPA Interim Policy, p. 7. 

18 WRAP states implementing smoke management programs using voluntary measures include NM and ID. 

19 64 FR 35719, emphasis added. 
7 

This Policy applies to both wildland and agricultural lands regardless of 

ownership (i.e., Federal, state, tribal, public, private), cause of ignition (e.g., 

lightning, arson, accidental human, land management practices) or purpose of the 

fire (e.g., vegetative residue disposal, hazard reduction, maintain ecosystem 

health). It is the intent that this Policy be applied equitably across all land types 

and sources. 20 

All fire source sectors are included in the WRAP ESMP Policy because it is recognized 

by EPA that “fire of all kinds (wildfire, prescribed fire, etc.) contributes to regional 

haze.”21 This Policy needs to be applied to all sources addressed by the WRAP Fire 

Categorization Policy. In accordance with Section 118(a) of the CAA requires that all 

entities, federal and non-federal, be subject to the same requirements, authorities and 

processes,22 the WRAP ESMP Policy will be applied equitably to all fire sources. 

The WRAP ESMP Policy specifically does not apply to Native American cultural nonvegetative burning for traditional, religious, or ceremonial purposes (e.g., cremation, 

sweat lodge fires).23 Nor does it apply to open burning activities on residential, 

commercial, or industrial property (e.g., backyard burning, garbage incineration, 

residential wood combustion, construction debris).24 However, states/tribes may choose 

to consider the impacts of these fire sources when developing their regional haze 

implementation plans. 

The WRAP ESMP Policy applies to smoke impacts in mandatory Class I areas from fire 

anywhere in the WRAP region. Each state has an obligation to account for those 

emissions it produces that have impacts in its own mandatory Class I areas. 

Accountability also extends to states and tribes that have smoke impacts outside their 

jurisdictions.

3.4 Section 309 

Policy Statement C: Enhanced smoke management programs are required for 

states under Section 309 of the Regional Haze Rule. 

The EPA incorporated all of the GCVTC recommendations into Section 309 of the Rule, 

which specifically calls for “[e]nhanced smoke management programs for fire that 

consider visibility effects, not only health [NAAQS] and nuisance objectives....”25 Under 

Section 309, states must incorporate an enhanced smoke management program into their 

SIPs, which will give them the demonstration of reasonable further progress through 

2018.26 The ability of a state/tribe to implement the enhanced smoke management 

 

20 WRAP Policy for Categorizing Fire Emissions, November 15, 2001 (hereafter referred to as “WRAP 

Fire Categorization Policy”), p 7. 

21 64 FR 35735. 

22 Clean Air Act §118(a). 

23 WRAP Fire Categorization Policy, p. 24. 

24 Ibid, however “industrial property” would not include land such as industrial forestland. 25 64 FR 35771, §51.309 (d) (6) (iv). 

26 64 FR 35769, §51.309 (a). 
8 

program may require legislative changes to existing rules or removal of exemptions from 

regulation for specific fire sources. 

The tracking of emissions from all fire (i.e., wildland and agricultural land) is a 

requirement of the Rule for states under Section 309, including the development of an 

emissions inventory for VOCs, NOx, elemental and organic carbon, and fine particulate 

matter.27 States/tribes under Section 309 will need to address projected fire emissions in 

order to facilitate regional haze planning and operational smoke management.28 The 

tracking of emissions could allow for these projections to be developed. Emissions 

tracking will also provide information critical to implementing several of the necessary 

elements of an enhanced smoke management program. The Rule under Section 309 

further calls for the establishment of annual emission goals for fire that will minimize 

emissions increases from fire to the maximum extent feasible.29 The WRAP is currently 

developing policy on both emissions tracking and on the establishment of annual 

emissions goals that will work in concert with the WRAP ESMP Policy. 

3.5 Section 308 

Policy Statement D. Enhanced smoke management programs are a viable tool for 

all other states and tribes in the WRAP region to use in the development of their 

implementation plans. 

The Rule requires states/tribes to address visibility impairment in mandatory Class I areas 

due to emissions from all sources including fire activities. The Preamble to the Rule 

emphasizes smoke management programs as effective tools to accomplish this: 

Where smoke impacts from fire are identified as an important contributor to 

regional haze, smoke management programs should be a key component of 

regional and State regional haze planning efforts and long-term strategies.30 

Under Section 308, a state must consider smoke management techniques for agricultural 

and forestry lands in its long-term strategy for regional haze. Section 308 of the Rule 

states: 

The State must identify all anthropogenic sources of visibility impairment 

considered by the State in developing its long-term strategy [for regional haze]. 

The State should consider major and minor stationary sources, mobile sources, 

and area sources.31

and: 

(v) The State must consider, at a minimum, the following factors in developing its 

long-term strategy [for regional haze]: 

 

27 64 FR 35771, §51.309 (d) (6) (ii) 

28 64 FR 35771, §51.309 (d) (6) (i). 

29 64 FR 35771, §51.309 (d) (6) (v). 

30 64 FR 35736. 

31 64 FR 35767, §51.308 (d) (3) (iv). 
9 

(E) Smoke management techniques for agricultural and forestry management 

purposes including plans as currently exist within the States for these purposes.32 

If a state’s visibility impairment analysis33 shows that fire sources contribute to visibility 

impairment in a mandatory Class I area and the state determines that fire sources need to 

be addressed in its SIP, then the enhanced smoke management program will be a viable 

tool to do so. A statewide inventory of emissions of pollutants that contribute to visibility 

impairment in mandatory Class I areas is a requirement of the Rule for states choosing to 

implement the Rule under Section 308. Further, these states will also be required to 

account for future projected emissions.34 

3.6 Elements of an Enhanced Smoke Management Program

Policy Statement E: Enhanced smoke management programs include nine 

elements that are necessary to meet the requirements of the Regional Haze Rule. 

The elements included in the enhanced smoke management program as outlined by this 

Policy have been selected in an attempt to address direct visibility effects and regional 

haze in mandatory Class I areas to improve visibility on the worst days and maintain 

visibility on best days.35 The first seven enhanced smoke management program elements 

come directly from Section 309 of the Rule that states that SIPs “must include smoke 

management programs that include all necessary components including, but not limited 

to, actions to minimize emissions, evaluation of smoke dispersion, alternatives to fire, 

public notification, air quality monitoring, surveillance and enforcement, and program 

evaluation.”36 These same smoke management components are also found in the EPA 

Interim Policy and the AAQTF Recommendation on Air Quality Policy. 37

The EPA Interim Policy and the AAQTF Recommendation on Air Quality Policy also 

advocate a burn authorization component (i.e., Element #8).38 Without a central burn 

authority considering the cumulative smoke impacts, it will be difficult on a daily basis 

for individual land managers/owners to assess their relative contribution to regional haze. 

Regional coordination (i.e., Element #9) is central to burn authorization, and will 

facilitate coordinated decision-making. It is a necessary mechanism to address transport 

issues and cumulative effects, especially when considering impacts of a source that may 

be large, or many sources that cumulatively are large, but a long distance from a Class I 

 

32 64 FR 35767, §51.308 (d) (3) (v) (E). 

33 As outlined in the Rule under Section 308, this process includes calculating the baseline of all sources; 

comparing the baseline visibility conditions with natural conditions; assessing the contribution to this of the 

different sources (of which smoke is one); then considering in the development of long term strategies: 

smoke management techniques, including current smoke management programs that exist; and if not 

adequate, considering enforceable emissions limitations and compliance schedules and other measures as 

necessary. 64 FR 35765 §51.308. 

34 64 FR 35767, §51.308 (d) (4) (v) and 35769, §51.308 (g) (4). 

35 64 FR 35764, §51.301. 

36 64 FR 35771, §51.309 (d) (6) (i), emphasis added. 

37 EPA Interim Policy, p. 17-23, and AAQTF Recommendation on Air Quality Policy, p. 2. 

38 EPA Interim Policy, p. 18, and AAQTF Recommendation on Air Quality Policy, p.12. 
10 

area (i.e., greater than 100 km). Regional coordination is emphasized in the Rule as key 

to reaching the national visibility goal. In the preamble, the Rule states: 

Therefore, States will need to develop strategies in coordination with one another, 

taking into account the effect of emissions from one jurisdiction to air quality in 

another.39 

And in the preamble to Section 308, the Rule states: 

In developing each reasonable progress goal, the State must consult with those 

States which may reasonably be anticipated to cause or contribute to visibility 

impairment in the mandatory Class I Federal area.40

The WRAP ESMP Policy elements include measures to control and/or reduce emissions 

from fire (Elements 1, 3, and 8); tools to assess and manage the potential impacts from 

fire (Elements 2 and 5); and operational components of a successful smoke management 

program (Elements 4, 6, 7, and 9). In addition to the elements descriptions that follow, 

suggestions for implementation of the nine enhanced smoke management program 

elements are included in Appendix C of this document. 

3.6.1. Element 1. Actions to Minimize Emissions from Fire

A wide range of opportunities to minimize emissions exists depending upon the fire 

source and management objectives. Four potential actions that may be used are: emission 

reduction techniques, establishing burn manager qualification programs,41 developing 

incentive programs, and establishing emissions goals. 

