# ASSESSING STATUS OF INCORPORATING

SMOKE EFFECTS INTO FIRE PLANNING AND OPERATIONS

Prepared by:

Entranco

345 E. Mountain Avenue

Fort Collins, CO 80524

In association with:

Core Environmental Consulting

Forest Stewardship Concepts, Ltd.

# i Contents

Tables ......................................................................................................................... ........i

Figures ........................................................................................................................ ........i

1.0 Introduction ............................................................................................................... ..1

2.0 Methods.................................................................................................................... ...3

2.1 Programmatic Plans ..................................................................................................5

2.2 Operational Plans .....................................................................................................6

2.3 Guidance Documents...............................................................................................7

3.0 Findings ................................................................................................................... ....8

3.1 Programmatic Plans ..................................................................................................9

3.2 Operational Plans ...................................................................................................12

3.3 Guidance Documents.............................................................................................24

4.0 Summary.................................................................................................................... 28

Tables

Table 1. Land Managers Requested to Prov ide Fire/Burn Plans for the Project.....................3

Table 2. Affirmative Criterion Responses for Programmatic Plans for Prescribed Fire ........10

Table 3. Affirmative Criterion Responses for Programmatic Plans for WFU .......................10

Table 4. Affirmative Criterion Responses for Operational Plans for Prescribed Fire ...........12

Table 5. Affirmative Criterion Responses for Operational Plans for WFU ..........................16

Table 6. Affirmative Criterion Responses for Operational Plans for WFSA.........................17

Table 7. Affirmative Criterion Responses fo r Implementation of Prescribed Fire................19

Table 8. Affirmative Criterion Responses for Implementation of WFU ..............................22

Table 9. Affirmative Criterion Responses for Guidance Documents ..................................24

Figures

Figure 1. Results from Operational Plans for Prescribed Fire.............................................13

Figure 2. Results from Implem entation of Prescribed Fire .................................................21

Figure 3. Results from Evaluation of Guidance Documents...............................................24

Appendices

Appendix A. List of Plans Reviewed for Project

Appendix B. Guidance Documents Reviewed

Appendix C. Evaluation Results and Review Comments for Guidance Documents

# 1 State Governments in WRAP 

# 1.0 Introduction

The Western Governor's Association (WGA), in conjunction with federal, state, tribal, and

local entities throughout the west, formed the Western Regional Air Partnership (WRAP).

The purpose of WRAP is to build on the work of the Grand Canyon Visibility Transport

Commission (GCVTC) in developing and planning programs that can reduce visibilityimpairing emissions and improve visibility throughout the West. WRAP can recommend

regional approaches to improving air quality and reducing regional haze, but the authority

and responsibility for implementing any or all WRAP recommendations lies with individual

states, tribal entities, and local governments.

WRAP has a principal planning group, the Initiatives Oversight Committee (IOC), and a

principal technical group, the Technical O versight Committee (TOC). Under the IOC and

TOC are several forums that develop technical and policy options for specific areas of

interest to WRAP. One such forum is the Fire Emissions Joint Forum (FEJF), which reports to

both the IOC and TOC. The FEJF is tasked w ith making recommendations on strategies and

methods to manage emissions from prescribed fi re. The Smoke Effects Task Team is part of

the FEJF and is the sponsoring agent for the project

described in this report.

Smoke from fires produces a variety of air pollutants.

The predominant sources of smoke in the region

typically are from fires for prescribed burns, natural

wildland fires and agricultural burns. GCVTC

recognized the need to addr ess air quality effects from

prescribed fire and managed natural fire (or wildland

fire use [WFU]) because of increased use of prescribed

fire throughout the West. GCVTC concluded that fire

planning efforts should consider more thoroughly the

effects of smoke on visibility, public nuisance, and the

National Ambient Air Quality Standards (NAAQS)

(GCVTC, 1996), and also as required by the

Environmental Protection Agency’s (EPA) Regional

Haze Rule (EPA, 1999).

The following sections describe a project that is one

step in investigating the existing level of c onsideration given to smoke impacts in fire

planning documents, and this was the overal l purpose of the project. The project involved

gathering and reviewing a number of different types of fire-related documents from a

variety of agencies and tribal entities that pe rform or authorize controlled or natural burns,

to assess the emphasis placed on smoke impacts. The project had several objectives,

including:

• assess the status of federal, state, local, tribal, and private prescribed fire programs in

considering smoke effects from prescribed fires and WFUs in strategic planning

documents, known as programmatic plans,

• evaluate whether non-burning alternatives were considered by land managers in

programmatic plans,

# 2 Steps in Federal Fire Planning Processes 

# • assess the status of federal, state, local, tribal, and private prescribed fire programs in

considering smoke effects from prescribed fires and WFUs in operational plans,

including use of the Wildland Fire Situation Analysis (WFSA) by federal land managers,

• evaluate the smoke effects from implementati on of operational plans for prescribed fires

and WFUs, including use of WFSA by federal land managers,

• identify and summarize relevant guidance doc uments for agencies on consideration of

air quality effects from prescribed fire and WFU in programmatic and operational plans,

and

• identify and summarize relevant guidance doc uments for use of the WFSA process for

assessing air quality effects for wildfire and WFU incidents.

Prescribed Fire is defined as a management-ig nited wildland fire that burns under specified

conditions where the fire is confined to a predetermined area and produces the fire

behavior and fire characteristics required to attain planned fire treatment and resource

management objectives.

WFU refers to the management of naturally-ign ited fires to accomplish specific, pre-stated

resource management objectives in predefined geographic areas that are outlined in the

governing programmatic plan. Prescribed Natu ral Fire is another term often used to

describe WFU, and both terms refer to the same concepts. WFU operational plans are only

developed by Federal Land Management agen cies that have approved Wildland Fire

Management Plans. WFU does not apply to state or county agencies, private land managers

or tribal entities.

WFSA is a decision-making process jointly es tablished by the Federal Land Managers that

evaluates alternative management strategies re lated to firefighter safety, environmental,

social, economic, political, and resource mana gement objectives. As such, WFSA plans

only apply to wildland fires on federally mana ged lands. Consequently, WFSA plans were

not received from state, county, private or tribal entities.

The documents of interest fit into three general categories: programmatic plans,

operational plans, and guidance documents. The discussion of methodology and results of

the project is broken out by these categories.

General

Management

Planning

Fire Management

Plan ( Environmental

Assessment)



# Burn Plan Forest Land

Management Plan

Fire Management

Plan ( Environmental

Assessment)



# Burn Plan Resource

Management Plan

(Environmental Impact

Statement)



# Phase 1 Analysis

(Environmental

Assessment)



# Fire Management

Plan Project (Environmental

Assessment) 

# Bureau of Land

Management Forest Service National Park

Service

Programmatic

Programmatic

Operational Level of Plan

# 3 

# 2.0 Methods

The overall approach within the project was to gather various burn plans/documents from

designated agencies and tribal entities, and assess the plans/documents relative to specific

project evaluation criteria. The results from the assessments were recorded, tabulated, and

summarized. One directive for the project was to summarize results to maintain individual

agency anonymity.

A sample of various recent fire planning a nd execution documents prepared by a number

of different agencies (or other entities) that use fire/burning for resource management was

the goal of the document collection task. The sample size and contacts were predetermined

by FEJF before the project began. Table 1 is a summary of the land managers and agencies

that were contacted for the project. The list in cludes tribal entities, federal, local, private,

state, and tribal land managers. It must be emphasized that most of the plans received and

reviewed for the project (excluding guidance documents) were selected by the resource

agencies in Table 1, not the project team.

Each land manager was requested to provide examples of the following types of

documents:

• Programmatic plans

 

# Programmatic for prescribed fire

 

# Programmatic for WFU

• Operational plans

 

# Operational for prescribed fire

 

# Implementation of prescribed fire

 

# Operational for WFU

 

# Implementation of WFU

 

# WFSA documentation

• Guidance documents, air quality regulations, and statutes supporting plan preparation

It should be noted that this plan-naming convention is not universal for all of the land

managers; the plan names are most applicab le to federal processes. Not every land

manager uses or is required to use each of th e named plan types. Therefore, each plan type

was not necessarily available from every land manager. In addition, th ere is considerable

variability in complexity within a category of plans, depending on the goals, objectives,

and regulatory requirements of the land manager. Where necessary, a specific fire/burn

document without an obvious category was design ated as the closest matching plan type. A

comprehensive list of the burn plans reviewed is presented in Appendix A.

The plans were assessed by comparing the conten ts of the plans/documents against a set of

evaluation criteria. The evaluation criteria were developed by FEJF. Different types of plans

had different evaluation criteria. The criteria by which each fire/burn plan was evaluated

are presented below. Note that some of th e criteria have multiple conditions joined by

“and.” In these cases, all criteria conditions must be true for an affirmative response to that

criterion. With an “or” or “e.g.,” a single tr ue condition elicits an affirmative response. The

results for each evaluation criterion were reco rded on data forms. The data were then

transferred to an electronic database develope d specifically to contain project information,

to facilitate analysis of the results. The databa se enabled the project team to view data in

# 4 

# both specific and anonymous terms as the projec t progressed. The database was also used

to track the progress of receipt and review of the various plans.



# Table 1. Land Managers Requested to Provide Fire/Burn Plans for the Project

Type Agency Region

Bureau of Indian Affairs

Alaska

Arizona

Colorado

Idaho

Montana

New Mexico

Nevada

Oregon

Utah Bureau of Land Management

Wyoming

Department of Defense

Alaska

Intermountain

Midwest National Park Service

Pacific West

1

2 U.S. Fish and Wildlife Service

6

1

2

3

4

5 Federal

U.S. Forest Service

6

Bernalillo County, New Mexico

Boulder County, Colorado

Columbia County, Washington

Jefferson County, Oregon

Missoula County, Montana

Pinal County, Arizona Local

San Joaquin Valley, California

The Nature Conservancy

Plum Creek Timber Private

USDA Natural Resources Conservation Service

Colorado Division of Forestry

Montana Division of Forestry

Nevada Division of Forestry

State of Arizona Agriculture

State of California Agriculture

State of Idaho Agriculture

State of Montana Agriculture

State of Oregon Agriculture State

State of Washington Agriculture

Institute for Tribal Environmental Professionals Tribal Intertribal Timber Council

# 5 

# 2.1 Programmatic Plans

Programmatic plans are strategic land managem ent plans for prescribed fire and/or WFU

that include fuel treatment activities at a prog ram level. They usually cover a 1- to 20-year

planning period for a specific management area.

Examples of federal programmatic plans are Resource Management Plans or Fire

Management Plans for a specific land managemen t unit (e.g., a BLM district or national

forest). Comparable planning documents ar e uncommon outside federal agencies for

burning that occurs on private lands, tribal la nds or under open burning permits issued to

the general public. Nevertheless, example programmatic documents that had been

prepared within the past 3 years (or their equivalent) were requested from all of the

contacts listed in Table 1.

The programmatic plans were evaluated for two ty pes of beneficial fire use: prescribed fire

and WFU. Different evaluation criteria were used for prescribed fire and WFU.

