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 Provide 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 for 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 Implementation 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 Oversight 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 with making recommendations on strategies and 

methods to manage emissions from prescribed fire. 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 address 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 consideration given to smoke impacts in fire 

planning documents, and this was the overall 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 perform 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 implementation of operational plans for prescribed fires 

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

• identify and summarize relevant guidance documents for agencies on consideration of 

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

and 

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

assessing air quality effects for wildfire and WFU incidents. 

Prescribed Fire is defined as a management-ignited 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-ignited fires to accomplish specific, pre-stated 

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

governing programmatic plan. Prescribed Natural 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 agencies 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 established by the Federal Land Managers that 

evaluates alternative management strategies related to firefighter safety, environmental, 

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

only apply to wildland fires on federally managed 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 and 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 includes 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 applicable to federal processes. Not every land 

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

was not necessarily available from every land manager. In addition, there 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 designated 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 contents 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 the 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 true condition elicits an affirmative response. The 

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

transferred to an electronic database developed specifically to contain project information, 

to facilitate analysis of the results. The database enabled the project team to view data in 
4 

both specific and anonymous terms as the project 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 

U.S. Fish and Wildlife Service 2 

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 

Private Plum Creek Timber 

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 management plans for prescribed fire and/or WFU 

that include fuel treatment activities at a program 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 management unit (e.g., a BLM district or national 

forest). Comparable planning documents are uncommon outside federal agencies for 

burning that occurs on private lands, tribal lands 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 types 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 effects 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 for 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 terminology, 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 documentation 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 and 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 visibility-impairing air pollutants and their 

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

2. Did the document discuss actions to be taken 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 receptors, 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 discussion, 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 and 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 receptors, 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 implementation reports seem to be uncommon, so the 

“implementation plan” often consisted of field 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 diligence of the providing agency. 

2.3 Guidance Documents 

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

effects of prescribed fire and WFU smoke effects, available guidance documents were 
8 

gathered and evaluated. An initial set of guidance 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 requirements, national smoke management guidance and 

training materials, agricultural burning smoke management program documents from 

Oregon and Washington, as well as federal and 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 guidance 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 when 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 example, 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 providing agency. The project team mentioned some 
9 

desired characteristics of the plans to be reviewed (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 addition, the project team had no access to the 

agency files and therefore had no control over 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 project 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 type. The tables show the total number of each 

type of plan reviewed, the number of those plans 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 could 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 findings regarding tribal activities. This outcome 

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

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

Indian Affairs), and (2) an official request process 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 Management 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 issues 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 programmatic plans were received from federal 

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

fire planning document), and one tribal prescribed 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 plans prepared by federal agencies indicates 

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

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

visibility. Many of the plans defer such matters 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 techniques 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 the 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 

Criteria 

Count Percent Count Percent Count Percent 

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 Responses for Programmatic Plans for WFU 

Agency 

Type 

Federal 

Criteria 

Count Percent 

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 discussed the laws that the plans must comply with, 

and this was often done in terms of the governing 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 this 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 federal activities (e.g., prescribed fire) in areas 

that are nonattainment or maintenance areas for 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 atmospheric conditions must be favorable for the 

action to proceed, although the required atmospheric 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 reviewed. 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 for Operational Plans for Prescribed Fire 

Agency Type 

Tribal Private Local State Federal 

Criteria 

Count Percent Count Percent Count Percent Count Percent Count Percent 

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 plans 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 categories 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 agencies 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

Conformity

Criteria

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 burning 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 department that provided an operational plan for 

prescribed fire that resembled the operational 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 obtained from a tribal organization. All of the 

project document types discussed in this section 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 over 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 and 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 criteria fell somewhere in between, but were 

generally relatively high. 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 

affirmative response when following the wording 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 ignition 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 methods 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 would take place. The most common form of 

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

instrument monitoring was mentioned. 