3.6.2. Element 2. Evaluation of Smoke Dispersion

A variety of tools and methods exist by which a land manager/owner could reduce smoke 

impacts over periods ranging from several hours to several days. States/tribes may focus 

on the use of specific weather information, fuels information, modeling or a burner 

qualification and certification program to assist in the evaluation of dispersion conditions. 

3.6.3. Element 3. Alternatives to Fire

Alternatives to fire (as distinguished from alternative methods of burning) include any 

method of removing or reducing fuels by mechanical, biological or chemical treatments. 

States/tribes may assist land managers/owners to develop and implement alternatives to 

fire. Land managers/owners may be required to assess the feasibility of using alternatives 

to fire where there are many competing sources or large amounts of burning occurring 

that could lead to visibility impairment in mandatory Class I areas. Regulatory authorities 

may want to consider incentives to encourage the use of alternatives to burning where 

appropriate. The WRAP through its FEJF has commissioned two reports on alternatives 

to burning that will aid states and tribes in addressing this element of the ESMP. 

 

39 64 FR 35728. 

40 64 FR 35766, §51.308 (d) (1) (B) (iv). 

41 States/tribes could consider adopting existing burn qualification programs sanctioned by land 

management agencies.
11 

3.6.4. Element 4. Public Notification of Burning

Public notification is a significant part of the CAA, and is inherent in the Rule. Public 

notification under an enhanced smoke management program should be at least what is 

required by EPA for a certifiable smoke management program,42 and may include extra 

activities, depending on location. Generally, regardless of what kind of smoke 

management program is in place, significant effort should be made to educate and notify 

the public about burning, its impacts, as well as its benefits. 

3.6.5. Element 5. Air Quality Monitoring

Monitoring of smoke impacts may be a very sophisticated effort using EPA reference 

method sampling equipment or it may be as simple as creating a hand-written log of 

smoke behavior as assessed visually. Minimal procedures would be most likely in areas 

of little burn activity or when farther away from Class I areas. 

3.6.6. Element 6. Surveillance and Enforcement

Good communication between regulators and land managers/owners can significantly 

reduce the need for surveillance and enforcement. An atmosphere of trust and 

cooperation between regulators and land managers/owners can help facilitate emissions 

reductions and compliance with air quality regulations. Performance and compliance 

standards may be established under various methods of operations. 

3.6.7. Element 7. Program Evaluation

Enhanced smoke management programs need to be reviewed on a periodic basis for their 

effectiveness by the regulatory authority and affected stakeholders. Formal periodic 

progress reports could coincide with time intervals used to evaluate reasonable progress. 

The Rule requires progress reports every five years.43 However, shorter review and 

evaluation time periods would better determine if enhanced smoke management 

programs are effective. 

3.6.8. Element 8. Burn Authorization 

Burn authorization requirements are expected to vary depending upon the amount of 

burning that is occurring, the fire source types that are conducting the burning, and the 

degree of impairment that exists or may be expected to occur as a result of the burning. 

The proximity of mandatory Class I and non-attainment areas may also have a bearing on 

the complexity of the burn authorization procedure that should be implemented. 

3.6.9. Element 9. Regional Coordination

Coordination of burning activity is critical to avoiding cumulative smoke impacts within 

and across source types in mandatory Class I areas. Coordination may range from a 

passive mode of information sharing between land managers/owners and/or the public to 

a more complex, active coordination in which burn decisions are altered based on 

jurisdictional authority and other activities that are occurring or have recently occurred. 

Methods for this inter-jurisdictional and regional coordination will need to be developed. 

 

42 EPA Interim Policy, p.17-23. 

43 64 FR 35768, § 1.308 (g) and 35772, §51.309 (d) (10). 
12 

The development process should be a collaborative one involving state, tribal, local and 

federal agencies, and private parties. 

3.7 Criteria

Policy Statement F: Enhanced smoke management programs will be based on the 

criteria of efficiency, economics, law, emission reduction opportunities, land 

management objectives, and reduction of visibility impact,44 which will determine 

the rigor applied to the nine elements. 

According to the Rule, enhanced smoke management programs are to be included in 

implementation plans based on the criteria of efficiency, economics, law, emissions 

reduction opportunities, land management objectives, and reduction of visibility impacts. 

These criteria will influence the extent to which individual elements of the enhanced 

smoke management program are applied or the level of effort that is possible. For 

example, legal barriers may need to be removed and/or infrastructure may need to be 

developed to implement the enhanced smoke management program. The level of effort 

each state/tribe will apply to the nine elements of the enhanced smoke management 

program needs to be based on a pre-determined process or metric established by the 

regulatory authority that considers the public as well as stakeholders. 

Additional examples of how states/tribes might consider the enhanced smoke 

management program criteria are listed below. 

Efficiency: What are the resources, infrastructure, networking, workforce and 

information necessary to reduce visibility impairment in mandatory Class I areas? Is it 

feasible to share these items with another group in order to reduce redundancy or build on 

existing expertise? 

Economics: What are the costs and incentives of the items listed under Efficiency? Are 

there ways to economically quantify improvements to regional haze in a local area? What 

is the economic trade-off of moving fuels off-site to be converted to another use or 

burned elsewhere? What are the economic costs to a landowner to look for emission 

reduction alternatives? What are the economic gains from improved habitats, functioning 

watersheds, species diversity and healthy ecosystems? What are the economic losses to a 

community associated with impairment, (e.g., property values, tourism, etc.)? 

Law: Are there federal, state, tribal ordinances, local rules or statutes that prohibit 

mechanical treatments or prohibit the regulation of burning? Are there conflicts with 

management or law pertaining to the Threatened and Endangered Species Act and/or the 

Wilderness Act? 

Emission Reduction Opportunities: Where are the opportunities to consider reducing 

emissions through mechanical, biological, or chemical means? Where are the places 

where reducing emissions will be best done through smoke management techniques 

 

44 64 FR 35771, §51.309 (d) (6) (iv). 
13 

rather than moving fuels off-site or manipulating fuels through chemicals or biological 

decomposition or a combination of mechanical treatments and maintenance burning? 

Land Management Objectives: Are there places where manipulating fuels is not an option 

because of land management objectives, e.g., tribal cultural values, wildlife habitat, crop 

requirements, residue removal constraints, or inaccessible terrain? Are there places 

where manipulating fuels is more conducive to the land management objective, e.g., areas 

targeted for commodity production, watershed protections or tribal cultural activities 

sites? Are there places that restoration of ecosystem function may have a high priority? 

Reduction of Visibility Impacts: Using the current information and science available to a 

state/tribe, how will an enhanced smoke management program decrease impacts to 

visibility? 

3.8 Application 

Policy Statement G: Enhanced smoke management programs may be applied 

uniformly to source sectors throughout a state’s jurisdiction or they may be 

tailored to source sectors and/or geographic areas to address presumed or 

confirmed visibility impairment. 

Since emissions from fire sources contribute differently to visibility impairment in Class I 

areas and/or may be from different geographical areas, tailoring of an enhanced smoke 

management program to a fire source sector and/or a geographic area may be appropriate. 

This section presents options for states/tribes to consider in tailoring such a program. The 

first two options are built upon a presumption that certain sources or situations contribute 

to visibility impairment. The third option relies upon confirmation of impairment 

attributed to a source sector. The options described below may be implemented 

independently or in any combination, as deemed appropriate by the state/tribe. 

The options explored here are not exhaustive or definitive in structure or design. 

However, any selected option must still consider the nine elements as well as the criteria 

as specified in the Rule. Application of these or any other options can be considered at 

the source sector level, but should also be sensitive to the potential for cumulative 

impacts of all fire source sectors. Additionally, state/tribal authorities will want to be 

mindful of equitable treatment of sources in the implementation of their enhanced smoke 

management programs. 

3.8.1 Source Sector Option

Under this option, there is a presumption that certain source sectors are reasonably 

expected to contribute to visibility impairment based on historical data and/or projected 

future burning. Where this presumption exists, states/tribes could choose to apply the 

nine enhanced smoke management program elements to those source sectors with a 

greater level of effort. 

 
14 

3.8.2 Situational Option

This option describes certain situations that, if true, would indicate to the state/tribe the 

need for a greater level of effort of implementation of the enhanced smoke management 

program elements. The scenarios below can be used by states/tribes in the development 

of area and/or source sector-specific enhanced smoke management programs. Each 

scenario describes a combination of emission levels, NAAQS status (e.g., non-attainment

area status) and proximity to Class I areas that may indicate the level of enhanced smoke 

management program needed. 

 

The following is an example of how this situational option could be applied, and is 

modeled after the Prevention of Significant Deterioration (PSD) permitting 

requirements45 for major stationary sources (see table in footnote below).46 In this 

example, the emissions are the annual totals that would be produced by a fire source 

sector. The attainment status accounts for existing non-attainment area (NAA) issues that 

a state/tribe may need to address.47 The proximity parameter addresses how close a fire 

source sector is to a Class I area. This example is predicated on all three factors applying 

simultaneously. 

a) Emissions levels: Greater than 50 tons/yr of PM10 (total/year) within 

state/tribe for all anthropogenic fire sources 

 Attainment status: No PM10 or Ozone NAAs 

 Proximity: Within and near (i.e., <50 km) a Class I area 

b) Emissions levels: Greater than 250 tons/yr of PM10 (total/year) within 

state/tribe for all anthropogenic fire sources 

 Attainment status: No PM10 or Ozone NAAs 

 Proximity: Within 100 km of Class I area 

c) Emissions levels: Greater than 100 tons/yr PM10 (total/year) within state/tribe 

for all anthropogenic fire sources 

 

45 40 CFR § 52.21. 