2.1.1 Programmatic Plans for Prescribed Fire

The evaluation criteria for programmatic prescribed fire plans were:

1. Was there evaluation of cumulative effect s of smoke (qualitative and/or quantitative

analysis)?

2. Was there evaluation of potential intrusions to Class I or other identified smokesensitive areas?

3. Was there identification and determination of compliance with applicable laws and

relevant policies?

4. Any identification of smoke management techniques to reduce fire emissions and

mitigate smoke impacts?

5. Analysis of recent historic (within 10 years ) and projected (for life of plan) annual or

seasonal emissions from prescribed fire and WFU?

6. Identification of non-burning alternatives that were analyzed or utilized as a fuel

treatment method?

7. Completion of General Conformity determination for projects in nonattainment

areas?

2.1.2 Programmatic Plans for Wildland Fire Use

The evaluation criteria for programmatic WFU plans were:

1. Was there consideration of cumulative effects of smoke (qualitative and/or

quantitative analysis)?

2. Was there assessment of potential intrusions to Class I or other identified smokesensitive areas?

3. Are any burn decisions tied to specific air quality criteria?

# 6 

# 4. Identification of non-burning alternatives that were analyzed or utilized as a fuel

treatment method?



# 2.2 Operational Plans

The operational plan category contains two general groups of documents: pre-burn and

post-burn. The true “operational” plans in this category are the pre-burn plans that describe

in advance how beneficial fire is planned fo r a specific land unit. The post-burn plans in

this category consist of the implementation of a pre-burn operational plan and are referred

to as implemented plans below.

Operational plans for this project are relevant for prescribed fire, WFU, and WFSA. Once

again, this is primarily federal terminolo gy, however, most non-federal land managers have

an equivalent pre-burn operational document. Most planned beneficial fire, whether it

occurs under a simple burning permit or a complex program to accomplish a large

wildland fire, has some type of operational plan. For the purposes of this survey, a recent

operational plan was requested from the sources listed in Table 1. In the case of

implemented plans, any available documenta tion on the results of the fire was requested,

as formal post-burn reports proved to be uncommon.

2.2.1 Operational Plans for Prescribed Fire, WFU and WFSA

To identify and assess federal, state and local-level operational plans with respect to air

quality effects from prescribed fire, WFU a nd WFSA smoke effects, available documents

were gathered and evaluated. The documents were gathered through telephone requests

from contacts specified by FEJF at the beginning of the project (Table 1). The evaluation

criteria for operational plans for prescribed fire, WFU, and WFSA were as follows:

1. Did the document estimate emissions of visi bility-impairing air pollutants and their

effects on visibility (regional haze and plume blight), NAAQS, and nuisance?

2. Did the document discuss actions to be ta ken to minimize fire emissions and/or

smoke impacts?

3. Was the use of smoke dispersion evaluation or criteria discussed in the document?

4. Did the document discuss the use of public notification procedures?

5. Did the document discuss the use of air quality monitoring?

6. Were predetermined “trigger points” for designating air quality impact discussed in

the document?

7. Did the document discuss predetermined contingency actions to be taken when air

quality impacts occurred?

8. Was planned cooperation with downwind re ceptors, regulatory agencies, and

compliance with their laws, rules, and guidance discussed in the document?

9. Was planned coordination with adjacent and downwind land managers discussed

in the document?

# 7 

# 10. For projects in nonattainment areas, did the document discuss completion of the

General Conformity determination? (Note: This criterion is for prescribed fire plans

only.)

In reviewing these documents, an affirmative evaluation was given if the criterion topic was

mentioned or discussed, even if only briefly. The project team did not attempt to assess the

thoroughness or adequacy of the criterion di scussion, only its presence. If the criterion

topic was not found, a negative evaluation was given. In some cases, a criterion may not be

applicable (e.g., Criterion 10) for a plan.

2.2.2 Implementation of Prescribed Fire and WFU

Implementation of WFSAs did not seem to be documented typically and was consequently

not available for evaluation under the project. Therefore, the evaluation criteria for

implemented prescribed fire a nd WFU plans were as follows.

1. Were smoke effects avoided?

2. Were unfavorable smoke effects experienced?

3. Was the frequency of verified public nuisance complaints reported in the

document?

4. Were air quality regulatory citations documented?

5. Were contacts made with downwind recept ors, regulatory agencies, and land

managers according to predetermined plans?

6. Were all of the smoke management elements of the burn plan implemented?

7. Were any contingency actions taken as a result of air quality impacts?

8. Were public notification and exposure reduction procedures followed?

9. Was compliance met with all applicable air quality laws, rules, and guidance?

10. Was the air quality monitoring plan followed?

11. Were actions taken to avoid smoke impacts and effects?

In reviewing these documents, an affirmative evaluation was given if the criterion topic was

mentioned, even if only briefly. If the criterion topic was not found, a negative evaluation

was given. In some cases, a criterion may not be applicable (e.g., Criterion 10) for a plan. It

must be emphasized that formal implementa tion reports seem to be uncommon, so the

“implementation plan” often consisted of fie ld notes, participant summaries, etc. The

project team had no way to verify independently the completeness of the data provided for

review, rather we relied on the d iligence of the providing agency.



# 2.3 Guidance Documents

To identify and assess federal, state, and loca l-level guidance with respect to air quality

effects of prescribed fire and WFU smoke e ffects, available guidance documents were

# 8 

# gathered and evaluated. An initial set of guid ance documents to be reviewed was specified

by FEJF at the beginning of the project, but other guidance was identified and added by the

project team. The documents included smoke management plans from throughout the

West, local open burning permit requiremen ts, national smoke management guidance and

training materials, agricultural burning smoke management program documents from

Oregon and Washington, as well as federal a nd state and local air quality regulations. The

documents were gathered from the Internet, from personal libraries, by telephone requests

and from local libraries. These documents were selected with the intent of assessing

reporting requirements for smoke effects from a representative set of air quality regulations

as well as land manager guidance documents. The guidance documents reviewed are listed

in Appendix B.

The evaluation criteria used for guid ance documents were as follows:

1. Did the document provide guidance on the use of categorical exclusions under the

National Environmental Policy Act (NEPA)?

2. Was guidance provided on the use of non-burning alternatives?

3. Did the document include information on applicable air quality laws, rules, and

guidance and the general conformity requirements of the Clean Air Act?

4. Was guidance provided on estimation of air pollutant emissions and their effects on

visibility (regional haze and plume blight) as well as the National Ambient Air

Quality Standards (NAAQS)?

5. Were predetermined “trigger points” to indicate when an air quality impact occurs

discussed in the document?

6. Were contingency actions to be taken wh en air quality impacts occur discussed?

7. Was coordination with adjacent and downwind land managers, regulatory

agencies, and other downwind receptors discussed?

8. Did the guidance cover cumulative effects of smoke through either a qualitative or

quantitative analysis of prescribed fire projections from other land managers and

other stationary or mobile sources?

In reviewing these documents, an affirmative evaluation was given if any guidance on the

criterion topic was provided, no matter how brief. If discussion of the criterion topic was

not present, a negative evaluation was given. In addition, the criteria as provided by the

FEJF were treated quite literally. For exampl e, the phrasing of Criterion 3 with “and”

requires several conditions all to be met for a document to receive an affirmative response.

As a result, any documents that might address some of the conditions of the criterion but

not others received a negative evaluation for the criterion.



# 3.0 Findings

In considering the results from the project tasks, a few points must be emphasized. The

great majority of the plans (excluding guidance documents) included in this project were

selected at the sole discretion of the provid ing agency. The project team mentioned some

# 9 

# desired characteristics of the plans to be revi ewed (such as 1998 or more recent, and fully

completed) but the agencies ultimately selected the individual plans on their own. (In a few

instances at the end of the project, the project team acquired a few plans on their own to

fill gaps in the overall project matrix.) In a ddition, the project team had no access to the

agency files and therefore had no control o ver the completeness of the documentation

provided for review. Every effort was made to ensure that the contacted agencies were

aware of the project goals, but the projec t team had no way of knowing if relevant

documentation was not provided by the agencies. Follow-up calls to the agencies were

made to ensure the relevant information was provided, but ultimately this was beyond the

project team’s control.

The findings from the evaluations of programmatic plans, operational plans and guidance

documents are presented below. The findings are divided into tables according to plan

type. Each table is summarized by agency ty pe. The tables show the total number of each

type of plan reviewed, the number of those pl ans with an affirmative (i.e., “yes”) evaluation

for each criterion, and the corresponding percentage of the total represented by the latter

number. Negative evaluations for a criterion c ould be due to absence from the document

reviewed or non-applicability of the criterion to the particular document. Please note that

negative evaluations do not necessarily mean a “poor” or “bad” finding, as in the case of

whether any air quality citations were issued.

Finally, the following sections present few fi ndings regarding tribal activities. This outcome

appeared to be due to several factors, incl uding (1) limited suppliers of tribal documents

(Institute for Tribal Environmental Professionals [ITEP], Intertribal Timber Council, Bureau of

Indian Affairs), and (2) an official request proc ess through tribal entities that was too lengthy

for the time constraints on the project. The ITEP study ( An Assessment of Tribal Air Quality

Data and Programs in the Western United States ) indicated that some Federal

Implementation Plans and tribal Smoke Mana gement Plans have been developed, but

copies of those plans, programmatic plans or operations plans are not readily available.

Therefore, it would be incorrect to presume that the lack of numbers of tribal plans below

corresponds to a lack of involvement in smoke i ssues by tribal agencies; rather, the project

team had difficulty acquiring plans within the framework of the project.



# 3.1 Programmatic Plans

A total of 18 prescribed fire and 12 WFU pr ogrammatic plans were received from federal

agencies. One local prescribed fire programmatic plan was reviewed (a county prescribed

fire planning document), and one tribal prescr ibed fire plan was reviewed. Results of the

assessment for programmatic plans are presented in Tables 2 and 3.

3.1.1 Programmatic Plans for Prescribed Fire

The review of prescribed fire programmatic pl ans prepared by federal agencies indicates

that while most plans do address the assessmen t criteria in very qualitative terms, none of

the plans provided quantitative analysis of th e effects of smoke on air quality and Class I

visibility. Many of the plans defer such ma tters to the smoke management program under

which they operate, noting only that the burning to be conducted will comply with smoke

management plan requirements. This infers that all applicable laws and relevant policies

are complied with and that smoke management te chniques will be applied. The majority of

the plans also note that prescribed burning may temporarily impact air quality and Class I

area visibility.

# 10 

# A programmatic plan for prescribed fire was obtained from both a tribal and a local agency.

These seemed to be rather rare occurrences . These two plans were somewhat hit-and-miss

regarding coverage of evaluation criteria, and th e large range in percentages (Table 2) is

reflective of the low number of plans available.



