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Utah 

Enhanced Smoke Management Plan 

August 11, 2003 
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Utah Enhanced Smoke Management Plan 

Table of Contents 

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I. Purpose..............................................................................3 

II. Goals.................................................................................3 

III. Scope.................................................................................3 

IV. Definitions...........................................................................4 

V. Elements of Utah Enhanced Smoke Management Program...............4 

a. Actions to Minimize Emissions from Fire.................................4 

b. Evaluation of Smoke Dispersion............................................5 

c. Alternatives to Fire............................................................7 

d. Public Notification.............................................................8 

e. Air Quality Monitoring.......................................................8 

f. Surveillance and Enforcement...............................................8 

g. Program Evaluation............................................................9 

h. Burn Authorization............................................................9 

i. Regional Coordination.........................................................9 

j. Evaluation Criteria............................................................10 
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Utah Enhanced Smoke Management Program 

August 11, 2003 

I. PURPOSE 

The purpose of this Utah Enhanced Smoke Management Plan (ESMP) is to 

identify the responsibilities of the Utah Division of Air Quality (UDAQ) and 

Federal, and State land managers (Land Managers) to coordinate procedures 

that mitigate the impacts of prescribed fire and wildland fire used for 

resource benefits (WFURB) on visibility in mandatory Class I areas. This 

plan is designed to meet the requirements of Section 309 of the federal 

Regional Haze Rule (Rule). As burning activity increases, Land Managers 

and UDAQ may consider strengthening the ESMP as needed to reduce 

impacts on visibility in Class I areas. 

This ESMP is an addendum to the Utah Smoke Management Plan (Utah 

SMP) and may be revised as needed at the end of the 2004 burning season 

and each year thereafter with the concurrence of all signatories to the Utah 

SMP. 

II. GOALS 

• To minimize or prevent smoke impacts to such a degree as possible to protect 

visibility in mandatory Class I areas 

• To develop an ESMP that is based on the criteria of efficiency, economics, 

law, emission reduction opportunities, land management objectives, and 

reduction of visibility impacts in accordance with the Rule 

III. SCOPE 

The ESMP provides direction and operating procedures for Land Managers 

involved in the use of prescribed fire and WFURB fires. The ESMP was 

developed cooperatively by all signatories to the Utah SMP and applies to 

those signatories uniformly across the state of Utah. 

 
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IV. DEFINITIONS (In addition to definitions in Utah SMP) 

Annual Emissions Goal – the annual establishment of a planned quantitative 

value of emissions reductions from prescribed fire. 

Emission Reduction Techniques – techniques for controlling emissions 

from prescribed fires to minimize the amount of emission output per unit or 

acre burned. 

Non-burning Alternatives to Fire – non-burning techniques that are used to 

achieve a particular land management objective, including but not limited to 

reduction of fuel loading, manipulation of fuels, enhancement of wildlife 

habitat, and ecosystem restructuring. These alternatives are designed to 

replace the use of fire for at least the next five years. 

V. ELEMENTS OF UTAH ENHANCED SMOKE MANAGEMENT PLAN 

A. Actions to Minimize Emissions from Fire 

There are a variety of different methods to use to minimize emissions from 

fire depending upon the fire source and management objectives. Utah’s 

ESMP focuses on three general approaches that are designed to minimize 

emissions: use of emission reduction techniques, establishing emissions 

goals, and use of existing burn manager qualification programs. 

Emission Reduction Techniques

An emission reduction technique is a technique for controlling emissions 

from prescribed fires to minimize the amount of emissions produced per 

acre or unit burned. Research has shown that fire emissions can be 

minimized through the use of emission reduction techniques that increase 

combustion efficiency and reduce the smoldering stage of burning. There 

are six general categories of emission reduction techniques: reduce the 

area burned, reduce fuel load, reduce fuel production, reduce fuel 

consumed, schedule burning before new fuels appear, and increase 

combustion efficiency. Under the ESMP, Land Managers will utilize the 

above emission reduction techniques as appropriate to minimize fire 

emissions and provide documentation of the techniques used in the Daily 

Emissions Report. The Annual Emission Goals for Fire will specify the 

types of emission reduction techniques to be utilized on a project specific 

basis. 
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Emissions Goals

As required by the Rule, an annual emission goal will be established to 

minimize emission increases from fire. The emission goal will be 

established prior to the beginning of the fire season, either at the beginning 

of the year or before the year begins. The emission goal will be 

established for the upcoming fire projects and in cooperation with states, 

federal land management agencies, and private entities. 