46 This table provides estimates of acres burned to give an idea of approximate fire size using the available 

emission factors for the source type indicated. These numbers are not an exact representation of acreages, 

emission factor, and fuel loading of all fires for each type. Note: Agriculture and Rangeland numbers are 

the same. 

Tons (PM10) Acres Burned (Annual Total)

Wildland 

(Forest: 20 tons/acre 

consumed)

Agriculture 

(4 tons/acre consumed) 

Rangeland 

(2 tons/acre consumed) 

250 833 12,500 12,500 

100 333 5,000 5,000 

70 233 3,500 3,500 

50 167 2,500 2,500 

 

47 When PM2.5 NAAs are identified, then PM2.5 could also be used in assessing the level of enhanced smoke 

management program needed. 
15 

 Attainment status: Moderate PM10 or Ozone NAA or Maintenance Area 

 Proximity: Within 100 km of Class I area 

d) Emissions levels: Greater than 70 tons/yr PM10 (total/year) within state/tribe 

for all anthropogenic fire sources 

 Attainment status: Serious PM10 or Ozone NAA 

 Proximity: Within 100 km of Class I area 

e) Emissions levels: Greater than 250 tons/yr of PM10 (total/year) within 

state/tribe for all anthropogenic fire sources 

Attainment status: Any level of Attainment/NAA 

Proximity: Distances farther than 100 km 

3.8.3 Impact Based Option

A state/tribe can determine the level of effort of an enhanced smoke management 

program based on the relative contribution (i.e., impact) of each of its fire source sectors 

and cumulatively all fire source sectors’ impacts to visibility impairment in Class I areas. 

One possible approach that could be used is related to deciview, the metric commonly 

associated with visibility analyses and also used within the PSD permitting process. 

Under this scenario, states/tribes would determine the frequency, magnitude (in 

deciview), and duration of a source sector's contribution to visibility impairment (on the 

20 percent “worst” visibility days in a calendar year). To prevent degradation of the 20 

percent “best” visibility days in a calendar year, the state/tribe may want to increase the 

rigor of its enhanced smoke management program if emissions from fire sources 

correspond with declining visibility. 

In order to determine these components, a visibility impairment assessment could be 

conducted using Interagency Monitoring of Protected Visual Environments (IMPROVE) 

data, emissions data derived from fire activity data, contemporary visibility modeling 

techniques, or other available information. Note that currently, final analysis of 

IMPROVE data sometimes lags as much as a year from when data were collected. This 

situation may also be true of visibility impairment assessments. Therefore, there may be 

lag time between when impacts were measured and how soon enhanced smoke 

management programs could be implemented or revised. 

Based on the results of the visibility assessment, the states/tribes could determine what 

level of effort of enhanced smoke management program corresponds to the degree of 

impact. 
16 

3.9 Collaborative Development 

Policy Statement H: The development and application of enhanced smoke 

management programs, including the consideration of the criteria (F), will be 

done collaboratively with state, tribal, local and federal agencies and private 

parties. 

The GCVTC Report cites the importance of a collaborative process in a number of places 

with regard to fire.48 EPA’s Interim Policy also supports collaborative efforts and 

specifies roles for the stakeholders in the process. The underlying tenet of the WRAP 

process further conveys the importance of approaching visibility and the Rule with 

stakeholder input and use of collaborative processes. 

Utilizing land managers and affected publics as well as the responsible air regulatory 

entity can result in an enhanced smoke management program that will meet the 

expectations of EPA for SIP submittal under Section 309, and may reduce localized 

controversy. There are certain steps in the enhanced smoke management program 

development process that will need cooperative efforts, such as the establishment of the 

criteria to be used by the regulatory entity to determine the level of effort needed for the 

enhanced smoke management program. The criteria for determining the level of effort is 

a significant issue as there is a paucity of data on emissions and visibility impairment 

from fire sources. This level of effort assessment is also tied to developing funding 

mechanisms for the enhanced smoke management program, which the GCVTC urged be 

developed cooperatively. 

The SIP/TIP development process will be initiated by the respective regulatory entity, 

which is the responsible party for initiating the collaborative efforts. The earlier in the 

SIP development process that a collaborative effort could be initiated would likely result 

in a more valuable result. It is envisioned that, through a collaborative effort, a schedule 

and process for implementing the enhanced smoke management program will be created 

that is acceptable to both EPA and affected stakeholders. Using a collaborative process 

will facilitate the needed equity among fire source sectors as well. 

 

48 GCVTC Report, p. 49-50. 
17 

APPENDICES 
18 

Appendix A 

Glossary 

This glossary is intended to facilitate readers’ consistent review of this Policy. This 

glossary is not intended to be a complete list of all terms and acronyms. An asterisk (*) 

indicates a definition from Section 1.1 of the WRAP Fire Emissions Joint Forum (FEJF) 

Workplan, February 25, 1999. A number sign (#) indicates a definition from the WRAP 

Policy for Categorizing Fire Emissions, November 15, 2001.

Agricultural Fire/Burning* - Any fire ignited by management actions to meet specific 

objectives (i.e., managed to achieve resource benefits) on agricultural land. 

Agricultural Land* - Agricultural land includes croplands, pasture, and other lands on 

which crops or livestock are produced (PL 104-127, Section 1240A). Rangeland will be 

included with wildland for the purposes of the FEJF work. 

Alternatives to Burning - Land management practices that treat fuel without using fire. 

Anthropogenic - Produced by human activities. 

Anthropogenic Emissions Source Classification (“anthropogenic”)# - A categorization 

that designates which fire emissions contribute to visibility impairment in a Federal Class 

I area. “Anthropogenic” emissions must be controlled to achieve progress toward the 

2064 natural conditions goal [i.e., natural visibility goal] for each Federal Class I area in 

the WRAP region. This classification includes natural and human-caused ignitions. 

Area Source - A source category of air pollution that generally extends over a large area. 

Prescribed burning, field burning, home heating, and open burning are examples of area 

sources. 

Attainment Area - An area considered to have air quality as good as or better than the 

national, state/tribe or local ambient air quality standards. Note that an area may be in 

attainment for one or more pollutants but be a non-attainment area for one or more other 

pollutants. 

Best Available Control Measures (BACM) - A term used to refer to the most effective 

measures (according to EPA guidance) for controlling small or dispersed particulates and 

other emissions from sources such as roadway dust, soot and ash from woodstoves and 

open burning of rush, timber, grasslands, or trash. 

Best Management Practices (BMPs) - A term applied collectively to any administrative 

or on-the-ground procedure that reduces the negative impacts of some action. An 

example of a Best Management Practice with respect to air quality would be conducting a 

prescribed burn when atmospheric ventilation is good, which in turn promotes smoke 

dispersal. 
19 

Class I Area - See Mandatory Class I Area and Non-Mandatory Class I Area. 

Control of Fire Emissions#

 - Actions may be taken to control fire emissions by utilizing 

best management practices such as the use of alternatives, biomass utilization, and other 

emission reduction techniques. 

Criteria Pollutants - The 1970 amendments to the CAA required EPA to set National 

Ambient Air Quality Standards (NAAQS) for certain pollutants known to be hazardous to 

human health. EPA has identified and set standards to protect human health and welfare 

for pollutants: ozone, carbon monoxide, particulate matter (PM10 and PM2.5), sulfur 

dioxide, lead, and nitrogen oxide. The term, "criteria pollutants" derives from the 

requirement that EPA must describe the characteristics and potential health and welfare 

effects of these pollutants. It is on the basis of these criteria that standards are set or 

revised. 

Cumulative Effects - The effect on the environment that results from the incremental 

impact of the action when added to other past, present, and reasonable foreseeable future 

actions regardless of what agency, entity or person undertakes such action. Cumulative 

effects can result from individually minor but collectively significant actions taking place 

over a period of time. 

Deciview - A unit of visibility proportional to the logarithm of the atmospheric 

extinction. Under many circumstances a change in one deciview will be perceived to be 

the same on clear and hazy days. 

Ecosystem Maintenance Burning#

 - A prescribed fire or wildfire managed for resource 

benefits, in an ecosystem that is currently in an ecologically functional and fire resilient 

condition, that is utilized to mimic the natural role of fire. 

Ecosystem Restoration Burning# - The re-establishment of natural vegetation that may be 

accomplished through the reduction of unwanted and/or unnatural levels of biomass, 

which may have accumulated due to management action. Prescribed fires, wildfires 

managed for resource benefits and mechanical treatments may be utilized to restore an 

ecosystem to an ecologically functional and fire resilient condition.

Emission - Pollution discharged into the atmosphere. Examples of emissions sources are 

smokestacks, other vents, and surface areas of commercial or industrial facilities; from 

residential chimneys; and from motor vehicle, locomotive, aircraft, or other non-road 

engines. 

Emission Inventory - A listing, by source, of the amount of air pollutants discharged into 

the atmosphere. 