# Table 2. Affirmative Criterion Responses for Programmatic Plans for Prescribed

Fire

Agency Type

Tribal Local Federal

CriteriaCountPercentCountPercentCountPercent



# 1) cumulative effects of

smoke 0 0 1 100 7 39

2) intrusions into Class I or

other areas 0 0 1 100 10 56

3) applicable laws and

relevant policies 0 0 0 0 15 83

4) smoke management

techniques 0 0 1 100 11 61

5) annual or seasonal

emissions 1 100 0 0 4 22

6) non-burning alternatives 1 100 1 100 8 44

7) General Conformity (in

nonattainment/maintenance

areas only) NA NA 1 6

Number of Documents 1 1 18

NA—not applicable



# Table 3. Affirmative Criterion Res ponses for Programmatic Plans for WFU

Agency

Type

Federal

CriteriaCountPercent



# 1) cumulative effects of

smoke 4 33

2) intrusions into Class I or

other areas 7 58

3) burn decisions tied to air

quality criteria 12 100

4) non-burning alternatives 9 75

Number of Documents 12

♦ Criterion 1: Cumulative effects

# 11 

# About a third of the federal plans discussed this topic, usually rather minimally. It was

covered in the local plan, but not the tribal plan.

♦ Criterion 2: Impacts on Class I areas

About half the federal plans covered this, often as a component of smoke estimation. It was

covered in the local plan, but not the tribal plan.

♦ Criterion 3: Laws and policies

A large majority of the federal plans discusse d the laws that the plans must comply with,

and this was often done in terms of the go verning local Smoke Management Plan. It was

not covered in the local plan or the tribal plan.

♦ Criterion 4: Smoke management techniques

This was kind of a mixed bag with the federal plans, though a majority of plans addressed

the topic. Some made mention of techniques such as backing fires. It was covered in the

local plan, but not the tribal plan.

♦ Criterion 5: Annual or seasonal emissions estimates

Few of the federal plans discussed this topic. It was not covered in the local plan, but was

in the tribal plan.

♦ Criterion 6: Non-burning alternatives

Just under half of the federal plans discussed th is topic and such discussions are often quite

brief and not comprehensive. It was also covered in the local plan, and briefly in the tribal

plan.

♦ Criterion 7: General Conformity

This criterion is relevant only for planned fede ral activities (e.g., prescribed fire) in areas

that are nonattainment or maintenance areas fo r one or more NAAQS; conformity is not an

issue in attainment areas. This topic was relevant for only one of the federal resource areas,

and it was discussed in the relevant plan. This topic was not relevant to either the local or

tribal resource areas and was therefore not presented.

3.1.2 Programmatic Plans for WFU

All of the programmatic plans for WFU reviewed were from federal agencies (Table 3). The

other agency types generally suppress any naturally-started fires.

♦ Criterion 1: Cumulative effects

Only about a third of the federal plans discussed this topic, usually rather minimally

♦ Criterion 2: Impacts on Class I areas

About half the federal plans covered this, often as a component of smoke modeling. Some

plans deferred this evaluation until ready to burn.

# 12 

# ♦ Criterion 3: Burn decision tied to air quality

Each of the federal plans indicated that atmo spheric conditions must be favorable for the

action to proceed, although the required atmos pheric conditions were not always identical.

♦ Criterion 4: Non-burning alternatives

Three-quarters of the plans discussed alternatives such as mechanical treatments. In some

instances, there are agency policies or other limitations on use of mechanical treatments.



# 3.2 Operational Plans

There are five subgroups of operational plans for the project, covering both operational

plans and the implementation of operational plans. For the project, a total of 47 operational

plans and 19 implementation “reports” were r eviewed. These documents were provided by

a variety of agency types and covered a wide gamut of technical needs. The results are

presented in Tables 4, 5 and 6.



# Table 4. Affirmative Criterion Responses fo r Operational Plans for Prescribed Fire

Agency Type

Tribal Private Local State Federal

CriteriaCountPercentCountPercentCountPercentCountPercentCountPercent



# 1) estimation of emissions 0 0 0 0 0 0 0 0 0 0

1a) estimation of emissions,

but ignoring regional haze

portion 0 0 0 0 3 50 2 25 8 44

2) actions to minimize

emissions 1 100 2 100 5 83 7 88 12 67

3) smoke dispersion

evaluation 1 100 2 100 6 100 8 100 18 100

4) public notification 1 100 1 50 2 33 4 50 16 89

5) air quality monitoring 1 100 2 100 4 67 5 63 16 89

6) predetermined trigger

points 0 0 1 50 3 50 5 63 10 56

7) predetermined

contingency actions 1 100 2 100 4 67 6 75 14 78

8) cooperation with

downwind receptors 1 100 1 50 4 67 8 100 16 89

9) coordination with adjacent

and downwind land

managers 1 100 1 50 2 33 4 50 11 61

10) completion of General

Conformity NA NA NA NA NA

Number of Plans 1 2 6 8 18

NA—not applicable

# 13 

# 3.2.1 Operational Plans for Prescribed Fire

A total of 35 operational plans for prescribed fire were reviewed for the project, and plans

were received from all five agency categories (Table 4). This was the plan type that was

most complete for the project. The types of pl ans received in this category ranged from

simple 1-page county open burn forms to Environmental Impact Statements. The results

from the evaluations of operational plans for prescribed fire are presented in Table 4 and

are graphed in Figure 1.

Comparison of plans from different agency categ ories showed a wide range in plan content

and complexity. However, the operational plans for prescribed fire from federal agencies

(Table 1) were fairly consistent in content as well as appearance. In general terms, federal

plans tended to be the most comprehensive and complete. State forestry agencies often use

prescribed fire on lands they manage. These ag encies typically prepare burn plans prior to

unit ignition, as required by their respective state smoke management plans.



# Figure 1. Results from Operational Plans for Prescribed Fire

0 20 40 60 80 100 1. Estimation of emissions

2. Actions to minimize

emissions

3. Smoke dispersion

evaluation

4. Public notification

5. Air quality monitoring

6. Predetermined trigger points

7. Predetermined contingency

actions

8. Cooperation with downwind

receptors

9. Coordination with downwind

land managers

10. Completion of General

ConformityCriteria



# Affirmative Responses (%)



# Tribal Private Local State Federal Not applicable

# 14 

# Several states also regulate agricultural burning and require simple plans as a condition of

burn permit issuance. A variety of documents were provided by the various state

agricultural and local entities on the list (Table 1), but these documents fit into two general

categories: those prepared for state/local agency approval and those that were not.

Examples of documents provided that were not for state/local approval included copies of

burn plans by other agencies (e.g., Forest Service) that were distributed through burn

notification requirements. These documents were evaluated for the project, but were

materially different from the next category. The documents that were prepared for

state/local approval were limited to open burni ng permit applications . These permits were

for ditch burning on private lands, burning of agricultural debris from orchards and grass

seed production, forestlands and general land clearing operations. The open burn

documents are typically simple in scope, limiting the kinds of materials that can be burned,

the notification procedures that must be used and burn day smoke dispersion requirements.

The one exception was a local parks departme nt that provided an operational plan for

prescribed fire that resembled the operati onal plans for prescribed fire acquired from

federal agencies.

The private land owners contacted for this project operated under open burn permits, and

sometimes they must prepare burn plans as a condition of permit issuance. Some of the

land owners proactively prepare burn plans for their own internal planning purposes, even

if not required in the permitting process. The scope of these plans can vary considerably

depending on smoke management program requirements.

One operational prescribed fire plan was obtai ned from a tribal organization. All of the

project document types discussed in this sec tion were included in the operational plan

assessment for prescribed burns.

Generally speaking, the operational plans for prescribed fire covered the evaluation criteria

pretty well, as most of the results are well o ver 50% (Table 4). This indicates that the fire

planners are giving the topics of concern at least some consideration. Criterion 3 had

universal recognition in the plans. Criteria 1 a nd 6 showed some of the lowest recognition.

Criterion 10 received no recognition because none of the reviewed plans were in NAAQS

non-attainment areas. Results for the other cr iteria fell somewhere in between, but were

generally relatively high. The following disc usses findings relevant to each of the

assessment criteria.

♦ Criterion 1: Estimation of emissions

The wording of this criterion should be noted. There are a number of conditions that must

all be true for an affirmative response to this criterion, and typically impacts to regional

haze (or more) were not addressed. Therefore, none of the reviewed plans received an

affirmative response when following the wordin g of the criterion. When the regional haze

portion of the criterion is ignored (Table 4 Line 1a), there are several affirmative responses.

In most cases, SASEM was run to estimate emissions.

♦ Criterion 2: Actions to minimize emissions

A large majority of the plans addressed this topic. For the federal reports, the most common

actions discussed were aerial ignition and ig nition patterns. For the state it was limiting the

area burned and for local it was ignition technique.

# 15 

# ♦ Criterion 3: Smoke dispersion evaluation

Every operational plan for prescribed fire that was reviewed addressed this criterion.

Scheduling involving the time of day and/or year that burning was permitted was the most

common way that achieving dispersion was addressed in all report types. Wind speed and

direction, mixing height were also very common.

♦ Criterion 4: Public notification

A large majority of the plans addressed this topic. All but two of the federal reports

indicated that public notification would take place usually via press releases to local

newspapers. Radio and signage were other meth ods mentioned. The majority of the reports

from other agency types address this criterion as well.

♦ Criterion 5: Air quality monitoring

A large majority of the plans addressed this topic. All but two of the federal reports

indicated that air quality monitoring w ould take place. The most common form of

monitoring for all agency types was visual mon itoring, except for the state reports in which

instrument monitoring was mentioned.

♦ Criterion 6: Predetermined trigger points

For about half the federal reports the most co mmon trigger point was smoke hitting a major

roadway within the vicinity of the burn. Other agency types tended to have very qualitative

assessment points.

♦ Criterion 7: Predetermined contingency actions

A large majority of the plans addressed this topic. Halting of ignition was the most common

recommended action in federal reports while extinguishing the fire was more common for

state reports.

♦ Criterion 8: Cooperation with downwind receptors

Planned cooperation with downwind receptors was discussed in all but five of the

operational plan for prescribed fire that were reviewed.

♦ Criterion 9: Coordination with other managers

Planned coordination with other managers wa s discussed in approximately half of the

operational plan for prescribed fire that were reviewed.

♦ Criterion 10: General Conformity in nonattainment areas

All responses to this question were “not app licable” because none of the sites were in

nonattainment areas.

# 16 

# 3.2.2 Operational Plans for WFU

A total of 5 operational plans for WFU were revi ewed for the project. Only federal agencies

make use of these types of plans. The results from the evaluations of operational plans for

WFU are presented in Table 5.

Generally speaking, the operational plans for WFU did not cover the evaluation criteria as

well as prescribed fire (Table 5). There were not nearly as many plans to review, but at least

one plan gave each topic at least some c onsideration. The following discusses findings

relevant to each of the assessment criteria.

♦ Criterion 1: Estimation of emissions

The wording of this criterion should be noted. There are a number of conditions that must

all be true for an affirmative response to this criterion, and typically impacts to regional

haze (or more) were not addressed. Therefore, none of the reports received an affirmative

response when following the wording of the criterion. When the regional haze portion of

the criterion is ignored (Table 5 Line 1a), th ere are two affirmative responses. Two of the

reports indicated that emissions had been esti mated as well as their effects on visibility,

NAAQS, and nuisance. In one case SASEM had been run.