♦ Criterion 6: Predetermined trigger points 

For about half the federal reports the most common 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 was 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 applicable” 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 reviewed 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 consideration. 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), there are two affirmative responses. Two of the 

reports indicated that emissions had been estimated 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 

Criteria 

Count Percent 

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 actions 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 coordination 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 burning 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 wording of the criterion. When the regional haze 

portion of the criterion is ignored (Table 6 Line 1a), there is one affirmative 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 Responses for Operational Plans for WFSA 

Agency 

Type 

Federal 

Criteria 

Count Percent 

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 implementation 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 received 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 programs, 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 following 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 

Criteria 

Count Percent Count Percent Count Percent 

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 specified 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 halted. 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 data 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 impacts

Criteria

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 implementation 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 Responses for Implementation of WFU 

Agency 

Type 

Federal 

Criteria 

Count Percent 

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 federal agencies. Again, these were not truly 

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

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

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

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

documents obtained from a number of sources 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 criteria. 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 smoke 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 these 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. Otherwise, the elements seemed to have 

been implemented. 

♦ Criterion 7: Contingency actions 

In one case, any new fires were extinguished 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 reviewed 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 the 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 

Criteria 

Count Percent Count Percent Count Percent 

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 quality 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 smoke 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 qualitative terms. Less than one-fifth of the federal 

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

management plans include centralized, daily burn authorization to coordinate burning 

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

programs also coordinate with WFU or agricultural or general open burning activity. 

Guidance on quantitative assessment of cumulative impacts of smoke is in the realm of 

regional transport modeling, not the practitioner guidance/air quality regulations 

reviewed here. Fire practitioners are typically 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 consisted of open burning permit requirements 

that are intended to minimize the nuisance effects 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 dealt 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 commonly 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

Smoke

Criteria

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. Many of these documents are widely used by 

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

policy, fire planning and regulatory issues that 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 significance, 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 state smoke management plans for both wildland 

fire and agricultural burning. They describe air 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 practitioners 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 included 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 almost solely limited to local air quality open 

burning and, in a few cases, smoke management 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 regulations 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 Service 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 the prescribed fire/WFU planning process is a 

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

newly published federal guidance documents now include more guidance on this topic. 

For example, the 1985 NWCG Prescribed Fire 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 and 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 new 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 treatments 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 commonly 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 evaluation of the effect of these pollutants on 

Class I visibility. The federal guidance (Table 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 guidance 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 Predetermined 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 documents reviewed used a quantitative measure of 

extinction (light scattering) as a “trigger point” 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 “significant contribution” to particulate matter 

under the NAAQS. 

♦ Criterion 6: Contingency Actions 

About one-third of the state and federal documents 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 measures 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 rapid mop-up and fuels isolation. Section VI.C.3 

of the EPA Interim Air Quality Policy on Wildland 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 all) through the respective smoke management 

program. About one-third of the federal guidance 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 cumulative 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 discusses the role of smoke in regional haze, 

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

and research activities. Comprehensive guidance 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 some holes in the agency/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 certain plan types, so they had no plans to 

contribute to the project. Other contacts chose 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 findings 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 project 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-federal) 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 variable. The results regarding the evaluation 

criteria were somewhat mixed, but, in general, the plans addressed the criteria 

reasonably well. 

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

fires. 

• Guidance documents for programmatic and operational plan preparation were 

reviewed. The findings were that there was often 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 Programmatic 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 Programmatic 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 Programmatic 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 Pacific West Programmatic Rx Yosemite Fire Management 

Plan 1991 
Agency 

Type Agency Region Plan Type Plan/Burn Name 

Federal National Park Service Pacific 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 Implemented 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 Programmatic Rx Bridger-Teton Forest Fire 

Management Plan 

U.S. Forest Service 4 Programmatic 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 Programmatic Rx Sierra Nevada Forest Plan 

Amendment 

U.S. Forest Service 5 Programmatic 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 Implemented Rx Rabbit Mtn.-Little 

Thompson Overlook 

Boulder County Colorado Operational 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 Operational 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 Operational Rx Yuma County Pest Control 

State of Idaho Ag Operational Rx Field Burning Registration 

From & Rules 

State of Montana Ag Operational Rx 2001 USFS Region 1 

permit 

State of Oregon Ag Operational Rx Not specified 

State of Washington Ag Operational 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 Quality 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 Air 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 Management 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 Prescribed 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 Policy 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 Council, the Institute for Tribal Environmental 

Professionals (ITEP) and BIA staff at the National 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 (available on the WRAP website) indicated that 

15 tribes have smoke management plans, but those tribes were not identified in the study. 