The quantified benefit from the use of emission reduction techniques 

constitutes the annual emission goal. To establish the goal, emission 

reduction techniques will be determined using feasibility criteria for the 

upcoming prescribed fire projects, and then the benefit from using the 

technique(s) will be quantified. At the end of the fire season, an 

assessment will be made of the techniques applied during the previous fire 

season to verify application. 

Burn Manager Qualification Programs

Burn manager qualification programs have been developed by federal and 

state land management agencies that use prescribed fire as a management 

tool. These burn manager qualification programs include information on 

emission reduction techniques and alternative burning practices as well as 

implementation issues. The benefit of a burn manager qualification 

program is to certify that the land manager is knowledgeable of alternative 

burning practices and emission reduction techniques and has the 

experience to implement them. Under the ESMP, Land Managers will 

update the information presented on alternative burning practices and 

emission reduction techniques as research improves. 

B. Evaluation of Smoke Dispersion 

Under the ESMP, smoke dispersion techniques such as dilution (burning 

during periods of good atmospheric dispersion) and avoidance 

(transporting smoke away from sensitive areas) will be used to reduce 

impacts on visibility in Class I areas. An evaluation of smoke dispersion 

will be made using the following tools and methods: scheduling or burn 

authorization of prescribed fires to minimize cumulative effects of smoke 

from fires on visibility in Class I areas, burner qualification and 

certification programs, use of dispersion modeling (to assist in the 

evaluation of dispersion conditions), and use of field level data, (e.g., wind 

direction, distance to receptors). 
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Burn Authorization Process

Under the Utah SMP, burn authorization decisions are based on 

meteorological information, national fire databases, information sharing 

efforts between adjoining states, and air quality monitoring information 

from UDAQ monitoring stations. 

Meteorological information is gathered from the National Weather Service 

(NWS), University of Utah modeling programs, and various satellites. 

The NWS office issues the Utah Airshed Clearing Indices, a predictor of 

how quickly pollutants dissipate in an area, and other weather forecast 

information. The University of Utah provides a link to the MM5 

modeling program that supplies ventilation data. Satellite information 

gives various views of cloud development and paths, and progress of 

frontal systems. 

Daily reports from national fire databases such as the National Incident 

Coordinator Center (NICC) supplies information on wildland fires 

including WFURB fires throughout the country. 

Air quality monitoring information is gathered from the UDAQ’s 

Monitoring Center’s website that provides readings of particulate matter 

levels in the Wasatch Front. 

All of the above information is utilized in the burn authorization process 

that is an essential element of the Utah SMP. Under state administrative 

rule, R307-204, Land Managers are required to submit pre-burn 

information including information on proximity to Class I areas, and burn 

requests to the executive secretary prior to conducting a burn. No 

prescribed fires requiring a burn plan can be ignited before the executive 

secretary approves or conditionally approves the burn request. 

Under the ESMP, Land Managers are required to submit information on 

the proximity of Class I areas to the proposed burns to allow for the 

scheduling of prescribed burns to reduce impacts on visibility in Class I 

areas and the generation of regional haze. 

 

Burner Qualification and Certification Programs

Burner qualification and certification programs have been developed and 

are being used by federal and state land management agencies that use 

prescribed fire as a management tool. These burn manager qualification 

programs include information on the relationships between weather and 

smoke dispersion. The benefit of a burn manager qualification program is 

to certify that the land manager is knowledgeable of and understanding of 

the factors affecting smoke behavior and, therefore, may make better 
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decisions on when and when not to burn to reduce smoke impacts on 

visibility in Class I areas. Under the ESMP, Land Managers will update 

the information presented on weather and smoke dispersion as research 

improves. 

Dispersion Modeling

Under the ESMP, smoke dispersion modeling may be conducted by Land 

Managers to evaluate smoke behavior if there is a concern about potential 

smoke impacts from a proposed prescribed burn(s). This tool could be 

used in the planning and implementation process for burning for 

determining cumulative effects of multiple burns. 