Emission Cap - An enforceable limit on the amount of specific air pollutants that can be 

released or on the amount of a specific pollutant that is allowed to be in the air in a 
20 

defined geographic area, and that has regulatory consequences. See also Emission Goal 

and Emission Target. 

Emission Goal - A desired future outcome that may be represented by a numeric 

indicator, but without regulatory consequences, and as distinguished from a limit (i.e., 

target or cap). See also Emission Cap and Emission Target. 

Emission Reduction - A strategy for controlling smoke from prescribed fires that 

minimize the amount of smoke output per unit of area treated or other objective unit of 

accomplishment. 

Emission Target - A firm limit on the amount of specific air pollutants that can be 

released or on the amount of a specific pollutant that is allowed to be in the air in a 

defined geographic area, but without regulatory consequences (as distinguished from a 

cap). See also Emission Cap and Emission Goal. 

Enhanced Smoke Management Program (ESMP) - A program for fire emissions that 

considers visibility effects, in addition to health and nuisance objectives, and is based on 

the criteria of efficiency, economics, law, emission reduction opportunities, management 

objectives, and reduction of visibility impact. 

Federal Class I area - see Class I Area. 

Fire* - When this term appears, it refers inclusively to wildfire, prescribed natural 

fire/wildland fire managed for resource benefits, prescribed fire, rangeland fire, and 

agricultural fire. 

Fire Source Sector - A segment of fire attributed to a particular management or 

ownership, e.g., wildland prescribed fire, agricultural prescribed fire, wildfire, and 

wildland fire use. Also known as a fire source. 

Fire Use - A term utilized in federal land management that includes both prescribed fire 

and wildland fire use. 

Fuel Moisture Content - The quantity of moisture in fuel expressed as a percentage of the 

weight when thoroughly dried at 212 degrees F. 

Fuel Reduction - The manipulation, including combustion, or removal of fuels to reduce 

the likelihood of ignition and/or to lessen potential damage and resistance to control. 

Fuel Treatment - Manipulation or removal of fuels to reduce the likelihood of ignition 

and/or to lessen potential damage and resistance to control (e.g., lopping, chipping, 

crushing, piling and burning). 
21 

Implementation Plan - Plans devised by states and/or tribes to carry out their 

responsibilities under the CAA. SIPs/TIPs must be approved by the U.S. Environmental 

Protection Agency and include public review. 

Interagency Monitoring of Protected Visual Environments (IMPROVE) - A cooperative 

visibility monitoring effort, using a common set of standards across the United States, 

between the EPA, federal land management agencies, and state air agencies. 

Jurisdiction - A geographic area of authority. 

Land Managers* - When this term appears, it refers inclusively to federal, state, tribal, 

and private land managers. 

Manage Fire Emissions# - Actions may be taken to manage fire emissions to minimize 

impacts on visibility, public health, and nuisance concerns. Some management actions 

include concepts such as the timing of ignitions for better dispersion and consideration of 

downwind air quality and visibility. It may also include consideration of factors related to 

the area to be burned such as the fuel moisture condition and other physical parameters. 

Manage fire emissions is analogous to smoke management. 

Mandatory Class I Area - An area set aside under the CAA to receive the most stringent 

protection from air quality degradation. Mandatory Class I Federal Areas are (1) 

international parks, (2) national wilderness areas and memorial parks larger than 5,000 

acres in size, (3) national parks that exceed 6,000 acres in size and which were in 

existence when the 1977 CAA amendments were enacted. The extent of a mandatory 

Class I Federal area includes subsequent changes in boundaries, such as park expansions. 

Modeling - The artificial simulation of some event or action that has quantifiable results. 

Mathematical expressions and computers are frequently used in modeling. 

National Ambient Air Quality Standards (NAAQS) - See Criteria Pollutants. 

National Environmental Policy Act (NEPA) - Establishes procedures that federal 

agencies must follow in making decisions on federal actions that may impact the 

environment. 

National Visibility Goal - Section 169A of the CAA sets forth a national goal for 

visibility which is the “prevention of any future, and the remedying of any existing, 

impairment of visibility in Class I areas which impairment results from manmade air 

pollution.” 

Natural Background Condition# - An estimate of the visibility conditions at each Federal 

Class I area that would exist in the absence of human-caused impairment. 

Natural Emissions Source Classification (“natural”)#

 - A categorization that designates 

which fire emissions can result in a natural reduction of visibility for each Federal Class I 
22 

area in the WRAP region. This classification includes natural and human-caused 

ignitions. 

Natural Ignition#

 - Fire/burn ignited due to a natural (i.e., non-human-caused) event, e.g., 

fire ignited by lightning or volcanic eruption. 

Natural Visibility Goal - The ultimate goal of the regional haze program is the absence of 

visibility impairment due to human-caused emissions. 

Non-Attainment Area (NAA) - An area identified by an air quality regulatory agency 

through ambient air monitoring (and designated by the EPA) that presently exceeds 

federal, state/tribe or local ambient air quality standards. See Attainment Area above. 

Non-Mandatory Class I Areas - Class I areas designated by states or tribes, but are not 

deemed mandatory by the CAA. As of January 2002, Class I areas designated by tribes 

include: Fort Peck Reservation in MT, Northern Cheyenne Reservation in MT, Flathead 

Reservation in MT, Yavapai-Apache Reservation in AZ (Class I status under litigation), 

and Spokane Reservation in WA. 

 

Nuisance Smoke - Unwanted smoke that does not exceed NAAQS primarily for 

particulate matter. 

Particulate Matter - Any liquid or solid particles. "Total suspended particulates" as used 

in air quality are those particles suspended in or falling through the atmosphere. They 

generally range in size from 0.1 to 100 microns. 

Plume Blight - Visual impairment of air quality that manifests itself as a coherent plume. 

PM10 - Particulate matter of aerodynamic diameter less than or equal to 10 micrometers. 

Emissions of PM10 are significant from fugitive dust, power plants, commercial boilers, 

metallurgical industries, mineral industries, forest and residential fires, and motor 

vehicles. 

PM2.5 - Particulate matter of aerodynamic diameter less than or equal to 2.5 micrometers. 

A measure of fine particles of particulate matter that comes from fuel combustion, 

agricultural burning, woodstoves, etc. 

 

Point Source - A fixed source of pollution. An example is the smoke stack of a coal-fired 

power plant or smelter. 

Prescribed Fire* - Any fire ignited by management actions to meet specific objectives, 

i.e., managed to achieve resource benefits. 

Rangeland#

 - Land on which the historic climax plant community is predominantly 

grasses, grass-like plants, forbs, or shrubs. Includes lands re-vegetated naturally or 

artificially when routine management of that vegetation is accomplished mainly through 
23 

manipulation of ecological principles. Rangeland includes natural grasslands, savannas, 

shrub lands, most deserts, tundra, alpine communities, coastal marshes and wet meadows 

(Natural Resources Conservation Service National Range and Pasture Handbook, 1997). 

Regional Haze - Visibility impairment caused by the cumulative air pollutant emissions 

from numerous sources over a wide geographic area. 

Smoke Effects* - The effects on visibility (both plume blight and regional haze), public 

nuisance, and the health-based NAAQS due to emissions from fire. 

Smoke Intrusion - Smoke from prescribed fire entering a designated area at unacceptable 

levels. 

Smoke Management Efforts - Programs, practices and techniques to minimize and/or 

reduce smoke emissions or impacts from fire. 

State Implementation Plan (SIP)# - See Implementation Plan. 

Suppression - A management action intended to protect identified values from a fire, 

extinguish a fire, or alter a fire’s direction of spread.

Transport Region State - One of nine states that make up the Grand Canyon Visibility 

Transport Region: Arizona, California, Colorado, Idaho, Nevada, New Mexico, Oregon, 

Utah, and Wyoming. 

Tribal Implementation Plan (TIP)#

 - See Implementation Plan. 

Visibility Impairment - Any humanly perceptible change in visibility (light extinction, 

visual range, contrast, coloration) from that which would have existed under natural 

conditions. 

Wildfire* - Any unwanted, non-structural fire. 

Wildfire Managed for Resource Objectives #

 - The management of naturally ignited fires, 

regardless of land type or ownership, to accomplish specific, pre-stated resource 

management objectives in predefined geographic areas with or without a plan in place. 

This term is considered to be analogous with the terms Wildland Fire Managed for 

Resource Benefits and Prescribed Natural Fire that are used in regulations and policies 

regarding federal wildlands. 

Wildland*- An area where development is generally limited to roads, railroads, power 

lines, and widely scattered structures. The land is not cultivated (i.e., the soil is disturbed 

less frequently than once in 10 years), is not fallow, and is not in the USDA Conservation 

Reserve Program (CRP). The land may be neglected altogether or managed for such 

purposes as wood or forage production, wildlife, recreation, wetlands, or protective plant 

cover (EPA Interim Air Quality Policy). The land is not “agricultural land” as 
24 

operationally defined above. Silvicultural land and rangelands (per the FEJF charge), 

woodlots, and private timberlands will be included with wildlands for the purposes of the 

FEJF work. 

Wildland Fire#

 - All types of fire (see definition of fire above), except fire on agricultural 

land. 