ITEP has been a tribal liaison for FEJF in the past, 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 Documents 

Guidance Type Agency Guidance Title Criterion 1 Criterion 2 Criterion 3 Criterion 4 Criterion 5  Response Comment Response Comment Response Comment Response Comment Response Comment State Alaska Alaska Department of No No No No No Guidance on open No No No No 

Department of Environmental burning laws, onlyEnvironmental Conservation Open Conservation Burning Rule 

18AAC50. Jan. 1997.

Alaska Alaska Open Burning No No No No No Conformity not No No Yes NAAQS Department of Policy and Guidelines mentioned Environmental ConservationArizona Forest and Range No No Yes R18-2-1509; Best No Conformity not No No No No Department of Management Burns: Management mentionedEnviron. Quality Title 18, Chapter 2, Practices

Article 15

Arizona State of Arizona No No Yes Under BMP No Conformity not No Plan only requires No No Department of Smoke Management requirements mentioned that this be done Environ. Quality Plan: Title 18, 

Chapter 3. Dept. Env Qual. Article 15.

California Air Proposed No No Yes Page 19. Brief. No No. Conformity not No No No No Resources Board Amendments to discussed

California's Agricultural Burning Guidelines: Staff Report. February 2000

California EPA Title 17, California No No No No. If done, it must No Conformity Yes No Only with referen

Code of Regulations be attached to burn to NAAQSSubchpt 2: Smoke plan.Management for Agriculture & Rx Fire

Colorado Colorado Open No No No No No Conformity not No No No No Department of Burning Rules mentionedPublic Health Document E008. Nov. 

24, 1995

Colorado Colorado Smoke No No Yes Required. Form No Conformity Yes SASEM modeling Yes NAAQS; <20 Department of Management MOU. SMP-C guidance in required; deciview Public Health Jan 1, 2001 Appendix F Colorado State Desk Guide for CSFS No State does not do Yes Yes Yes Yes Forest Service Prescribed Fire NEPA

Procedures

Montana State of Montana No No No No No Conformity not No No No No Department of Open Burning Rule mentionedEnvironmental Chapter 8, Quality Sub-Chapter 6Montana/Idaho Montana/Idaho No No No No. Encourages use No Conformity not No No No definition of Airshed Group Airshed Group of alternative mentioned "intrusion" provid

Operating Guide. methodsAug. 2001

Nevada Division Nevada Smoke No No Yes Detailed description No Conformity not Yes Distance from Class Yes NAAQS of Management Plan - of alternatives mentioned I & nonattainment Environmental July 6, 1999 required areas Protection
Appendix C. Evaluation Results and Review Comments for Guidance Documents 

Guidance Type Agency Guidance Title Criterion 1 Criterion 2 Criterion 3 Criterion 4 Criterion 5  Response Comment Response Comment Response Comment Response Comment Response Comment State New Mexico New Mexico Smoke No No No No No Conformity not Yes Emission Yes NAAQS 

Environment Management MOU mentioned calculations Department 1997-2002 Oregon Oregon Open Burning No No No No No Conformity not No No No No Department of Rules Division 264 mentionedEnvironmental (Nov. 15, 2001)QualityOregon Oregon Smoke No No No No No Conformity not Yes Emission Yes Light scattering aDepartment of Management Plan mentioned calculations visibility Forestry and RulesOregon Dept. Field Burning Permit No No No No No No. Conformity not No No No No Agriculture Agent Manual: mentioned

Willamette Valley, Oregon. March 2001

Utah Utah Emission No No Yes Description required Yes R307-204-7(k) Yes Emission Yes NAAQS: Department of Standards: Smoke calculations Environmental Management. Rule Quality 307-204. Sept 1, 2001Utah Division of Utah Smoke No No No No No Conformity not Yes Requires daily No No Air Quality Management Plan mentioned emissions estimates 

7/20/00 Rev. 3/23/00 

Washington Agricultural Burning No No Yes Growers reqd to No No mention of No No No No Department of Permit Application evaluate conformityEcology and Best 

Management 

Washington Washington State No No Yes Alternative use No Conformity not Yes Requirements to No No Department of Smoke Management required when mentioned calculate emissionsNatural Plan. Rev. 1995. possibleResourcesWyoming DEQ Wyoming Smoke No No No No No Conformity not No No No No 