# Table 5. Affirmative Criterion Responses for Operational Plans for WFU

Agency

Type

Federal

CriteriaCountPercent



# 1) estimation of emissions 0 0

1a) estimation of emissions,

but ignoring regional haze

portion 2 40

2) actions to minimize

emissions 2 40

3) smoke dispersion

evaluation 4 80

4) public notification 5 100

5) air quality monitoring 4 80

6) predetermined trigger

points 1 20

7) predetermined

contingency actions 2 40

8) cooperation with

downwind receptors 3 60

9) coordination with adjacent

and downwind land

managers 4 80

Number of Plans 5

# 17 

# ♦ Criterion 2: Actions to minimize emissions

Two reports discussed actions to minimize emissions.

♦ Criterion 3: Smoke dispersion evaluation

The majority of the reports addressed smoke dispersion. Wind speed and direction and the

use of other meteorological data were the most common methods.

♦ Criterion 4: Public notification

All of the reviewed plans indicated that public notification would take place through

various types of media.

♦ Criterion 5: Air quality monitoring

Four of the five reports indicated that air quality monitoring would take place. The most

common type of monitoring was visual.

♦ Criterion 6: Predetermined trigger points

Only one report addressed trigger points.

♦ Criterion 7: Predetermined contingency actions

Two reports addressed contingency ac tions such as stopping ignitions.

♦ Criterion 8: Cooperation with downwind receptors

Three reports addressed planned cooperation with downwind receptors.

♦ Criterion 9: Coordination with other managers

Four reports addressed planned c oordination with other managers.

3.2.3 Operational Plans for WFSA

A total of 7 operational plans for WFSA were reviewed for the project. Only federal

agencies make use of these types of plans. The results from the evaluations of operational

plans for WFSA are presented in Table 6.

Generally speaking, the operational plans for WFSA did not cover the evaluation criteria as

well as either prescribed fire or WFU. This is likely a function of WFSAs being nearly “after

the fact” plans where the fire is already bur ning before the WFSA process begins. The

following discusses findings relevant to each of the assessment criteria.

♦ Criterion 1: Estimation of emissions

The wording of this criterion should be noted. There are a number of conditions that must

all be true for an affirmative response to this criterion, and typically impacts to regional

haze (or more) were not addressed. Therefore, none of the reviewed plans received an

# 18 

# affirmative response when following the wordin g of the criterion. When the regional haze

portion of the criterion is ignored (Table 6 Li ne 1a), there is one a ffirmative responses. One

of the WFSA documents mentioned estimated emissions.

♦ Criterion 2: Actions to minimize emissions

Few of the plans mentioned this. Most typically, the fundamental emissions control action

is to put the fire out as quickly as possible. One plan mentioned that safety and suppression

were the priorities.

♦ Criterion 3: Smoke dispersion evaluation

One of the WFSA documents mentioned this.



# Table 6. Affirmative Criterion Respons es for Operational Plans for WFSA

Agency

Type

Federal

CriteriaCountPercent



# 1) estimation of emissions 0 0

1a) estimation of emissions,

but ignoring regional haze

portion 1 14

2) actions to minimize

emissions 2 29

3) smoke dispersion

evaluation 1 14

4) public notification 4 57

5) air quality monitoring 1 14

6) predetermined trigger

points 1 14

7) predetermined

contingency actions 0 0

8) cooperation with

downwind receptors 1 14

9) coordination with adjacent

and downwind land

managers 1 14

Number of Plans 7

♦ Criterion 4: Public notification

About half of the plans mentioned this, the other half did not.

♦ Criterion 5: Air quality monitoring

# 19 

# Only one plan mentioned any kind of air monitoring.

♦ Criterion 6: Predetermined trigger points

One plan described a rather qualitative trigger; if smoke becomes noticeable in an adjacent

area.

♦ Criterion 7: Predetermined contingency actions

One of the WFSA documents mentioned this.

♦ Criterion 8: Cooperation with downwind receptors

One of the plans discussed this criterion. One plan seemed to indicate there would be

communication only if complaints were received.

♦ Criterion 9: Coordination with other managers

One of the WFSA documents mentioned this.

3.2.4 Implementation of Prescribed Fire

A total of 15 reports detailing the implementa tion of operational plans for prescribed burns

were reviewed for the project, and plans were received from three of the five agency

categories. The results from the evaluations of operational plans for WFSA are presented in

Table 7 and graphed in Figure 2.

The majority of these reports (13) were receiv ed from federal agencies, although it should

be noted that these were not truly “reports” but rather collections of information. These

reports were often a collection of individual documents obtained from a number of sources

including air agencies, smoke management prog rams, and district and regional offices. In

cases where adverse smoke impacts occurred as a result of a fire, the post-burn report can

be voluminous, but in most cases the reports were brief and often incomplete with respect

to the assessment criteria. Only Criterion 1 exceeded 50% in coverage.

Most of the non-federal reports gave next to no consideration to the evaluation criteria, and

usually the documentation was quite thin. The fo llowing discusses findings relevant to each

of the assessment criteria.

♦ Criterion 1: Avoided smoke effects

The majority of reports indicated that there was no smoke effect because of good

dispersion; the others (from all agency categories) were silent on the topic.

♦ Criterion 2: Unfavorable smoke effects

Two federal reports mentioned that there were effects. None of the other reports mentioned

this topic.

♦ Criterion 3: Verified public nuisance complaints

# 20 

# Three federal reports addressed the topic by indicating there had been complaints. None of

the other reports mentioned this topic.



# Table 7. Affirmative Criterion Responses for Implementation of Prescribed Fire

Agency Type

Private Local Federal

CriteriaCountPercentCountPercentCountPercent



# 1) avoided smoke effects 1 100 1 100 9 69

2) unfavorable smoke effects 0 0 0 0 2 15

3) verified public nuisance

complaints 0 0 0 0 5 38

4) air quality citations 0 0 0 0 0 0

5) contacts made with

downwind receptors 0 0 0 0 5 38

6) smoke management

elements of burn plan

implemented 0 0 1 100 6 46

7) contingency actions taken

as a result of air quality

impacts 0 0 0 0 1 8

8) public notification and

exposure reduction 0 0 0 0 4 31

9) compliance with air

quality laws 0 0 0 0 4 31

10) air quality monitoring

plan followed 0 0 1 100 5 38

11) actions taken to avoid

smoke impacts 0 0 0 0 2 15

Number of Plans 1 1 13

♦ Criterion 4: Air quality citations

One of the federal reports indicated that a citation had been issued, but it was later

rescinded upon further investigation. That was the only mention of the topic.

♦ Criterion 5: Contacts made with downwind receptors

Most of the operational plans indicated that this would be done during the burn. If this was

executed during implementation, it was not well documented in most of the reports.

♦ Criterion 6: Smoke management elements implemented

The local agency report seemed to indicate that this was done. A few federal reports

indicated that this was done, while most of the reports were silent on the topic. One federal

report seemed to indicate that the data sp ecified in the operational plan was not all

collected during the burn. The private agency report did not mention the topic.

# 21 

# Figure 2. Results from Implementation of Prescribed Fire

♦ Criterion 7: Contingency actions

For one federal burn, new ignitions were halte d. No other such actions were mentioned.

♦ Criterion 8: Public notification

Again, if this was executed during implementation, it was not well documented in most of

the reports.

♦ Criterion 9: Compliance with air quality laws

The reports typically did not discuss their status with this criterion.

♦ Criterion 10: Air quality monitoring

The majority of reports did not contain da ta showing this was done. It is possible

monitoring was performed but was not provided in the data package.

♦ Criterion 11: Actions taken to avoid smoke impacts 

# 0 20 40 60 80 100 1. Avoided smoke effects

2. Unfavorable smoke effects

3. Verified public nuisance complaints

4. Air quality citations

5. Contact downwind receptors

6. Smoke management implemented

7. Contingency actions taken

8. Public notification

9. Compliance with air quality laws

10. Air quality monitoring followed

11. Actions to avoid smoke impactsCriteria



# Affirmative Responses (%)



# Private Local Federal

# 22 

# Very few of the documented burns needed to act to reduce smoke (water drops, reduce fuel

consumed, etc.). This complements Criterion 1 where good smoke dispersion was typically

reported.

3.2.5 Implementation of WFU

A total of four reports detailing the implem entation of operational plans for WFU were

reviewed for the project. The results from the evaluations of operational plans for WFU are

presented in Table 8.



# Table 8. Affirmative Criterion Re sponses for Implementation of WFU

Agency

Type

Federal

CriteriaCountPercent



# 1) avoided smoke effects 1 25

2) unfavorable smoke effects 2 50

3) verified public nuisance

complaints 2 50

4) air quality citations 0 0

5) contacts made with

downwind receptors 4 100

6) smoke management

elements of burn plan

implemented 3 75

7) contingency actions taken

as a result of air quality

impacts 1 25

8) public notification and

exposure reduction 4 100

9) compliance with air

quality laws 2 50

10) air quality monitoring

plan followed 3 75

11) actions taken to avoid

smoke impacts 1 25

Number of Plans 4

These reports were available only from fede ral agencies. Again, these were not truly

“reports” but often just collections of info rmation. These post-burn reports may include

information on how the burn was actually accomp lished, tons of fuel actually burned,

smoke complaints (if any) received, plume tr ansport and other information detailing what

actually happened during the burn. These repor ts were often a collection of individual

documents obtained from a number of source s including air agencies, smoke management

programs, and district and regional offices. The reports tended to be brief and often

incomplete with respect to the assessment cr iteria. There were few reports available for

# 23 

# review, and the results were inconsistent (Table 8). The following discusses findings

relevant to each of the assessment criteria.

♦ Criterion 1: Avoided smoke effects

Two burns had poor dispersion and some smok e effects, one had good dispersion and one

did not mention the topic.

♦ Criterion 2: Unfavorable smoke effects

Half the burns had effects from poor dispersion.

♦ Criterion 3: Verified public nuisance complaints

Half the burns had some complaints, though th ese were not always the same burns as

Criterion 2.

♦ Criterion 4: Air quality citations

No citations were reported.

♦ Criterion 5: Contacts made with downwind receptors

All the reports described contacting downwind receptors.

♦ Criterion 6: Smoke management elements implemented

One burn did not document smoke modeling. Ot herwise, the elements seemed to have

been implemented.

♦ Criterion 7: Contingency actions

In one case, any new fires were ex tinguished as a contingency action.

♦ Criterion 8: Public notification

The reports indicated that this was done.

♦ Criterion 9: Compliance with air quality laws

One burn report did not mention the topic. Another burn report did not show daily

monitoring as recommended in the agency guidelines.

♦ Criterion 10: Air quality monitoring

As with Criterion 9, one burn report did not show daily monitoring.

♦ Criterion 11: Actions taken to avoid smoke impacts

An action was taken for one burn by removing vegetation on ridge tops.