Wildland Fire Managed for Resource Benefits/Prescribed Natural Fire* - These terms 

both have current use in regulations and policies. They are considered to be synonymous 

and are used interchangeably in this work plan. These terms refer to the management of 

naturally ignited fires to accomplish specific, pre-stated resource management objectives 

in predefined geographic areas outlined in the fire management plan. Also referred to as 

Wildland Fire Use. 
WRAP ESMP Policy 10/15/02 25 

Appendix B 

Related Documents Listing

Regional Haze Rule 

Published in the Federal Register on July 1, 1999, 64 FR 35714. 

http://www.epa.gov/ttn/oarpg/t1/fr_notices/rhfedreg.pdf

Grand Canyon Visibility Transport Commission Report

Grand Canyon Visibility Transport Commission, Recommendations for Improving Western 

Vistas, Report to the U.S. EPA, June 10, 1996. 

http://www.wrapair.org Go to the GCVTC link.

EPA Interim Air Quality Policy on Wildland and Prescribed Fire 

U.S. EPA, Office of Air Quality Planning and Standards, Interim Air Quality Policy on Wildland 

and Prescribed Fires, April 23, 1998. 

http://www.epa.gov/ttn/oarpg/t1/memoranda/firefnl.pdf

AAQTF Recommendation on Air Quality Policy 

Agricultural Air Quality Task Force, Air Quality Policy on Agricultural Burning, 

Recommendation to the U.S. Department of Agriculture, November 10, 1999. 

http://fargo.nserl.purdue.edu/faca/Archives/2000/Policy/Burning%20Policy.htm

Tribal Authority Rule 

Published in the Federal Register on February 12, 1998, 63 FR 7253. 

http://www.epa.gov/fedrgstr/EPA-AIR/1998/February/Day-12/a3451.htm

WRAP Policy for Categorizing Fire Emissions 

Approved by the Western Regional Air Partnership, November 15, 2001. 

http://www.wrapair.org/commindex.htm Go to the FEJF Task Teams, then Natural Background.

Wildland Fire: Elements of a Basic Smoke Management Program Draft Report

Completed for the FEJF on July 10, 2001.

http://www.wrapair.org/commindex.htm Go to the FEJF Task Teams, then Basic Smoke 

Management.

Smoke Management Program Surveys 

http://www.wrapair.org/commindex.htm Go to the FEJF, then Basic Smoke Management. 

1) Wildland Smoke Management Program Survey, January 26, 2001 

2) Boulder Wildland Smoke Management Program Survey, February 2, 2001 

3) Agricultural Burning Smoke Management Program Survey, March 30, 2001 

4) An Assessment of Tribal Air Quality Data and Programs in the Western United States, The 

Institute for Tribal Environmental Professionals (ITEP), September 2001

Class I Area Map 

http://www.wrapair.org Go to About WRAP, then WRAP Boundaries and Regional Visibility 

Planning in the West. 
WRAP ESMP Policy 10/15/02 26 

Appendix C 

Enhanced Smoke Management Program: 

Implementation Guidance

C. 1 Regional Haze Rule Implementation Plan Process 

The Rule requires states to develop State Implementation 

Plans (SIPs) for addressing regional haze in the Nation’s 

156 mandatory Class I areas.49 Additionally, the Rule requires effective 

management of fire sources. 

In general, the SIP/TIP process includes the following steps: state/tribal agency technical 

analyses; identification of necessary emission reductions; identification of control 

strategies to achieve emission reductions; demonstration of reasonable further progress; 

submittal of SIP/TIP to EPA for consideration/approval; public review/comment; EPA 

approval of SIP/TIP; five-year state/tribe review for reasonable progress and SIP/TIP resubmittal. 

Under Section 309, states are required to, and tribes may, have a regional haze 

implementation plan that addresses the Class I areas of the Colorado Plateau (the 16 

Class I areas specified by the GCVTC) 50 submitted by December 31, 2003. The Rule 

stipulates that states must commit to implement all SIP measures from December 31, 

2003 through December 31, 2018.51 Further, all mandatory Class I areas in the GCVTC 

Transport Region, other than the Colorado Plateau 16, may be addressed in SIPs/TIPs by 

the 2008 Section 309 deadline.52

Under Section 308 states must, and tribes may, incorporate the requirements of the Rule 

into their implementation plans within 12 months of designation as PM2.5 attainment, or 

within three years after designation as PM2.5 non-attainment, but no later than December 

31, 2008. Under Section 308, all mandatory Class I areas, except those addressed under 

Section 309, will be addressed in the SIP/TIP submittal tied to the PM2.5 designation.53

 

49 The Rule is only applicable to mandatory Class I areas (see Appendix A & Appendix B for additional 

information on mandatory Class I areas). States/tribes in the WRAP region may utilize the WRAP ESMP 

Policy to protect visibility in non-mandatory Class I areas. 

50 The GCVTC Report specified 16 mandatory federal Class I areas on the Colorado Plateau that were 

adopted into Section 309 of the Regional Haze Rule. These 16 Class I areas are: Grand Canyon National 

Park, Sycamore Canyon Wilderness, Petrified Forest National Park, Mount Baldy Wilderness, San Pedro 

Parks Wilderness, Mesa Verde National Park, Weminuche Wilderness, Black Canyon of the Gunnison 

Wilderness, West Elk Wilderness, Maroon Bells Wilderness, Flat Tops Wilderness, Arches National Park, 

Canyonlands National Park, Capital Reef National Park, Bryce Canyon National Park, and Zion National 

Park. 64 FR 35770, §51.309 (b) (1). 

51 64 FR 35770, §51.309. EPA Region 9 has determined that implementation schedules may be negotiated 

as part of the SIP/TIP process and has previously accepted up to one year for implementation of SIP/TIP 

programs. 

52 64 FR 35773, §51.309. 

53 64 FR 35765, §51.308 (b) (1), (2).
WRAP ESMP Policy 10/15/02 27 

It is anticipated that the establishment of enhanced smoke management programs will be 

incorporated into the SIPs/TIPs submitted to EPA in order to meet the requirements of 

the Rule. Within the context of smoke management, it is recommended that states/tribes 

integrate their NAAQS and visibility SIP/TIP requirements. 

Under the WRAP ESMP Policy there are nine elements of an enhanced smoke 

management program that meet the requirements of the Rule. For each of the enhanced 

smoke management program elements, there are implementation examples listed to assist 

states/tribes in developing their enhanced smoke management programs. This is not 

meant to be an exhaustive list, and states/tribes may also want to review the Fire 

Emissions Joint Forum (FEJF) draft report on Wildland Basic Smoke Management 

Program Elements as well as the EPA Interim Policy and the AAQTF Recommendation 

on Air Quality Policy for additional suggestions.54 The level of effort each state/tribe 

would apply to the nine elements of the enhanced smoke management program needs to 

be based on a pre-determined process or metric developed collaboratively. 

C. 2 Elements of an Enhanced Smoke Management Program 

C.2.1. Element 1. Actions to Minimize Emissions from Fire

A wide range of opportunities to minimize emissions exists depending upon the fire 

source. Emission reduction techniques may be as simple as changing ignition timing to 

allow for more efficient combustion. Other techniques may include the use of mechanical 

means. Options to provide incentives and emission goals may also serve this purpose. 

C.2.1.1 Emission Reductions Techniques 

Under an enhanced smoke management program, provisions are made to account for 

emission reduction techniques that are utilized when burning. Documentation of emission 

reduction practices that were considered in the planning or implementation of burns also 

support annual emission goals and associated emissions tracking requirements. This 

documentation may be part of a burn plan or other data collection or reporting system 

that is used to meet annual emission goals and associated emissions tracking 

requirements as developed by the FEJF. 

• Reducing the fuel load to be burned can reduce emissions. This can be 

accomplished on forestland by not treating (no burning) portions of the unit, 

yarding, consolidating, or isolating non-merchantable material; providing public 

firewood access before the burn; finding off-site use for more of the wood before 

the burn; using chemicals; burning when non-target fuels have a high fuel 

moisture; using alternative mechanical treatments, and rapid mop-up. 

• In agriculture, emissions can be reduced by baling and removing some of the 

residue, spot burning only needed areas of the field, strip burning and backing 

fires. Emissions can also be reduced by moving the burning season into a different 

 

54 See Appendix B, Related Documents Listing. 
WRAP ESMP Policy 10/15/02 28 

time of the year if changes in fuel consumption or emissions factors can be 

achieved. 

• Land managers/owners should strive for the most efficient combustion possible. 

Vegetation should be dry and in a condition that will minimize the smoke emitted 

during combustion. When pile burning, material should be burned in dirt-free, 

not overly compressed, cured, and dry piles. Piled material should be covered if 

possible. Fires should be ignited so as to burn as rapidly as possible, in ways that 

shift the proportion of the burn from the smoldering phase to the flaming phase. 

Minimizing duff consumption and smoldering through fuel moisture 

considerations will reduce emissions as well. Land managers/owners should only 

burn those fuels essential to meet resource management objectives and burn piles 

when other burns are not feasible, such as in snow or rain.

Regulatory authorities and other interest groups may also use WRAP guidance 

information, such as its Alternatives to Burning document that is currently under 

development by the FEJF, as a reference for specific alternatives. Another resource is the 

Smoke Management Guide for Prescribed and Wildland Fire, 2001 Edition (in press).55

C.2.1.2 Burn Manager Qualification 

Another manner in which to reduce emissions is a burn manager qualification program 

that certifies the land manager/owner is knowledgeable of alternative burning practices 

and emission reduction techniques, and is capable of implementing them. Burn manager 

qualification programs already exist in most federal, state and tribal land management 

agencies. 