Management Chapter mentioned10

Local Amador County Amador County Air No No No No No Conformity not No No No No 

CA Pollution Control mentioned

District Open Burning Rules

Antelope Valley Antelope Valley No No No No No Conformity no No No No No APCD APCD Open Fires referencedBay Area AQMD Bay Area AQMD Open No No No No No Conformity No No No No 

 Burning Regulation 5

Boulder County Air Quality/Prescribed No No Yes Brief No No discussion of Yes Briefly No No Health Fire Guidance conformityDepartment DocumentBoulder County Open Burning Policy No No No No No No Yes SASEM modeling No No Health requiredDepartment
Appendix C. Evaluation Results and Review Comments for Guidance Documents 

Guidance Type Agency Guidance Title Criterion 1 Criterion 2 Criterion 3 Criterion 4 Criterion 5  Response Comment Response Comment Response Comment Response Comment Response Comment Local Butte County Butte County AQMD No No No No No Conformity No No No No 

AQMD Open Burning Rule 

300, 309

Calaveras Calaveras County No No No No No Conformity No No No No County APCD APCD Open Burning 

Rule 300

Colusa County Colusa County APCD No No No No No Conformity No No No No APCD Reguation VIAgricultural Burning 

Rule 6.18 & 6.19

Feather River Feather River AQMD No No No No No Conformity not No No No No AQMD Open Burning Rule mentoned 

2.17 & 2.8: Wildland Veg. & Range Burning

Great Basin Great Basin Unified No No No Analysis must be No Conformity not No No No No Unified APCD APCD Wildland Veg. attached to burn mentioned 

Burning & Forest application Management Burning Rules 410, 411

Mariposa County Mariposa County No No No No No Burn permit No No No No  APCD APCD Rule307 requirements. 

Wildland Burning Conformity 

Missoula County It's Fall: Why Can't I No No No No No No No No No No  Health Dept. Burn?Missoula County Missoula County Open No No No No No Conformity not No No Yes NAAQS  Health Dept. Burning Rules, mentioned

Chapter 7

Northern Sierra Northern Sierra AQMD No No No No No Permit requirements No No No No AQMD Open Burn Rules only. Conformity 

300,306, 307 & 315 not mentioned

Placer Cty APCD Placer County APCD No No No No No Burn permit No No No No 

Open Burning Rule requirments only316 & 317 Wildland Fire and Veg. Management Rules

Sacramento Sacramento AQMD No No No No No Requirements for No No No No County AQMD Agricultural Burning OB Permit 

Rule 501 (Applies to forestry burning)

Sacramento Sacramento Valley No No No No No No No No No No Valley AQMD Smoke Management 

Program. June, 2001

San Joaquin San Joaquin APCD No No Yes Requires description No Burn plan Yes Requries ID of No No APCD Prescribed Burning of BACM requirements only smoke sensitive 

Rule 4106 considered but not conformity areas 

San Joaquin San Joaquin Valley No No Yes BACM Workplan No Conformity not Yes Requries calculation No No Valley Unified Unified APCD Sec.7 mentioned of emissions APCD Prescribed Burning 

MOU (7/21/97 Draft)
Appendix C. Evaluation Results and Review Comments for Guidance Documents 

Guidance Type Agency Guidance Title Criterion 1 Criterion 2 Criterion 3 Criterion 4 Criterion 5  Response Comment Response Comment Response Comment Response Comment Response Comment Local Seven Air Northeast Air Alliance No No No No but requires an No No No No but requires an No No 

Districts in Smoke Management analysis be done estimate be Northern CA Plan submitted Shasta County Shasta County AQMD No No Yes Evaluation of No Conformity not No No No No AQMD Open & Ag. Burning alternatives must be mentioned 

Rules 2:6- attached 

Siskiyou County Siskiyou County APCD No No No No No Conformity not No No No No APCD Open Burning Rule mentioned 

7.1; 7.5 

South Coast South Coast AQMD No No No No Yes Rule 1901. Applies No No No No AQMD Open Fires Rule 444; to federal actions 

Conformity Rule 1901 

Tuolumne Tuolumne County No No No No No Conformity not No No No No County APCD APCD Open Burn mentioned 

Rule 300; Wilaland Veg. Management Burning Rule 307, 

Federal Congress/EPA Clean Air Act Title 1 No No No No No This section does No No No No 

Part A: Air Quality and not include Emission Limititations ConformitySectioins 101-131

Congress/EPA Clean Air Act Title 1 No No No No No Conformity not in No No Yes PSD increments 

Part C Prevention of this section of the Significant CAADeterioration Sec. 160 - 169.