# 24 

# 3.3 Guidance Documents

In total, 68 guidance documents were revi ewed for the project: 25 local documents, 21

state-level documents including smoke management plans, and, 22 federal guidance

documents. Table 9 and Figure 3 summarize th e results of the assessment. Detailed findings

for each guidance document are tabulated in Appendix C.



# Table 9. Affirmative Criterion Responses for Guidance Documents

Agency Type

Local State Federal

CriteriaCountPercentCountPercentCountPercent



# 1) categorical exclusions 0 0 0 0 5 23

2) non-burning alternatives 5 20 9 43 13 59

3) evaluation of air quality

laws and rules including

general conformity 1 4 2 10 12 55

4) estimation of air pollutants and visibility impacts 5 20 9 43 14 64

5) predetermined trigger

points 1 4 7 33 8 36

6) contingency actions to be

taken 4 16 7 33 7 32

7) coordination with

adjacent and downwind

land managers 2 8 5 24 7 32

8) cumulative effects of

smoke 0 0 1 5 3 14

Number of Documents 25 21 22

• Findings presented in Table 9 underscore the scarcity of General Conformity guidance

in state or local-level documents relative to wildland fire use or agricultural burning. All

of these documents do, however, address air qua lity regulatory requirements of state or

local air agencies or districts. Most of the General Conformity guidance is found in

documents drafted by federal agencies and about half of documents reviewed provide

guidance on this issue.

• Few of the documents discuss categorical exemptions within NEPA as applied to smoke

effects.

• About one-third of the federal and state guidance and fewer than 10% of the local

documents define “trigger points” used to quantitatively determine when smoke

impacts occur. In most of the guidance, smoke impacts that exceed NAAQS are the

implied “trigger point” level, but in many cases the meaning of “smoke impact” is left

undefined.

• Guidance on the cumulative impacts of smok e when considered in combination with

other point and area sources (including other burning activity) is either not generally

# 25 

# available or is treated only in very qualita tive terms. Less than one-fifth of the federal

guidance and none of the state or local guid ance discuss this issue. While many smoke

management plans include centralized, daily burn authorization to coordinate burning

activity and collectively minimize smoke effe cts on visibility and NAAQS, few of these

programs also coordinate with WFU or ag ricultural or general open burning activity.

Guidance on quantitative assessment of cumulativ e impacts of smoke is in the realm of

regional transport modeling, not the prac titioner guidance/air quality regulations

reviewed here. Fire practitioners are typica lly concerned about smoke effects from the

single fire they are responsible for managing rather than the broad-scale cumulative

effects of smoke.



# Figure 3. Results from Evaluation of Guidance Documents

• Local guidance documents generally consis ted of open burning permit requirements

that are intended to minimize the nuisance e ffects of smoke, regulate the kinds of

materials burned and fire hazard issues, only. As a result, much of the local

guidance/air quality regulations reviewed de alt only with compliance with county or

district air quality rules and regulations. Many of the criteria assessed here do not apply

to these documents.

• Private landowners and tribal entities co mmonly use federal and state guidance

documents in their fire use programs. We were unable to identify or obtain any smoke

management (or any other guidance documents) from tribal entities for this assessment. 

# 0 20 40 60 80 100 1. Categorical Exclusions

2. Non-burning Alternatives

3. AQ Laws & Conformity

4. Estimate Pollutant. &

Visibility

5. Trigger Points

6. Contingency Actions

7. Downwind Coordination

8. Cumulative Effects of

SmokeCriteria



# Affirmative Responses (%) Federal

State

Local

# 26 

# Nationally, there are no adopted Tribal Implementation Plans, so none could be

reviewed.

3.3.1 Federal Guidance Documents

In overview, the federal guidance documents provided the best and most thorough

discussion of air quality-smoke effect issues. Ma ny of these documents are widely used by

fire practitioners and air quality regulators, na tionwide and cover a wealth of technical,

policy, fire planning and regulatory issues th at apply to most forestland managers. Since

federal guidance documents focus on national issues that apply to federal land managers,

discussions of matters of more local significan ce, such as fire permit authorization, are not

generally included in these documents. In response to new air regulatory requirements,

National Wildfire Coordinating Group (NWCG) Smoke Management Guide has greatly

expanded sections on regional haze, visibility, emission reduction methods and nonburning alternatives. NWCG provides both guidance and training materials.

3.3.2 State Guidance Documents

Documents in this category include the st ate smoke management plans for both wildland

fire and agricultural burning. They describe ai r quality rules and regulations, programs and

policies that apply to wildland fire, agricultural, and open burning. They also provide useful

information and describe services to fire pr actitioners that help minimize emissions and

smoke impacts, including meteorological forecasting. They do not address issues of special

significance to Federal Land Managers such as NEPA categorical exclusions. As noted in

Table 9, about one-quarter of the state guidance documents reviewed included

coordination with downwind agencies and the public, as this is a common element of

smoke management plans. About one-third includ ed either a requirement that contingency

actions be specified in the burn plan in the event of smoke impacts or that actual measures

to be taken are identified.

3.3.3 Local Guidance Documents

The local-scale guidance, as noted above, is al most solely limited to local air quality open

burning and, in a few cases, smoke managem ent programs adopted by local air quality

agencies and districts. With the exception of the smoke management plans adopted by

county and district-level agencies, the majority of these documents describe procedures for

issuance of open burn permits, coordination with fire protection agencies and reporting

requirements.

3.3.4 Review of the Assessment Criteria

The following discusses findings relevant to each of the assessment criteria.

♦ Criterion 1: NEPA Categorical Exclusions

Of the 22 federal guidance or air quality re gulations reviewed, very few provided any

guidance on NEPA categorical exclusions. The most extensive discussion was found in the

National Park Service National Director’s Guidance 12: NEPA and in the BLM Land Use

Planning Handbook H-1601. The US Forest Se rvice guidance “Describing Air Resource

Impacts of Prescribed Fire Projects in NEPA documents” is also useful. No other documents

# 27 

# were found that addressed the topic. None of the state or local-level guidance documents

addressed this issue.

♦ Criterion 2: Non-Burning Alternatives

Consideration of non-burning alternatives in th e prescribed fire/WFU planning process is a

relatively new requirement of many state/lo cal smoke management plans and as a result,

newly published federal guidance documents no w include more guidance on this topic.

For example, the 1985 NWCG Prescribed Fi re Smoke Management Guide had only brief

mention of alternatives to fire while Chapter 8 of the new NWCG Smoke Management

Guide 2001 Edition has extensive information of the subject. The discussions in state/local

guidance documents and air quality rules are principally focused on their requirements for

fire practitioners to consider a nd document non-burning alternatives to fire in the state/local

smoke management programs and permitting process.

♦ Criterion 3: Air Quality Laws and General Conformity

Most of the federal documents did discuss air quality laws, rules applicable to prescribed

fire or WFU but few provided any guidance on General Conformity. Within the federal

guidance category, the most extensive guidance is found in NWCG RX-450/410 training

course materials and in Chapter 4 of the new NWGC Smoke Management Guide 2001

Edition. The EPA Interim Air Quality Policy outlines relatively ne w and groundbreaking

policy with respect to wildland fire smoke impacts on air quality. The Policy recognizes the

important role that fire plays in the ecosystems of the nation's forests while urging wildland

managers to consider air quality impacts of fires and take steps to minimize these impacts,

emphasizing consideration of alternative treatm ents rather than the use of fire. State and

local regulations deal almost exclusively with applicable air quality regulations that apply

to wildland and agricultural burning but exclude the issue of General Conformity.

♦ Criterion 4: Estimation of Pollutants and Visibility Effects

Calculations of pollutant emissions are comm only required in state and local regulations

but only 20% of the local and 43% of the state guidance or air quality regulations require

estimation of both pollutant emissions and evalu ation of the effect of these pollutants on

Class I visibility. The federal guidance (Tab le 9) more commonly (about two-thirds)

addresses both topics. In the case of state and local regulations, estimation of PM-10

emissions prior to unit ignition is required by the smoke management plans. Some also

require SASEM modeling but none of the guidan ce reviewed require modeling of smoke

effects on Class I visibility. Most smoke management plans do, however, strive to protect

Class I area visibility through meteorological forecasting and burn scheduling. Again, the

NWCG Smoke Management Guide provides the most up-to-date guidance on emission

estimates (Chapter 11) and visibility effects (Chapter 3).

♦ Criterion 5: Evaluation of Pr edetermined Trigger Points

Clear definitions of “trigger points” that signal a smoke impact is unusual in local

regulations (less than 10%). About one-third of the state air regulations and federal

guidance documents use NAAQS exceedances as a benchmark of an unacceptable smoke

impact. Only two of the guidance document s reviewed used a quantitative measure of

extinction (light scattering) as a “trigger poi nt” which, if exceeded, would require action to

minimize fire emissions. None of the guidance documents reviewed adequately addressed

# 28 

# this issue. What constitutes a “trigger point ” defining an unacceptable smoke impacts

involves considerations of public nuisance, visibility impairment, possible human health

effects and how regulatory agencies define a “s ignificant contribution” to particulate matter

under the NAAQS.

♦ Criterion 6: Contingency Actions

About one-third of the state and federal documen ts reviewed either provided guidance on

or required that contingency actions be taken in the event of a smoke impact. Less than

one-fifth of the local air regulations required contingency plans to minimize emissions from

a burn causing a smoke impact. In state and federal documents, which do include a

required contingency action plan, the specific me asures that must be taken are left to the

fire practitioner managing the fire. The best and most current guidance is found in two

documents. The NWCG Smoke Management Guide describes smoke management and

emission reduction techniques, including rapi d mop-up and fuels isolation. Section VI.C.3

of the EPA Interim Air Quality Policy on W ildland and Prescribed Burning provides a

helpful list of contingency actions that can be taken to reduce public exposure to smoke.

♦ Criterion 7: Coordination with Downwind Agencies

Again, federal guidance documents provide the best source of information on coordination

measures to be taken with downwind air agencies, the media or the public. This

coordination is usually done (if done at a ll) through the respective smoke management

program. About one-third of the federal guidan ce specifically discussed this topic but only

one-quarter of the state air regulations or smoke management plans reviewed required

downwind coordination. Less than one-tenth of the local air regulations mentioned

downwind coordination. Section 6.0 (Public Awareness) of the EPA BACM Technical

Information Document provides helpful guidance on coordination with downwind

agencies, the public and the burn community.

♦ Criterion 8: Evaluation of Cumulative Effects of Smoke

Very little guidance on evaluation of the cumula tive effects of smoke when considered in

combination with other stationary and mobile sources of air pollution was found in the

guidance reviewed. This topic was not addressed in any of the local guidance and in only

one of the state-level documents. The best guidance was found in the NWCG Smoke

Management Guide 2001 Edition, which discusse s the role of smoke in regional haze,

numeric models that may be used to evaluat e visibility impacts of smoke on Class I areas

and research activities. Comprehensive guidan ce on this topic is, however, beyond the

scope of the documents reviewed here.