A certification and qualification process could be established by prescribing what training 

meets requirements, such as training provided by the National Wildfire Coordination 

Group (NWCG), and by implementing training seminars and other institutional 

opportunities for land managers/owners to gain the necessary skills and knowledge to 

implement proper smoke management techniques. Land manager/owner

certification/qualification programs may be similar to those required by federal land 

management agencies like those offered by the NWCG. For non-federal land 

managers/owners that cannot participate in federal sponsored training, states/tribes could 

develop their own certification processes and host training courses such as a “State 

Forestry Prescribed Fire Correspondence Course” or an “Interagency Basic Prescribed 

Fire Course”. 

In an enhanced smoke management program, burner qualifications might be required on 

permit applications and tracked by the regulatory agency. Burn size or emission output 

might be limited depending on the level of burner qualification. For example, a Level I 

qualified burner can burn up to abc acres/tons while a Level II qualified burner can burn 

up to cde acres/tons, and so on. 

 

55 Smoke Management Guide for Prescribed and Wildland Fire, 2001 Edition (in press), produced by the 

National Wildfire Coordinating Group (NWCG) Fire Use Working Team. 
WRAP ESMP Policy 10/15/02 29 

As examples, a few types of burner qualifications are listed below: 

• Satisfactory completion of the “State Forestry Prescribed Fire Correspondence 

Course” and direct experience in three prescribed burns prior to taking the 

course, or satisfactory completion of the “Interagency Basic Prescribed Fire 

Course” and direct experience in three prescribed burns before or after the 

course. 

• Completion of a NWCG or federal/state/tribe land manager equivalent course 

dedicated to smoke management or attendance at a state approved smoke 

management workshop. 

• Successful completion of a training program (which includes home study, 8-hour 

classroom session, and a written exam), documented practical experience in 

prescribed burning, and a signed agreement to conduct all burns in compliance 

with all applicable laws and ordinances, 

• Land management agencies and the state/tribe develop and present interagency 

training to promote understanding of the regulatory context and affects of air 

pollution, fire ecology, and smoke management. 

C.2.1.3 Incentives 

Providing incentives to landowners and land managers for practicing emission reduction 

techniques and utilizing alternatives to burning is yet another option for states/tribes to 

include in enhanced smoke management programs. This approach could be seen as 

addressing equity issues in that those who make efforts to reduce emissions are rewarded 

for their efforts. The reward to the landowner/land manager could be seen in terms of 

environmental gains as well as financial gain. The reward to communities could be seen 

in retaining property values, and maintaining economic development and tourist-related 

industries. 

Environmental win-win options may be that by decreasing emissions, a burner is given a 

higher priority when allocating burn days. Or, by utilizing alternatives, a higher priority 

is given to a burner when attempting to burn. Similarly, financial win-win options may be 

to decrease any assessed fees or burn costs when alternatives are used before burning. 

The system rewards those that take the extra time, effort and money to utilize emission 

reductions and alternatives. Those who either choose not to, or for land management 

constraints, cannot utilize emission reductions/alternatives, would pay more. 

Landowners/land managers could be afforded the opportunity to deal with other sources 

to negotiate emissions management strategies for financial gain that would result in a net 

emissions decrease. In January 2001, the EPA issued a policy document that provides 

information on discretionary economic incentive programs.56 In May 2002, the EPA 

provided additional guidance on voluntary and backstop approaches to emissions 

reduction in its Section 309 Annex to the Regional Haze Rule for stationary sources of 

sulfur dioxide.57 In an enhanced smoke management program, an incentive may be 

 

56 EPA Improving Air Quality with Economic Incentive Programs (EIP Guidance), January 2001. 57 67 FR 30418. 
WRAP ESMP Policy 10/15/02 30 

available if a landowner/land manager can reduce his/her emissions and gain financially 

from not only supplying a marketplace with raw materials, but also receiving payment for 

emissions not generated. 

C.2.1.4 Emissions Goal/Limit 

Another action that could be taken by regulatory authorities to minimize emissions is to 

establish an emissions goal or limit within portions of a state/tribe, the entire state/tribe or 

over a multi-state/tribe region. How to meet the goal or limit would be left to the 

discretion of the land managers/owners. Establishing such a goal or limit would 

encourage land managers/owners to seek alternative methods of burning and alternatives 

to burning so as to retain the ability to burn where no alternatives are available. 

C. 2.2 Element 2. Evaluation of Smoke Dispersion

A variety of tools and methods exist by which a land manager/owner could reduce smoke 

impacts over periods ranging from several hours to several days. Enhanced smoke 

management programs could contain the following criteria to support the dispersion 

estimation process. 

• States/tribes may provide or find ways to provide websites of current weather and 

fuels information (i.e., fuel moisture) specific to meet the needs of land 

managers/owners. Land managers/owners would utilize this information to time 

ignitions during periods of expected good smoke dispersion. 

• Acceptable weather and climatic conditions can be prescribed for burning in specific 

areas so as to avoid impacting Class I areas. A predefined set of weather elements 

would provide a degree of certainty as to when burning opportunities would be most 

likely to occur. Burning should be banned during periods when air stagnation 

advisories or air pollution alerts are in effect. 

 

• As described previously, a burner qualification and certification program could be 

established that includes advanced training on understanding the relationships 

between weather and smoke dispersion. Individuals who have greater knowledge and 

understanding of the factors affecting smoke behavior may make better decisions on 

when and when not to burn. 

• A more sophisticated and more comprehensive effort to evaluate smoke behavior 

would be to conduct smoke dispersion modeling in the planning and implementation 

process for burning. Dispersion modeling may be conducted by a state/tribal agency 

or other delegated regulatory authority. Such modeling results could be used as a 

screening approach to determine if there should be extra reason for concern about the 

proposed burn(s). This approach may assist in determining cumulative effects of 

multiple burns. 
WRAP ESMP Policy 10/15/02 31 

• Centralized decision-making of burn decisions with coordination among land 

managers/owners (either by source type or between sources) would require a more 

intensive effort of involvement by groups involved in burning. Land 

managers/owners would check-in with a centralized burn authority to receive 

information about other source activity prior to conducting a burn. 

• A rigorous, timely, centralized decision-making system established with the intent of 

providing "go/no-go" decisions affords a greater level of coordination that would rely 

on greater infrastructure and resources for support. Meteorologists and other 

specialists with knowledge of air quality, fire, weather and fuels interaction would 

provide services that direct where and when burning could occur.

C. 2. 3 Element 3. Alternatives to Fire

The WRAP through its FEJF has commissioned two reports on alternatives to burning 

that will aid states and tribes in addressing this element of the enhanced smoke 

management program. These reports show potential methodologies for regulatory entities 

and their affected stakeholders to assess the potential for alternative use on both 

wildlands and agricultural lands in their respective jurisdiction. These reports also 

provide information on barriers to the use of alternatives, which is a requirement of 

section 309 of the Rule. States/tribes could establish websites with information describing 

the alternatives. 

 

Land managers/owners may be required to assess the feasibility of using alternatives to 

fire where there are many competing sources or large amounts of burning occurring. 

This assessment could be based on established criteria, such as sustainability or potential 

fuel reduction. Burn plans and data systems could contain information that helps track the 

practice of using alternatives to fire. Emissions tracking systems58 and reasonable further 

progress assessments could use this information to validate landowner/land manager's 

implementation of alternative practices as an emissions reduction technique. 

Sources of smoke from geographic areas that continue to adversely affect a mandatory 

Class I area's 20 percent “worst” and “best” days, according to the Rule, may be required 

to implement measures that utilize alternatives to burning to the maximum extent feasible 

as a condition of further burning. Incentives could be identified wherein land owners/land 

managers have the opportunity to substitute emissions not produced in one area for 

emissions produced in another geographic area not affecting a Class I area's visibility as 

long as there is a net emissions decrease as a result of using the alternatives. 

Geographic areas with sustained sources of adverse smoke impacts in mandatory Class I 

areas may consider burn curtailments if programs to minimize emissions, impacts and 

alternatives to fire use do not provide the necessary tools to meet reasonable progress 

toward the natural visibility goal. Such actions could be considered on a fire source basis 

so as to not impair one source's ability to use fire because of the failure of another source 

type to take needed actions to meet the natural visibility goal. 

 

58 The WRAP’s FEJF is currently preparing a policy on emissions tracking systems to assist states/tribes. 
WRAP ESMP Policy 10/15/02 32 

C. 2. 4 Element 4. Public Notification of Burning

Public notification is a significant part of the CAA, and is inherent in the Rule. Public 

notification under an enhanced smoke management program should be at least what is 

required by EPA for a certifiable smoke management program,59 and may include extra 

activities, depending on location. Generally, regardless of what kind of smoke 

management program is in place, significant effort should be made to educate and notify 

the public about burning, its impacts on visibility as well as its benefits. 

Public notification includes public education and media relations, and consists of 

activities such as issuing notices through the local news media including name and phone 

number of person/agency, fuel type, expected time and date of burn, location of burn, and 

the expected plume direction, extent, and duration. Public notification of non-burning 

alternatives that have been considered for a project could also be included. 