 

Field Level Data

State administrative rule, R307-204, requires Land Managers to submit 

pre-burn information for approval prior to ignition. The pre-burn 

information identifies any sensitive receptor, including any Class I or 

Non-attainment area within 15 miles, distance and direction of the 

sensitive receptor in degrees from the project site, and a map that shows 

the daytime and nighttime smoke path and down-drainage flow for a 

minimum of 15 miles from the burn site. This map in addition to the fire 

prescription that is prepared by the Land Manager provides field level data 

that is essential for supporting the dispersion estimation process. 

C. Alternatives to Fire 

Alternatives to fire are techniques that replace fire as a means to achieve a 

particular land management objective (e.g., reduction of fuel-loading, 

manipulation of fuels, enhancement of wildlife habitat, ecosystem 

restoration, etc.). Under the ESMP, non-burning alternatives do not 

include techniques used in conjunction with fire. 

Land Managers typically evaluate the use of alternatives to fire in 

programmatic or long-term management plans. Federal land managers 

evaluate non-burning alternatives in programmatic plans as a requirement 

of the National Environmental Policy Act (NEPA). Therefore, the 

decision to use fire or non-burning alternatives has been determined prior 

to development of the operational-level plan or burn plan. 

Under the Utah ESMP, the types of non-burning alternatives and the acres 

treated during the previous calendar year will be summarized annually 

using newly developed land manager databases. The summary will 

provide documentation of the types of non-burning alternatives utilized by 

the Land Managers annually and the acres treated. 
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D. Public Notification 

The Utah SMP and state administrative rule, R307-204, emphasize the 

importance of public notification by requiring Land Managers to notify the 

public of upcoming fire activities. In addition, public notification 

information is a component of burn plans that are developed by state and 

federal land managers. 

Under the Utah ESMP, a one-stop information center will be added to the 

existing Utah SMP website to provide a list of upcoming projects as a 

means to notify the public about prescribed fire or wildland fire projects. 

This tool would provide another means for information dissemination. 

E. Air Quality Monitoring 

The Utah SMP and state administrative rule, R307-204, requires land 

managers to monitor the effects of prescribed fires on smoke sensitive 

receptors, and visibility in Class I areas using either visual monitoring or 

sampling equipment. 

Under the ESMP, visual monitoring will be used in areas of little burn 

activity or areas located farther away from Class I areas. UDAQ in 

cooperation with Land Managers may consider conducting a more 

widespread and comprehensive monitoring program as fire activity 

increases. The use of cameras, satellite imagery and aerial monitoring to 

track and document smoke movement could be considered. The use of 

IMPROVE monitored data may have to be supplemented by air quality 

monitoring outside of Class I areas to track smoke movement. 

Under the ESMP, a description of the monitoring equipment that is 

available, location of equipment, and equipment training opportunities will 

be added to the existing Utah SMP website as an aid to Land Managers. 

F. Surveillance and Enforcement 

State administrative rule, R307-204, establishes by rule the procedures 

that Land Managers are required to follow to mitigate impacts on public 

health and visibility of prescribed fire and wildland fire. Failure to 

comply with the state rule may result in an enforcement action, such as a 

notice of violation or cease and desist order. 

Under the ESMP, Land Managers will permit UDAQ staff to enter and 

inspect burn sites before, during, and after burns to verify the accuracy of 

the burn plan and compliance with the burn plan, if appropriate. For 

safety purposes, site inspection procedures will be coordinated by the 

UDAQ through the land manager prior to any site inspections. 
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G. Program Evaluation 

The ESMP will be reviewed for effectiveness by the UDAQ in 

cooperation with the Land Managers on an annual basis. In addition, the 

Rule requires progress reports every five years to EPA describing how 

well the enhanced smoke management program is being implemented as 

needed to meet reasonable further progress requirements. Annual 

evaluations of the overall smoke management program will provide the 

information needed for periodic reports. 