# 4.0 Summary

The preceding section detailed the findings from the plan reviews performed for the

project. For a number of reasons, there were so me holes in the agen cy/plan type matrix.

Some of the contacts did not respond in a timely fashion so their plans could not be

included. Some of the contacts did not utilize ce rtain plan types, so they had no plans to

contribute to the project. Other contacts chos e not to participate. While the number of

plans reviewed for the project may have been less than originally envisioned, a number of

plans and guidance documents were reviewed.

# 29 

# The preceding sections present few finding s regarding tribal activities. This outcome

appeared to have several contributors that were previously discussed. It would be incorrect

to presume that the lack of numbers of tribal plans corresponds to a lack of involvement in

smoke issues by tribal entities; rather, the pr oject team had difficulty in acquiring plans.

Several project objectives were listed in the Introduction. To summarize the overall project,

the outcome for each objective is listed below.

• Many of the agency contacts (i.e., non-federa l) do not use programmatic plans, so they

can not consider smoke effects in such plans. Those that do use programmatic plans

showed mixed results regarding the evaluation criteria.

• Just over half of the programmatic plans discussed non-burning alternatives.

• Operational plans for prescribed fire (or its equivalent) were obtained from all five

agency categories. Only federal agencies used WFU or WFSA as tools. Content and

complexity of these plans was quite vari able. The results regarding the evaluation

criteria were somewhat mixed, but, in gen eral, the plans addressed the criteria

reasonably well.

• Relatively few of the implemented plans show ed smoke effects (of any kind) from the

fires.

• Guidance documents for programmatic and operational plan preparation were

reviewed. The findings were that there was o ften incomplete or inconsistent guidance

regarding the evaluation criteria.

• Guidance documents for WFSA were reviewed.

Again, the project review process tended to be generous. If a document discussed the topic

of a criterion, even briefly, then credit was given for addressing the topic. The project team

did not attempt to assess the thoroughness or adequacy of the criterion discussion, only its

presence. This approach has the effect of painting a more optimistic picture of the

comprehensiveness of the documents that were reviewed.

# Appendices

# Appendix A: List of Plans Reviewed for Project

Agency

Type Agency Region Plan Type Plan/Burn Name

Federal Bureau of Land Management AZ Implemented Rx Sam Springs

Bureau of Land Management AZ Operational Rx Sam Springs

Bureau of Land Management AZ WFSA Mt. Emma

Bureau of Land Management CO Implemented Rx Big Duck

Bureau of Land Management CO Operational Rx Lobo/China Wall

Bureau of Land Management CO Program matic Rx Little Snake/Brown's Park

Bureau of Land Management CO Programmatic WFU Little Snake/Brown's Park

Bureau of Land Management ID Programmatic Rx Owyhee Resource

Management Plan

Bureau of Land Management MT Implemented Rx Elk Creek

Bureau of Land Management MT Operational Rx Elk Creek

Bureau of Land Management MT Programmatic Rx Missoula Field Office Fire

Mgmt. Plan

Bureau of Land Management MT Programmatic WFU Elkhorn Wildland Fire

Guidebook

Bureau of Land Management MT WFSA High Ore Road/Boulder Hill

Bureau of Land Management NV Implemented RX Stormy

Bureau of Land Management NV Operational Rx Stormy

Bureau of Land Management NV Programmatic Rx Elko Fire Management Plan

Bureau of Land Management NV Programmatic WFU Elko Fire Management Plan

Bureau of Land Management OR Operational Rx Brady Butte

Bureau of Land Management OR Programmatic Rx Lakeview RMP DEIS

Bureau of Land Management UT Implemented Rx Dry Creek

Bureau of Land Management UT Operational Rx Dry Creek

Bureau of Land Management UT Programmatic Rx Cedar City Fire

Management Plan

Bureau of Land Management UT WFSA Lydia's Canyon

Bureau of Land Management WY Implemented Rx Sawmill

Bureau of Land Management WY Operational Rx Sawmill

Bureau of Land Management WY Programmatic Rx Kemmerer RMP-FEIS

National Park Service Intermountain Implemented WFU Langston Fire Complex

National Park Service Intermountain Operational WFU Langston Fire Complex

National Park Service Intermountain Operational Rx Loop Hazard Fuels

Reduction Plan Unit 4 Pile

National Park Service Intermountain Pr ogrammatic Rx Wildland FMP-Zion NP

National Park Service Intermountain Programmatic WFU Wildland FMP-Zion NP

National Park Service Midwest Implemented Rx Bison Flats

National Park Service Midwest Operational Rx Bison Flats

National Park Service Midwest Pr ogrammatic Rx Wind Cave NP FMP

National Park Service Midwest Programmatic WFU Wind Cave NP FMP

National Park Service Midwest WFSA Highland Creek

National Park Service Pacific West Implemented Rx East Buttress Meadow

National Park Service Pacific West Operational Rx East Buttress Meadow

National Park Service Paci fic West Programmatic Rx Yosemite Fire Management

Plan 1991

# Agency

Type Agency Region Plan Type Plan/Burn Name

Federal National Park Service Paci fic West Programmatic WFU Yosemite Fire Management

Plan 1991

U.S. Fish and Wildlife Service 1 Operational Rx Kern NWR Marsh Unit 1

U.S. Fish and Wildlife Service 1 Programmatic Rx Hart Mountain

U.S. Fish and Wildlife Service 2 Implemented Rx Buenos Aries Hill 1

U.S. Fish and Wildlife Service 2 Operational Rx Buenos Aries Hill 1

U.S. Fish and Wildlife Service 2 Programmatic Rx Buenos Aires NWR Fire

Mgmt. Plan

U.S. Fish and Wildlife Service 6 Implemented Rx Ruppel Waterfowl

Production Area (WPA)

U.S. Fish and Wildlife Service 6 Operational Rx Fish Springs NWR

U.S. Fish and Wildlife Service 6 Programmatic Rx Brown's Park

U.S. Fish and Wildlife Service 6 Programmatic WFU Brown's Park

U.S. Forest Service 1 Implemented WFU Birk Fire

U.S. Forest Service 1 Operational WFU Birk Fire

U.S. Forest Service 1 Operational Rx South Fork Sun Burn

U.S. Forest Service 1 Programmatic Rx Bitterroot NF FMP

U.S. Forest Service 1 Programmatic WFU Bitterroot NF FMP

U.S. Forest Service 1 WFSA Little Blue

U.S. Forest Service 2 Implemented Rx Polhemus Prescribed Burn

U.S. Forest Service 2 Operational Rx Polhemus Prescribed Burn

U.S. Forest Service 2 Programmatic Rx San Juan FMP

U.S. Forest Service 2 Programmatic WFU San Juan FMP

U.S. Forest Service 3 Implemented Rx Water Canyon

U.S. Forest Service 3 Implemen ted WFU Bloodgood Complex Fire

U.S. Forest Service 3 Operational WFU Bloodgood Fire Complex

U.S. Forest Service 3 Operational Rx Water Canyon

U.S. Forest Service 3 Programmatic Rx Gila NF Fire Management

Plan

U.S. Forest Service 3 Programmatic WFU Gila NF Fire Management

Plan

U.S. Forest Service 3 WFSA Homestead

U.S. Forest Service 4 Implemented Rx Gregory-Johnson

U.S. Forest Service 4 Implemented WFU Iron Creek Fire

U.S. Forest Service 4 Operational WFU Iron Creek Fire

U.S. Forest Service 4 Operational Rx Gregory-Johnson

U.S. Forest Service 4 Programmati c Rx Bridger-Teton Forest Fire

Management Plan

U.S. Forest Service 4 Programmati c WFU Bridger-Teton Forest Fire

Management Plan

U.S. Forest Service 4 WFSA Sawyer

U.S. Forest Service 5 Operational Rx Georgetown R2H2 Burn

U.S. Forest Service 5 Programmati c Rx Sierra Nevada Forest Plan

Amendment

U.S. Forest Service 5 Programmati c WFU Sierra Nevada Forest Plan

Amendment

U.S. Forest Service 6 Operational WFU French Creek

# Agency

Type Agency Region Plan Type Plan/Burn Name

Local Boulder County Colorado Implemen ted Rx Rabbit Mtn.-Little

Thompson Overlook

Boulder County Colorado Operat ional Rx Rabbit Mtn.-Little

Thompson Overlook

Boulder County Colorado Programmatic Rx General regulations

Jefferson County Oregon Operational Rx Open Burning Permit, SMP,

& Regulations

Missoula County Montana Operational Rx Unified Outdoor Burning

Permit

Pinal County Arizona Operational Rx Agricultural Open Burn

Permit

San Joaquin Valley California Operational Rx Nobe A Burn--Forest

Service

San Joaquin Valley California Operatio nal Rx Hercules Restoration Burn-

-Park Service

Private Nature Conservancy Implemented Rx Albany Pine BushFirebrand

Nature Conservancy Operational Rx Albany Pine Bush-Friendly

Plum Creek Timber Operational Rx General burn permit

State Colorado State Forest Service Operational Rx Woodland Park Section 16

Montana Division of Forestry Operational Rx Open Burn Permit

Nevada Division of Forestry Operational Rx Incline Village

State of Arizona Ag Operatio nal Rx Yuma County Pest Control

State of Idaho Ag Operatio nal Rx Field Burning Registration

From & Rules

State of Montana Ag Operat ional Rx 2001 USFS Region 1

permit

State of Oregon Ag Oper ational Rx Not specified

State of Washington Ag Operat ional Rx Wagoner Toychet Farm

Tribal Chippewa Cree Operational Rx Centennial Mountain

Colville

Confederated Programmatic Rx Colville Integrated

Resource Management

Plan

# Appendix B: Guidance Documents Reviewed

State/Local Open Burning and Smoke Management

1. California Rules & Regulations

a. Smoke Management Guidelines for Agricultural & Prescribed Burning, Title 17 of

the California Code of Regulations

b. Northeast Air Alliance Smoke Management Plan for Butte, Lassen, Modoc,

Plumas, Shasta, Siskiyou, Tehama. August 2000

c. Amador County Air Pollution Control District Open Burning Rules 306; Wildland

Vegetation Management Burning Rule 308.1 and Forest Management Burning

309.1.

d. Antelope Valley Air Pollution Control District Rule 444 Open Fires

e. Bay Area Air Quality Management District Regulation 5 Open Burning

f. Butte County Air Quality Management District Rule 300 Open Burning

g. Colusa County Air Pollution Control District Rule VI Agricultural Burning

h. Great Basin Unified Air Pollution Control District Rule 410 Forest Management

Burning and Rule 411 Wildland Vegetation Management Burning in Wildland and

Wildland/Urban Interface Areas.

i. Mariposa County Air Pollution Control District Rule 307 Wildland Vegetation

Management Burning

j. Northern Sierra Air Quality Management District Rule 306 Forest Management

Burning and 307 Wildlands Vegetation Management Burning.

k. Placer County Air Pollution Control District Rule 316 Range Improvement /Forest

Management Burning and 317 Wildland Vegetation Management Burning.

l. Sacramento Air Quality Management District Rule 501 Agricultural Burning

(includes forest management burning)

m. San Joaquin Valley Unified Air Pollution Control District Rule 4106 Prescribed

Burning and Hazard Reduction Burning.

n. Shasta County Air Qua lity Management District Rule 2:6 Open Burning

o. Siskiyou County Air Pollution Control District Rule 7 Open Burning

p. South Coast Air Quality Management District Rule 444 Open Fires

q. Tuolumne County Air Pollution Control District Rule 300 Open Burning

r. Feather River Air Quality Management District Rule 2.17 Wildland Vegetative

Management Burning.