Congress/EPA Clean Air Act Title 1 No No No No Yes Conformity section No No No No 

Part D Section 176c of the CAA

Interagency NWCG Wildland & No No Yes No No Yes No No 

Prescribed Fire Mgmt Policy Implementation Procedures Reference 

National Wildfire Prescribed Fire Smoke No No No No No Nothing on Yes No No Coordinating Management Guide, ConformityGroup Feb. 1985National Wildfire Smoke Management No No Yes Extensive Yes Part I Sections 4.1 Yes Yes Part I Section 3.3 Coordinating Guide for Prescribed and 4.2Group and Wildland Fire 

2000 Edition (draft)

National Wildfire Smoke Management No No Yes Yes Yes No No Coordinating Techniques: RX-450 Group Instructor and Student 

Guides

US EPA 40 CFR Chapter 1, No No Yes 51.309 (d) (6) (iii) No Visibility Protection Yes Yes Sec. 51.301 

Subpart C, Part 51 requirements, Excl definition of adveSubpart P - Protection Conform. impact of Visibility
Appendix C. Evaluation Results and Review Comments for Guidance Documents 

Guidance Type Agency Guidance Title Criterion 1 Criterion 2 Criterion 3 Criterion 4 Criterion 5  Response Comment Response Comment Response Comment Response Comment Response Comment Federal US EPA Interim Air Quality No No Yes Brief description Yes Section IX A Yes Briefly No No 

Policy on Wildland and Prescribed Fires

US EPA OAQPS Prescribed Burning No No Yes Extensive No Conformity Yes Yes In State smoke  Sept 92 Background Document management pla

 and Technical summaries Information Document for Prescribed Burn BACM

US Fish and Fire Management No No No No No Conformity not No No No No Wildlife Service Policies and specifically noted

Responsibilities for Fire Managers Part 621 Chpt. 3

US Fish and USFWS - Fire Yes Yes Yes Yes Yes Wildlife Service Management 

Handbook

USDA Forest A Desk Reference for Yes Pg. 2-9. Refers to Yes Pg. 3.1.2-7. Yes Page 2-6 to 2-8. Yes Chapter 3. Yes Page 2-14. Service NEPA Air Quality FSH 1909.15.

Analysis

USDA Forest Air Quality Conformity No No Yes Yes No NAAQS implied Service HandbookUSDA Forest Describing Air Yes Yes Appendix A No Conformity not Yes Fuels consumption Yes NAAQS Service Resource Impacts from specifically and emission 

 Prescribed Fire addressed estimatesProjects in NEPA Documents for Montana & Idaho

USDA Forest Guidelines for No Not directly. When Yes Yes Conformity Yes Emissions No No Service Preparing a NEPA Air NEPA anal. Is discussion included calculations 

Quality Analysis needed included. guidance

USDA Forest USDA Forest Service No No Yes Yes Yes Yes Service Manual System 2580 

& 5100

 USDA Forest Desk Guide for Integra- No No Yes Yes No  Service ting Air Quality and Fire  Management into Land Management Planning 

USDI Bureau of USDI Bureau of Land Yes Ref. Manual 516 Yes App C Page 9 Yes App. C Page 2 No No No No Land Management Land DM2, App1 and 516Management Use Planning DM6 App 5.4

Handbook H-1601-1

USDI Bureau of USDI Bureau of Land No No No No Yes Requires No No No No Land Management Manual compliance with Management 1601: Land Use Fed., state, local 

Planning regs.

USDI National NPS Director's Order Yes Secs. 3.0 has an No No No Conformity not No No No No Park Service 12: NEPA extensive discussion specifically notedUSDI National USDI National Park No No Yes Item 10a describes No Item 10F requires No No No No Park Service Service Director's mechanical air rule compliance

Order #18: Wildland treatment. Vs fireFire Management. 

Nov. 17, 1998