The following elements of the ESMP will be evaluated during annual 

evaluations: 

• Implementation 

• Burn activity summaries 

• Smoke complaint summaries 

• Compliance and enforcement 

• Sections needing clarification or improvement 

• Progress towards goals including visibility improvement/impact 

reduction 

• Recommendation for revisions 

• Scientific advancements 

H. Burn Authorization 

State administrative rule, R307-204, requires Land Managers to submit 

pre-burn information for approval by the Executive Secretary prior to 

ignition of prescribed fires. This inter-state burn authorization program 

utilizes meteorological information, prescribed burn information, and 

updates of fire activity in adjoining states to schedule burns to avoid 

impacts of smoke on public health. Under the ESMP, Land Managers are 

required to identify whether a Class I area may be impacted by a burn 

prior to ignition. This additional information on potential impacts on 

visibility in Class I areas will be utilized within the burn authorization 

program to prevent cumulative impacts of smoke to visibility in Class I 

areas from prescribed burns and WFURB fires within Utah boundaries. 

I. Regional Coordination 

Under the SMP, notification of upcoming prescribed fires and approved 

WFURB projects is provided to adjoining states for coordination purposes. 

This process of information sharing is important to help adjoining states 

with burn authorization programs prioritize their prescribed burn projects. 

Likewise, information on upcoming prescribed, WFURB, and wildland 

fire projects in neighboring states is utilized for burn scheduling purposes 
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within Utah boundaries to reduce smoke impacts on public health. This 

information is gained from national databases such as the National 

Incident Coordination Center (NICC) report, and phone calls and emails 

from adjoining states. 

Under the ESMP, information on prescribed, WFURB, and wildland fire 

projects in neighboring states will be utilized for burn scheduling purposes 

within Utah boundaries to reduce cumulative smoke impacts on visibility 

in Class I areas within Utah. Smoke from wildland fires are more likely to 

be of longer duration and have the greater potential for impacts on 

visibility in Class I areas and generating regional haze. 

In the future, it may be necessary to develop and implement a regional 

coordination center to prioritize burns in areas that would be most likely to 

create cross-jurisdictional impacts. To do so, regional meteorological and 

air quality information would be shared with the result being regional 

approval and real-time tracking of burns and their smoke impacts. 

New modeling tools, such as BlueSKY, are being developed that provide 

smoke column footprints and estimates of smoke concentrations that will 

be useful for regional coordination efforts. 

J. Evaluation Criteria 

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

based on the criteria of efficiency, economics, law, emissions reduction 

opportunities, land management objectives, and reduction of visibility 

impacts. These criteria will determine the extent to which individual 

elements of the enhanced smoke management program are applied or the 

level of effort that is possible. The enhanced smoke management program 

criteria are listed below including some options on how to apply each 

criterion: 

Efficiency: Consider the resources, infrastructure, networking, workforce, 

and information necessary to reduce visibility impairment in mandatory 

Class I areas. It may be feasible to share these items with another group in 

order to reduce redundancy or build on existing expertise. 

Economics: After evaluating the items listed under Efficiency, consider 

the costs and incentives of those items. If possible, quantify the 

improvements to regional haze in a local area. Consider the economic 

trade-off of moving fuels off-site to be converted to another use or burned 

elsewhere. Consider the economic costs to a landowner to look for 

emission reduction alternatives. Consider the economic gains from 

improved habitats, functioning watersheds, species diversity and healthy 
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ecosystems. Consider the economic losses to a community associated 

with impairment. 

Law: Consider the federal, state, tribal ordinances, local rules or statutes 

that prohibit mechanical treatments or prohibit the regulation of burning. 

Consider conflicts with management or law pertaining to the Threatened 

and Endangered Species Act and/or the Wilderness Act. 

Emission Reduction Opportunities: Consider opportunities for reducing 

emissions through mechanical, biological, or chemical means. Consider 

places where reducing emissions will be best done through smoke 

management techniques rather than moving fuels off-site or manipulating 

fuels through chemicals or biological decomposition or a combination of 

mechanical treatments and maintenance burning. 

Land Management Objectives: Consider whether manipulating fuels is 

not an option because of land management objectives, e.g. tribal cultural 

values, wildlife habitat, crop requirements, residue removal constraints, or 

inaccessible terrain. Consider whether manipulating fuels is more 

conducive to the land management objective, e.g., areas targeted for 

commodity production, watershed protections or tribal cultural activity 

sites. Consider whether restoration of ecosystem function is a high 

priority. 

Reduction of Visibility Impacts: Consider how the ESMP will decrease 

visibility impacts on Class I areas, using the current information and 

science that is available. 
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