# s. Calaveras County Air Pollution Control District Rule 300 Open Burning

t. San Joaquin Valley Unified APCD Prescribed Burning MOU

u. Proposed Amendments to California’s Agricultural Burning Guidelines. Staff

Report. California Air Resources Board. February 2000.

v. Sacramento Valley Smoke Management Program. Sacramento Valley Basinwide

Air Pollution Control Council. June 15, 2001.

2. Montana

a. Open Burning Rule 17.8

b. Missoula County Open Burning Rules Chapter 7

c. It’s Fall. Why Can’t I Burn? – Missoula County Health Department

d. Montana – Idaho State Airshed Group Smoke Management Program 8/2001

3. Arizona

a. Forest and Range Management Burns Chapter 2 Article 15

b. Smoke Management Plan Chapter 3

4. Colorado

a. State Open Burning Procedure E008

b. Smoke Management Memorandum of Understanding Feb. 2001

c. Boulder County Health Department Ai r Quality/Prescribed Fire Guidance

Document. March 1, 1999.

d. Boulder County Health Department Open Burning Policy. Jan. 1, 2001

e. Desk Guide for CSFS Prescribed Fire Procedures

5. Nevada Smoke Management Plan

6. Wyoming Open Burning & Smoke Management Regulations: Chapter 10

7. Oregon

a. Smoke Management Program, Administrative Rules & Directives

b. Open Burning Rules Division 264

c. Willamette Valley Field Burning Permit Agent Manual. March 2001.

8. Utah

a. Smoke Management Plan

# b. Utah DEQ Smoke Management Rule R307-204

9. Washington

a. State Smoke Management Plan

b. Agricultural Burning Best Manageme nt Practices, Permit and Focus Sheet

10. Alaska

a. Open Burning Rules, Policy & Guidelines

b. Open Burning Rule 18AAC50

11. New Mexico Smoke Management MOU

Federal Guidance Documents, Training Materials & Laws

1. EPA Interim Air Quality Policy on Wildland and Prescribed Fires

2. NWCG Prescribed Fire Smoke Management Guide, 1985

3. EPA Prescribed Burning Background and Technical Information Document for

Prescribed Burning Best Available Control Measures

4. USDI Bureau of Land Management Handbook H-1601-1

5. USDI National Park Service Director’s Order #18: Wildland Fire Management

6. USDI National Park Service Director’s Order #12: NEPA

7. US Fish & Wildlife Service Part 621 Fire Management – Prescribed Fire

8. Clean Air Act – Title I: Part A Air Quality and Emission Limitations Sec. 101-131

9. Clean Air Act – Title I: Part C Prevention of Significant Deterioration Sec. 160-169;

Subpart 2, Sec. 169A and 169B

10. Clean Air Act – Title I, Part D, Sec. 176c Conformity

11. CFR Title 40, Part 51 Subpart P Protection of Visibility

12. USDI Bureau of Land Management Manual M-1601- Land Use Planning

13. USDA Forest Service Guidelines for Preparing a NEPA Air Quality Analysis

14. Describing Air Resource Impacts from Prescr ibed Fire Projects in NEPA Documents For

Montana and Idaho in Region 1 and Region 4

15. Forest Service Manual

16. Forest Service Desk Guide for Integrating Air Quality and Fire Management into Land

Management Planning--Draft

# 17. NWCG Smoke Management Techniques RX- 450 Training Manual-Instructor’s Guide

18. USDA Forest Service Air Quality Conformity Handbook

19. USDA Forest Service Desk Reference for NEPA Air Quality Analysis

20. US Fish & Wildlife Service Fire Management Handbook

21. NWCG Smoke Management Guide for Prescribed and Wildland Fire

22. NWCG Wildland & Prescribed Fire Mgmt Po licy Implementation Procedures Reference

Guide

Tribal Laws & Plans

A number of potential sources were contacted in an effort to obtain information on tribal

laws, programs and plans. Calls to EPA Regions 8, 9 and 10 indicated that (1) EPA could

not provide Tribal Implementation Plans or relevant Federal Implementation Plans and (2)

EPA could not provide tribal smoke management plans. Other calls to the White Mountain

Apache Tribe, the Intertribal Forestry Counc il, the Institute for Tribal Environmental

Professionals (ITEP) and BIA staff at the Nati onal Interagency Fire Center all failed to

produce any guidance documents that (1) could be made available for review or (2) were in

existence somewhere else. A study by ITEP (a vailable on the WRAP website) indicated that

15 tribes have smoke management plans, but t hose tribes were not id entified in the study.

ITEP has been a tribal liaison for FEJF in the pa st, but ITEP was not able to provide the types