Other means of notification may include the use of a website, public open houses or 

meetings, signs at burn sites, distribution of fact sheets that include information on smoke 

impacts, brochures, posters, notices, personal contact by phone or visit, or legal 

advertisements. It is a good practice to maintain a contact list of interested and affected 

publics, and make sure that notification of planned burns gets to everyone on that list. A 

plan for notifying the public could be part of the burn plan. 

Effective public involvement, notification, and education can decrease complaints and 

resistance to burning projects, as well as prepare the public to manage their activities 

around scheduled burns. Public notification and education activities can also increase the 

public’s faith in the different agencies and landowners, knowing that their health and 

welfare is being carefully considered in both planning and implementation. A welldeveloped public education and awareness program would not only serve the public but 

also fulfills a recommendation from the GCVTC. 

Public awareness and education activities may be conducted by states/tribes, land 

managers/owners, or in cooperation by all. Training and guidance in public notification 

techniques could be provided to land managers/owners not accustomed to conducting 

such work, i.e., non-federal land managers/owners. Program administrators might 

consider developing an in-state/tribe public notification process to assist the non-federal 

land managers/owners. Programs could strive to enhance non-federal land 

managers’/owners’ ability to involve public in planning by providing training and 

guidance, or open forums for disseminating information on planned burning activities 

that may affect visibility. If the public is involved in the planning of such activities 

regarding potential affects to them, there is less chance of resistance to the burn while it 

is in progress.

 

59 See Appendix B Related Documents Listing, EPA Interim Policy. 
WRAP ESMP Policy 10/15/02 33 

Finally, developing involvement by the community and participation by land 

managers/owners in the SIP/TIP and National Environmental Policy Act (NEPA) 

planning processes may be beneficial in developing common expectations. 

C. 2. 5 Element 5. Air Quality Monitoring

Monitoring of smoke impacts may be a very sophisticated effort using sampling 

equipment and extensive modeling or it may be as simple as creating a log of smoke 

behavior. 

Minimal procedures would be most likely in areas of little burn activity or when farther 

away from Class I areas. On-site record keeping with subsequent submittal to the 

state/tribe regulatory authority should be substantive enough for use in analysis of 

reasonable further progress tracking or emission reduction programs.

As burning activity increases, states/tribes and land owners/managers could consider 

conducting a more widespread and comprehensive monitoring program. The use of 

cameras, satellite imagery and aerial monitoring to track and document smoke movement 

could be considered. The use of IMPROVE monitored data may have to be supplemented 

by air quality monitoring outside of Class I areas to track smoke movement. 

Also, using visitor surveys in Class I areas regarding visibility impairment perceived 

during their stay may be a way of generating subjective assessments of smoke impacts. 

Such information would only be used to provide further validation of impacts, as relying 

on surveys alone would be too subjective for states/tribes to administer reasonable smoke 

management programs. 

C. 2. 6 Element 6. Surveillance and Enforcement

Good communication between regulators, land managers/owners and the public can 

significantly reduce the need for surveillance and enforcement. An atmosphere of trust 

and cooperation between regulators and land managers/owners can go a long way toward 

facilitating emissions reductions and compliance with air quality regulations. 

Four primary methods under which surveillance and enforcement activities may occur 

are: 

• Voluntary (Land manager/owner self-enforcement) 

• Source sector regulator (e.g., Agricultural Burn Manager, Smoke Management 

Meteorologist) 

• State/tribe oversight 

• Centralized regulatory authority (state or tribe) 

Criteria and activities described below may be applicable for use in any of the four 

methods. Some of the criteria can, obviously, only be enforced by a body that has legal 

standing to do so. Whichever of the four methods a state/tribe may choose to implement 

would be dependent upon the severity of the visibility impacts that are being addressed. 
WRAP ESMP Policy 10/15/02 34 

If states/tribes have regulations in place that govern smoke impacts, public complaints 

can serve to monitor compliance. Such regulations should define criteria for establishing 

these smoke impacts. The number and location of public complaints may be used to 

monitor air quality impacts of fires. The number of complaints may not necessarily be a 

trigger, rather the nature of the complaints and external verification of circumstances 

leading to the complaints. In some cases, smoke regulations may apply only to noncertified burning. In such cases certified burners cannot be shut down for complaints 

related to visibility, but can be shut down for a threat to health or safety. 

Some criteria for taking action on smoke impacting visibility include: 

• Is the visibility impact occasional or constant? 

• Is the use of property affected? 

• What are the economic impacts of both burning and not burning? 

• Is the location of the impact within or outside of a Class I area? 

• What is the duration of the impairment? 

• What is the number of people affected? 

• How many complaints have been received? 

• Was the burn conducted in compliance with applicable regulations? 

• Has the visibility impact been mitigated to the extent practicable? 

• Is the public health threatened? 

• Is the impact a result of poor planning or of something that could not be 

anticipated? 

Criteria of performance standards in an enhanced smoke management program must be 

stated clearly. Methods for detecting non-compliance could also be defined. Some 

criteria or standards might include: 

• Numerical standards for optical data at specific Class I areas (e.g., deciviews) 

• NAAQS 

• Comparison with photos taken of certain pre-determined visibility conditions 

(most impaired, least impaired days) 

Accordingly, some methods for detecting compliance might include: 

• IMPROVE sites 

• Photo points 

• NAAQS ambient air monitors 

If performance standards are established in code, random audits and inspections can 

provide assistance with compliance. Unannounced burn inspections and burn report 

audits, including smoke dispersion information, are means of ensuring compliance with 

air quality regulations. Aerial observations are another surveillance method. 

If no visibility impact-related regulations are in place, violation of NAAQS or violation 

of other codified permit conditions or authorizations might trigger enforcement actions. 

Enforcement actions must be based on established statute and regulation, and must be 

applied equitably to all land managers/owners. Depending on state/tribe needs and 
WRAP ESMP Policy 10/15/02 35 

compliance history, a written report or warning may be issued on the first instance of 

violation, while subsequent observed violations result in appropriate legal action. 

Example enforcement actions may include: 

• 5-day moratorium on ignitions 

• Civil/criminal penalties, depending on how regulations are written 

• Burn shutdown/mop-up 

• Notice of violation/compliance order 

• Liability for cost of suppression or damages 

• Revocation of permit 

• Felony punishment for willful or intentional violation 

• Misdemeanor for careless violation 

C. 2. 7 Element 7. Program Evaluation

Enhanced smoke management programs need to be reviewed on a periodic basis for their 

effectiveness by the regulatory authority and affected stakeholders. It is incumbent upon 

the state/tribe to submit progress reports to EPA describing how well the enhanced smoke 

management program is being implemented as part of meeting reasonable further 

progress requirements. Formal periodic progress report intervals could coincide with time 

intervals used to evaluate reasonable progress. The Rule requires progress reports every 

five years.60 However, shorter review and evaluation time periods would better determine 

if enhanced smoke management programs are effective. 

Generally, daily interaction between land managers/owners and program administrators 

can provide a continuous means of program evaluation, but a formal method could be in 

place to document periodic evaluations. Annual evaluations of the overall smoke 

management program will provide the information needed for periodic reports. Each 

element of the enhanced smoke management program should consider evaluating: 

• Implementation 

• Compliance and enforcement 

• Sections needing clarification or improvement 

• Progress towards goals 

• Recommendation for revisions 

• Scientific advancements (modeling or other technological needs) 

These annual evaluations could include, but not be limited to: 

• An accounting of progress toward defined visibility improvement/impact 

reduction goals 

• An accounting of progress toward emission reduction goals 

• Review of project burning for the next year, as well as additional out-year 

planning 

• Regional information, considering visibility impacts to and from adjoining 

states/tribes 

 

60 64 FR 35768, §51.308 (g) and 35772, §51.309 (d) (10). 
WRAP ESMP Policy 10/15/02 36 

• Burn activity summaries 

• Burning restrictions or air quality alerts 

• Significant smoke intrusions or visibility impacts 

• Summaries of IMPROVE and other monitored air quality data 

• Emission inventory summaries 

• Information tracking summaries 

• Smoke complaint summaries 

• Discussion of alternatives to burning 

In an enhanced smoke management program, federal land managers responsible for 

protecting air quality related values in Class I areas should be given the opportunity to 

provide input to annual program evaluations. 

Where MOUs or other agreements govern smoke management programs, an annual 

meeting should be held where members share successes and failures, data is summarized 

and the program is evaluated. In cases where review criteria are established in state code, 

performance can be compared against standards. Permit files may be kept for a period of 

time, including complaint files, and statistics generated to evaluate trends in the program. 

C. 2. 8 Element 8. Burn Authorization 

Burn authorization requirements are expected to vary depending upon the amount of 

burning that is occurring, the fire source types that are conducting the burning, and the 

degree of impairment that exists or may be expected to occur as a result of the burning. 

The proximity of non-attainment areas may also have a bearing on the complexity of the 

burn authorization procedure that should be implemented. Four broad levels of stringency 

may be considered in the development and adoption of an enhanced smoke management 

program. 