of documents needed in the timeframe available for the project.Appendix C. Evaluation Results and Review Comments for Guidance DocumentsPage 1GuidanceTypeAgencyGuidance TitleCriterion 1Criterion 2Criterion 3Criterion 4Criterion 5Criterion 6Criterion 7Criterion 8Response Comment Response Comment Response Comment Response CommentResponse Comment ResponseComment Response Comment Response CommentStateAlaskaAlaska Department ofNoNoNoNoNoGuidance on openNoNoNoNoNoNoNoNoNoNoDepartment ofEnvironmentalburning laws, onlyEnvironmentalConservation OpenConservationBurning Rule18AAC50. Jan. 1997.AlaskaAlaska Open BurningNoNoNoNoNoConformity notNoNoYesNAAQSNoNoNoNo. Burners mustNoNoDepartment ofPolicy and Guidelinesmentionedspecify how publicEnvironmentalwill be adviseConservationArizonaForest and RangeNoNoYesR18-2-1509; BestNoConformity notNoNoNoNoNoNoNoNoNoNoDepartment ofManagement Burns:ManagementmentionedEnviron. QualityTitle 18, Chapter 2,PracticesArticle 15ArizonaState of ArizonaNoNoYesUnder BMPNoConformity notNoPlan only requiresNoNoYesUnderNoNoNoNoDepartment ofSmoke Managementrequirementsmentionedthat this be doneBMP-ManagingEnviron. QualityPlan: Title 18,Smoke ImpactsChapter 3. Dept. EnvQual. Article 15.California AirProposedNoNoYesPage 19. Brief.NoNo. Conformity notNoNoNoNoNoNoNoNoNoNoResources BoardAmendments todiscussedCalifornia'sAgricultural BurningGuidelines: StaffReport. February 2000California EPATitle 17, CaliforniaNoNoNoNo. If done, it mustNoConformityYesNoOnly with referenceNoNoNoNoNoNoCode of Regulationsbe attached to burnto NAAQSSubchpt 2: Smokeplan.Management forAgriculture & Rx FireColoradoColorado OpenNoNoNoNoNoConformity notNoNoNoNoNoNoNoNoNoNoDepartment ofBurning RulesmentionedPublic HealthDocument E008. Nov.24, 1995ColoradoColorado SmokeNoNoYesRequired. FormNoConformityYesSASEM modelingYesNAAQS; <20YesRequiredYesPublic notificationNoNoDepartment ofManagement MOU.SMP-Cguidance inrequired;deciviewreq'd. AgencyPublic HealthJan 1, 2001Appendix Fcontacts listedColorado StateDesk Guide for CSFSNoState does not doYesYesYesYesYesNoNoNoNoForest ServicePrescribed FireNEPAProceduresMontanaState of MontanaNoNoNoNoNoConformity notNoNoNoNoNoNoNoNoNoNoDepartment ofOpen Burning RulementionedEnvironmentalChapter 8,QualitySub-Chapter 6Montana/IdahoMontana/IdahoNoNoNoNo. Encourages useNoConformity notNoNoNo definition ofNoNoNoNoNoNoAirshed GroupAirshed Groupof alternativementioned"intrusion" providedOperating Guide.methodsAug. 2001Nevada DivisionNevada SmokeNoNoYesDetailed descriptionNoConformity notYesDistance from ClassYesNAAQSYesRequires that suchYesAffected agencyNoNoofManagement Plan -of alternativesmentionedI & nonattainmentplans be identifiednotification requiredEnvironmentalJuly 6, 1999requiredareasby burnersProtectionAppendix C. Evaluation Results and Review Comments for Guidance DocumentsPage 2GuidanceTypeAgencyGuidance TitleCriterion 1Criterion 2Criterion 3Criterion 4Criterion 5Criterion 6Criterion 7Criterion 8Response Comment Response Comment Response Comment Response CommentResponse Comment ResponseComment Response Comment Response CommentStateNew MexicoNew Mexico SmokeNoNoNoNoNoConformity notYesEmissionYesNAAQSYesManagers mustNoNo. Burners mustNoNoEnvironmentManagement MOUmentionedcalculationshave contingencynotify local officialsDepartment1997-2002plans.OregonOregon Open BurningNoNoNoNoNoConformity notNoNoNoNoNoNoNoNoNoNoDepartment ofRules Division 264mentionedEnvironmental(Nov. 15, 2001)QualityOregonOregon SmokeNoNoNoNoNoConformity notYesEmissionYesLight scattering andYesDirectives AppendixYesNoNoDepartment ofManagement Planmentionedcalculationsvisibility4Forestryand RulesOregon Dept.Field Burning PermitNoNoNoNoNoNo. Conformity notNoNoNoNoNoNoNoNoNoNoAgricultureAgent Manual:mentionedWillamette Valley,Oregon. March 2001UtahUtah EmissionNoNoYesDescription requiredYesR307-204-7(k)YesEmissionYesNAAQS:YesContingency planNoNoNoNoDepartment ofStandards: SmokecalculationsrequiredEnvironmentalManagement. RuleQuality307-204. Sept 1, 2001Utah Division ofUtah SmokeNoNoNoNoNoConformity notYesRequires dailyNoNoNoNoYesPublic notificationYesEastern Great BasinAir QualityManagement Planmentionedemissions estimatesrequiredCoord Center does7/20/00 Rev. 3/23/00daily reportWashingtonAgricultural BurningNoNoYesGrowers reqd toNoNo mention ofNoNoNoNoNoNoNoNoNoNoDepartment ofPermit ApplicationevaluateconformityEcologyand BestManagementWashingtonWashington StateNoNoYesAlternative useNoConformity notYesRequirements toNoNoNoNoYesNoNoDepartment ofSmoke Managementrequired whenmentionedcalculate emissionsNaturalPlan. Rev. 1995.possibleResourcesWyoming DEQWyoming SmokeNoNoNoNoNoConformity notNoNoNoNoNoNoNoNoNoNoManagement Chaptermentioned10LocalAmador CountyAmador County AirNoNoNoNoNoConformity notNoNoNoNoNoNoNoNoNoNoCAPollution ControlmentionedDistrict Open BurningRulesAntelope ValleyAntelope ValleyNoNoNoNoNoConformity noNoNoNoNoNoNoNoNoNoNoAPCDAPCD Open FiresreferencedBay Area AQMDBay Area AQMD OpenNoNoNoNoNoConformityNoNoNoNoNoNoNoNoNoNoBurning Regulation 5Boulder CountyAir Quality/PrescribedNoNoYesBriefNoNo discussion ofYesBrieflyNoNoYesBrieflyNoNoNoNoHealthFire GuidanceconformityDepartmentDocumentBoulder CountyOpen Burning PolicyNoNoNoNoNoNoYesSASEM modelingNoNoNoNoNoNoNoNoHealthrequiredDepartmentAppendix C. Evaluation Results and Review Comments for Guidance DocumentsPage 3GuidanceTypeAgencyGuidance TitleCriterion 1Criterion 2Criterion 3Criterion 4Criterion 5Criterion 6Criterion 7Criterion 8Response Comment Response Comment Response Comment Response CommentResponse Comment ResponseComment Response Comment Response CommentLocalButte CountyButte County AQMDNoNoNoNoNoConformityNoNoNoNoNoNoNoNoNoNoAQMDOpen Burning Rule300, 309CalaverasCalaveras CountyNoNoNoNoNoConformityNoNoNoNoNoNoNoNoNoNoCounty APCDAPCD Open BurningRule 300Colusa CountyColusa County APCDNoNoNoNoNoConformityNoNoNoNoNoNoNoNoNoNoAPCDReguation VIAgricultural BurningRule 6.18 & 6.19Feather RiverFeather River AQMDNoNoNoNoNoConformity notNoNoNoNoNoNoNoA notificationNoNoAQMDOpen Burning Rulementonedprocedure must be2.17 & 2.8: WildlandsubmittedVeg. & Range BurningGreat BasinGreat Basin UnifiedNoNoNoAnalysis must beNoConformity notNoNoNoNoNoNoNoPublic notificationNoNoUnified APCDAPCD Wildland Veg.attached to burnmentionedprocedures need beBurning & ForestapplicationsubmittedManagement BurningRules 410, 411Mariposa CountyMariposa CountyNoNoNoNoNoBurn permitNoNoNoNoNoNoNoNo but procdures toNoNoAPCDAPCD Rule307requirements.distribute burn infoWildland BurningConformityis reqdMissoula CountyIt's Fall: Why Can't INoNoNoNoNoNoNoNoNoNoNoNoNoNoNoNoHealth Dept.Burn?Missoula CountyMissoula County OpenNoNoNoNoNoConformity notNoNoYesNAAQSNoNoNoNoNoNoHealth Dept.Burning Rules,mentionedChapter 7Northern SierraNorthern Sierra AQMDNoNoNoNoNoPermit requirementsNoNoNoNoNoNoNoNoNoNoAQMDOpen Burn Rulesonly. Conformity300,306, 307 & 315not mentionedPlacer Cty APCDPlacer County APCDNoNoNoNoNoBurn permitNoNoNoNoNoNoNoNoNoNoOpen Burning Rulerequirments only316 & 317 WildlandFire and Veg.Management RulesSacramentoSacramento AQMDNoNoNoNoNoRequirements forNoNoNoNoNoNoNoNo. Method ofNoNoCounty AQMDAgricultural BurningOB Permitpublic notificationRule 501 (Applies tomust be specifidforestry burning)SacramentoSacramento ValleyNoNoNoNoNoNoNoNoNoNoNoNoNoNoNoNoValley AQMDSmoke ManagementProgram. June, 2001San JoaquinSan Joaquin APCDNoNoYesRequires descriptionNoBurn planYesRequries ID ofNoNoYesRequires thatYesRequires descriptionNoNoAPCDPrescribed Burningof BACMrequirements onlysmoke sensitivecontingencies beof publicRule 4106consideredbut not conformityareasidentifiednotification methodSan JoaquinSan Joaquin ValleyNoNoYesBACM WorkplanNoConformity notYesRequries calculationNoNoNoNo. Does requireNoNoNoNoValley UnifiedUnified APCDSec.7mentionedof emissionsdescription ofAPCDPrescribed Burningmethods to be usedMOU (7/21/97 Draft)Appendix C. Evaluation Results and Review Comments for Guidance DocumentsPage 4GuidanceTypeAgencyGuidance TitleCriterion 1Criterion 2Criterion 3Criterion 4Criterion 5Criterion 6Criterion 7Criterion 8Response Comment Response Comment Response Comment Response CommentResponse Comment ResponseComment Response Comment Response CommentLocalSeven AirNortheast Air AllianceNoNoNoNo but requires anNoNoNoNo but requires anNoNoNoNo but requiresNoNoNoNoDistricts inSmoke Managementanalysis be doneestimate becontingencies beNorthern CAPlansubmittedidentifiedShasta CountyShasta County AQMDNoNoYesEvaluation ofNoConformity notNoNoNoNoYesContingency actionNoNo. PublicNoNoAQMDOpen & Ag. Burningalternatives must bementionedmust be describednotificationRules 2:6-attachedprocedures requiredSiskiyou CountySiskiyou County APCDNoNoNoNoNoConformity notNoNoNoNoNoNoYesRequires aNoNoAPCDOpen Burning Rulementionedprocedure to7.1; 7.5disseminate projectinfo.South CoastSouth Coast AQMDNoNoNoNoYesRule 1901. AppliesNoNoNoNoNoNoNoSpecs forNoNoAQMDOpen Fires Rule 444;to federal actionsdisseminatingConformity Rule 1901project info isrequiredTuolumneTuolumne CountyNoNoNoNoNoConformity notNoNoNoNoNoNoNoSpecs. ForNoNoCounty APCDAPCD Open BurnmentioneddisseminatingRule 300; Wilalandproject info requiredVeg. ManagementBurning Rule 307,FederalCongress/EPAClean Air Act Title 1NoNoNoNoNoThis section doesNoNoNoNoNoNoNoNoNoNoPart A: Air Quality andnot includeEmission LimititationsConformitySectioins 101-131Congress/EPAClean Air Act Title 1NoNoNoNoNoConformity not inNoNoYesPSD incrementsNoNoNoNoYesIf applicable toPart C Prevention ofthis section of theprescribed fireSignificantCAADeterioration Sec. 160- 169.Congress/EPAClean Air Act Title 1NoNoNoNoYesConformity sectionNoNoNoNoNoNoNoNoNoNoPart D Section 176cof the CAAInteragencyNWCG Wildland &NoNoYesNoNoYesNoNoYesYesNoPrescribed Fire MgmtPolicyImplementationProcedures ReferenceNational WildfirePrescribed Fire SmokeNoNoNoNoNoNothing onYesNoNoNoNoNoNoNoNoCoordinatingManagement Guide,ConformityGroupFeb. 1985National WildfireSmoke ManagementNoNoYesExtensiveYesPart I Sections 4.1YesYesPart I Section 3.3YesYesYesCoordinatingGuide for Prescribedand 4.2Groupand Wildland Fire2000 Edition (draft)National WildfireSmoke ManagementNoNoYesYesYesNoNoYesYesNoNoCoordinatingTechniques: RX-450GroupInstructor and StudentGuidesUS EPA40 CFR Chapter 1,NoNoYes51.309 (d) (6) (iii)NoVisibility ProtectionYesYesSec. 51.301YesGeneralNoNoNoNoSubpart C, Part 51requirements, Excldefinition of adverserequirements ofSubpart P - ProtectionConform.impactof VisibilityAppendix C. Evaluation Results and Review Comments for Guidance DocumentsPage 5GuidanceTypeAgencyGuidance TitleCriterion 1Criterion 2Criterion 3Criterion 4Criterion 5Criterion 6Criterion 7Criterion 8Response Comment Response Comment Response Comment Response CommentResponse Comment ResponseComment Response Comment Response CommentFederalUS EPAInterim Air QualityNoNoYesBrief descriptionYesSection IX AYesBrieflyNoNoNoNoYesYesBrieflyPolicy on Wildlandand Prescribed FiresUS EPA OAQPSPrescribed BurningNoNoYesExtensiveNoConformityYesYesIn State smokeYesYesBriefly in stateNoNoSept 92Background Documentmanagement plansmoke planand TechnicalsummariessummariesInformation Documentfor Prescribed BurnBACMUS Fish andFire ManagementNoNoNoNoNoConformity notNoNoNoNoNoNoNoNoNoNoWildlife ServicePolicies andspecifically notedResponsibilities forFire Managers Part621 Chpt. 3US Fish andUSFWS - FireYesYesYesYesYesYesYesNoWildlife ServiceManagementHandbookUSDA ForestA Desk Reference forYesPg. 2-9. Refers toYesPg. 3.1.2-7.YesPage 2-6 to 2-8.YesChapter 3.YesPage 2-14.NoNoNoServiceNEPA Air QualityFSH 1909.15.AnalysisUSDA ForestAir Quality ConformityNoNoYesYesNoNAAQS impliedNoNoNoServiceHandbookUSDA ForestDescribing AirYesYesAppendix ANoConformity notYesFuels consumptionYesNAAQSNoNoNoNoNoNoServiceResource Impacts fromspecificallyand emissionPrescribed FireaddressedestimatesProjects in NEPADocuments forMontana & IdahoUSDA ForestGuidelines forNoNot directly. WhenYesYesConformityYesEmissionsNoNoNoNoNoNoNoNoServicePreparing a NEPA AirNEPA anal. Isdiscussion includedcalculationsQuality Analysisneeded included.guidanceUSDA ForestUSDA Forest ServiceNoNoYesYesYesYesYesYesNoServiceManual System 2580& 5100USDA Forest Desk Guide for Integra- No No Yes Yes No No No NoService ting Air Quality and FireManagement into Land Management PlanningUSDI Bureau ofUSDI Bureau of LandYesRef. Manual 516YesApp C Page 9YesApp. C Page 2NoNoNoNoNoNoNoNoNoNoLandManagement LandDM2, App1 and 516ManagementUse PlanningDM6 App 5.4Handbook H-1601-1USDI Bureau ofUSDI Bureau of LandNoNoNoNoYesRequiresNoNoNoNoNoNoNoNoNoNoLandManagement Manualcompliance withManagement1601: Land UseFed., state, localPlanningregs.USDI NationalNPS Director's OrderYesSecs. 3.0 has anNoNoNoConformity notNoNoNoNoNoNoNoNoNoNoPark Service12: NEPAextensive discussionspecifically notedUSDI NationalUSDI National ParkNoNoYesItem 10a describesNoItem 10F requiresNoNoNoNoNoNoNoNoNoNoPark ServiceService Director'smechanicalair rule complianceOrder #18: Wildlandtreatment. Vs fireFire Management.Nov. 17, 1998