• Establish a permit-by-rule system 

• Establish a burn permitting system by source sector or a coalition of source 

sectors 

• Establish a centralized burn authority 

• Establish a regional burn authority 

Establishment of any of these authorization situations would also entail the development 

of coordination procedures described in (9) below. 

C.2.8.1 Permit by Rule 

The AAQTF Recommendation on Air Quality Policy describes a process in which a set 

of requirements are established under which burning may take place. These requirements 

may include acreage, time of year, time of day and meteorological factors.61 A written 

permit may or may not be required. As long as the conditions are met, then burning may 

occur. There is no daily decision-making by a coordinating authority in this scenario. 

 

61 AAQTF Recommendation on Air Quality Policy, p.9. 
WRAP ESMP Policy 10/15/02 37 

Such a system may be applicable for any fire source type in geographic areas of low fire 

use. This system should, however, still allow for the collection of enough information by 

an appropriate regulatory authority so that source activity and emissions may be tracked. 

C.2.8.2 Burn Permitting System 

A burn permitting system that is established by fire source type would include a local 

burn manager and/or state, tribe, local agency, whose responsibility is to develop the 

conditions under which burning may occur and then ensure that burning occurs within the 

requirements that are established. The elements described in this WRAP ESMP Policy 

would be implemented by the burn manager to ensure that visibility in Class I areas is 

protected. 

C.2.8.3 Centralized Burn Authority 

A more intensive level of smoke management would involve the creation of a centralized 

authority at the state, tribal or local level that provides daily coordination and approval of 

burns if significant state/tribe-wide burning is occurring. The centralized authority may 

be responsible for activities of one particular source type or a combination of sources. 

This type of program could include the detailed use of meteorological information, burn 

information and a permitting system to avoid cumulative impacts of smoke from a variety 

of burns. 

C.2.8.4 Regional Burn Authority 

Establishment of a regional burn authority may be required if there are continued and 

extensive inter-state impacts from burning. States/tribes would agree to have oversight of 

burning by an authority that equitably considers burning opportunities for all source types 

while addressing the Class I area impacts over broad areas. A regional burn authority 

would likely, in most cases, be working with the most severe and persistent problems. 

C. 2. 9 Element 9. Regional Coordination

Coordination of burning activity is critical to avoiding cumulative visibility impacts 

within and across source types. Coordination may range from a passive mode of 

information sharing between land managers/owners and/or the public to a more complex, 

active coordination in which burn decisions are altered based on other activities that are 

occurring or have recently occurred. 

Coordination can occur at locations that reflect the affected level of concern. When burns 

are located near Class I areas or non-attainment areas, coordination will be carried out at 

a level that is appropriate. If burns are located adjacent to state/tribe boundaries, 

coordination will occur appropriate to the smoke transport/emission path and quantity. 
WRAP ESMP Policy 10/15/02 38 

A common mode of coordination regardless of the complexity and magnitude of burning 

would be information sharing via use of the web. Operationally, certain information 

needs to be established and updated as needed. This would include: 

• Burn information (size, location, ignition date, etc.) 

• Names and locations of sensitive receptors and/or special protection zones; 

sensitive receptors should include sensitive populations 

• Locations of monitors (state, tribe, EPA or local) 

• Database of known significant users of fire (name, phone number) 

• Identification of airsheds or air administered units 

• Possible identification of Clean Air Corridors 

• Updateable database of non-attainment and maintenance areas for criteria 

pollutants of concern 

• Identification of the centralized burn authority that maintains oversight 

A minimal level of coordination would include the use of websites to post burn activity. 

This passive mode of coordination would be used regardless of the burn authorization 

method that is in place in a particular geographic area. Land managers/owners and 

regulators could use this information to encourage and promote voluntary coordination 

among land managers/owners. Burn locations and weather conditions may be posted or 

linked at a common webpage or series of webpages. 

C.2.9.1 Source Sector Authority Coordination 

A more advanced coordination concept is that of using burn managers or smoke 

coordination centers to actively time burning to avoid cumulative smoke impacts from 

burns within a source sector. In addition to creating awareness of other sectors' burning 

via tracking information on the web, radio or phone communications would be used to 

distribute that burning information to land managers/owners. 

A step further in this process is active management of burning with coordination 

occurring between burn managers of different source types. Considerations that would 

be taken into account by the burn managers are parameters such as special weather 

conditions needed for a particular burn, fire safety considerations, etc. These 

considerations can be identified in the early periods of burn planning so that all parties 

are aware of the rationale behind burn decisions. 

C.2.9.2 Centralized Authority Coordination 

A centralized coordination authority within a state/tribe provides for a greater level of 

control of smoke production and reduction of impacts. In this scenario, potential 

state/tribe-wide impacts may be better managed and problems avoided than is the case 

with more fragmented coordination points. Central authorities for each source type 

would coordinate activities or one central authority would coordinate activities across all 

source types. In most cases this coordination would occur through a statewide 

coordination center that has access to information from all burning sources. Such a 

coordination center would also be more likely to have sophisticated meteorological, air 
WRAP ESMP Policy 10/15/02 39 

quality, modeling and fire behavior and effects expertise upon which decisions would be 

made. 

C.2.9.3 Regional (Multi-State/Tribe) Coordination 

Burning that creates inter-jurisdictional impacts may require the establishment and use of 

multi-state/tribal coordination information procedures. If states’/tribes’ Class I areas are 

consistently and measurably being impacted by smoke from outside of their own 

boundaries, then more information sharing may be needed on day-to-day burning 

activities. State/tribe centralized coordination centers would share information and 

resources to limit cumulative impacts from external sources as well as from those within 

its own boundaries. 

 

Each state’s/tribe’s central coordination center would prioritize burns in areas that would 

be most likely to create cross-jurisdictional impacts. On a regional basis, acres or 

emissions may be limited by each state’s/tribe’s burn authority to minimize air quality 

impacts in neighboring areas. Regional meteorological and air quality information would 

be shared by coordination centers, with the result being regional approval and real-time 

tracking of burns and their smoke impacts. 

A segment of fires that are considered to be natural under the WRAP Fire Categorization 

Policy may best be suited for regional coordination opportunities. Such fires are more 

likely to be of longer duration and have the greater potential for generating regional haze. 

Coordination in this case may range from monitoring smoke from such fires and 

reporting impacts to nearby states/tribes, to limiting other burning until the smoke from 

the natural fires has abated. 

Methods for this inter-jurisdiction and regional coordination will need to be developed. 

The development process should be a collaborative one, involving state, tribal, local and 

federal agencies, and private parties. Entities to be involved in this process could include 

WRAP, the Western States Air Resources Council (WESTAR), the National Tribal 

Environmental Council (NTEC), the Wildfire Leadership Council, the Western States 

Fire Managers, and national/regional agricultural organizations. 

C. 3 Responsibilities Under an Enhanced Smoke Management Program 

Throughout all the enhanced smoke management program elements outlined in this 

Policy, it is assumed that the regulatory authority (i.e., state, tribe, or EPA on behalf of 

the tribe) has the oversight for the enhanced smoke management program through its 

implementation plan, although it may choose to delegate implementation to another 

entity, e.g., county, municipality, fire source sector representative or other nongovernmental organization. 

It is the regulatory authority’s responsibility to ensure that the mechanisms and 

infrastructure are in place to implement the enhanced smoke management program. The 

state/tribe is responsible to track emissions and determine the amount of the contribution 
WRAP ESMP Policy 10/15/02 40 

to visibility impairment in Class I areas. It is also incumbent upon the regulatory 

authority to develop a SIP/TIP that is consistent with Section 118 of the CAA pertaining 

to equitable treatment of federal activities.62 Finally, failure of the regulatory authority to 

develop appropriate and necessary oversight and responsibilities may result in EPA's 

disapproval of the regional haze SIP/TIP.

It is the land manager’s/owner’s responsibility to meet the enhanced smoke management 

program requirements. The land manager/owner needs to ensure that data and 

information submitted to the regulatory authority are accurate, timely, and complete. In 

some instances this may be no more onerous than a form faxed by the land 

manager/owner to the regulatory authority at the end of the year; in others, extensive 

information on a daily basis regarding planned and accomplished burning will be 

required. 

C.4 Funding Mechanisms for Enhanced Smoke Management Programs 

Funding for enhanced smoke management programs can come from many possible 

sources. Further, funding mechanisms will depend on the magnitude or complexity of the 

enhanced smoke management program needed. The following is a list of possible 

methods for funding enhanced smoke management programs: 

A. Funds obtained from users of prescribed fire. 

a. Memorandum of Understanding (MOU)/Memorandum of Agreement 

(MOA)/Consortium Funds 

• Each member/signatory pays an annual membership fee and there is an 

additional per acre fee for accomplished burns. 

b. Fees 

• Permit Fees 

• Emissions-based Fees 

• Acreage-based Fees 

B. Funds Obtained from Users of Class I Areas 

C. Grants and/or Appropriated Funding 

• A combination of many sources including EPA grants, state/tribe, city and 

county governments, fire protection assessments, property taxes. 

• General revenue program/appropriated funds received from a legislative 

body. 

D. Provision of Resources 

• Fire source sector provides personnel or other resources to aid or manage 

the enhanced smoke management program in lieu of direct permit 

payments to defray overall costs of the enhanced smoke management 

program.

 

62 Clean Air Act §118 (a).