# Western Regional Air Partnership Policy

on Annual Emission Goals for Fire

Approved by the Western Regional Air Partnership April 2, 2003

Prepared by the Annual Emission Goals Task Team

of the

Fire Emissions Joint Forumi 

### WRAP Policy

Annual Emission Goals for Fire

Executive Summary

The Western Regional Air Partnership (WRAP) is charged with developing technical and policy tools to assist states (or the delegated regulat ory authority) and tribes with implementing the Regional Haze Rule (Rule).

The WRAP Policy on Annual Emission Goals for Fi re (WRAP AEG Policy) has been developed over a six-month period through a stakeholder-based consensus process to assist the WRAP region states and tribes in addressing emissions from fire sources. In this Policy, the WRAP seeks to provide a consistent framework that states and trib es can use to efficiently develop their individual implementation plans. The WRAP recognizes stat es’ and tribes’ authority and responsibility to develop, adopt and implement their regional haze im plementation plans, and recognizes the Rule as the principal document on which states and tribes should rely.

The Rule requires states to develop implementati on plans (SIPs) for addressing regional haze in the Nation’s 156 mandatory Class I areas. Additionally, th e Rule requires effective management of fire sources. The Rule provides two pathways for west ern states to follow as they implement the requirements of the Rule: 1) develop their regi onal haze implementation plans per the nationally applicable provisions of Section 308, or 2) Transport Region states may choose to incorporate the Grand Canyon Visibility Transport Commission (G CVTC) Recommendations into their regional haze implementation plans under Section 309 of the Rule.

The GCVTC recognized that projected increases in fire activity will resu lt in episodic impacts on visibility in the West, and called for the developm ent of annual emission goals that would minimize these impacts. Section 309 of the Rule specifically requi res the establishment of annual emission goals that minimize emission increases from fire to the maximum extent feasible. Further, these goals must be developed in cooperation with stat es, tribes, land management agencies and private

entities.

The WRAP defines the annual emissi on goal as a quantifiable value that is used to measure progress each year toward the desired outcome of achieving the minimum emission increase from fire. In this WRAP AEG Policy, the WRAP outlines a process by which states/tribes may establish annual emission goals, based on the utilization of currently available emission reduction techniques (ERTs), to include in their regional haze implementation plans.ii Although Section 309 of the Rule specifically requi res the establishment of annual emission goals, the strategy outlined here for the utilization of ERTs could be considered by states and tribes that choose to follow the requirements of Section 308 of the Rule and/or may be used to protect visibility in non-mandatory Federal Class I areas. 1

Tribes are not subject to the same requirements of the Rule as states, but tribes wishing to assume the regional haze requirements outlined in the Rule may, according to the CAA, seek approval to be treated in the same manner as states, under the Tr ibal Authority Rule (TAR), 40 CFR 49. The intent of this Policy is to assist both states and trib es with the development of their regional haze implementation plans (SIPs/TIPs), and therefore, tr ibes are included in all references to states, except where specific requirements and/or deadlines of the Rule are cited. In the case of annual emission goals, the WRAP considers them a viable t ool for all tribes in the WRAP region to use to

achieve the minimum emission increase from fire.

The WRAP AEG Policy document is comprised of four major sections. Section 1 is the seven WRAP AEG Policy statements. Section 2 provides overall background for the WRAP AEG Policy.

Section 3 is an annotation of each of the seven policy statements, further explaining and defining them. Finally, the Appendices include (A) a glossary of terms, (B) a rela ted documents listing, (C) additional guidance for states/tribes on the impl ementation of annual emission goals, and D) an example of a table that will be developed as a separate guidance document by the WRAP Fire Emissions Joint Forum for use with annual emission goals.

1 The Rule is only applicable to mandatory Class I areas . States/tribes in the WRAP region may utilize the AEG Policy to protect visibility in non-mandatory Class I areas.iii 

### WRAP Policy

Annual Emission Goals for Fire

TABLE OF CONTENTS

Executive Summary i

1. The WRAP Policy on Annual Emission Goals for Fire 1 Policy Statements

2. Background 1

2.1 Clean Air Act and Grand Canyon Visibility Transport Commission 1 2.2 Western Regional Air Partnership 2 2.3 Regional Haze Rule 2

3. Annotated Policy 3

3.1 Introduction 3 3.2 Policy Statement A: AEGs Required Under Section 309 4 3.3 Policy Statement B: Annual Emission Goal Defined 4 3.4 Policy Statement C: Applicability 5 3.5 Policy Statement D: Emission Reduction Techniques (ERTs) 6 3.5.1 Implementation Options 8 3.6 Policy Statement E: Feasibility Criteria 9 3.7 Policy Statement F: Utilizing Collaborative Processes 10 3.8 Policy Statement G: Tracking Procedure 10

4. Appendices 11

Appendix A: Glossary 11

Appendix B: Related Documents Listing 14

Appendix C: Annual Emission Goal Implementation Guidance 16

1. Applicability 16iv TABLE OF CONTENTS

2. Regional Haze Implementation Plans 16 2.1 Section 308/309 Requirements 16 2.2 Submission of Periodic Reports 17

3. Use of ERTs 17

3.1 California 18 3.2 Oregon 18 3.3 Washington 18

3.4 Utah 18

4. Establishment of Annual Emission Goals 19 4.1 Current ERT Application 19 4.2 Non-burning Alternatives and Annual Emission Goals 19 4.3 Determination of Appropriate ERTs 20 4.4 Feasibility Criteria 21 4.5 Existing Guidance Documents 21

4.6 Research Needs 22

4.7 Calculation of Averted Emissions 22

Appendix D: ERT & Associated Emission Averted Table 241 

### 1. WRAP Policy on Annual Emission Goals for Fire

Policy Statements

A) The establishment and implementation of annual emission goals is a viable technique to control 2

fire emissions for WRAP states and tribes. A nnual emission goals are required for states under Section 309 of the Regional Haze Rule.

B) Annual emission goals will achieve the minimu m emission increase from fire. Annual emission goals are quantifiable values that are distinct from emission limits.

C) Annual emission goals are applied to all fire sources (excluding wildfire) due to their potential impacts on visibility.

D) The minimum emission increase from fire is accomplished through the optimal application of emission reduction techniques, which provides the basis for annual emission goals.

E) The use of emission reduction techniques to achieve annual emission goals is subject to economic, safety, technical and environmental feas ibility criteria, and land management objectives.

F) States, tribes or the designated authority will establish annual emission goa ls in cooperation with federal land management agencies and private entities on a yearly basis.

G) States and tribes will need to develop a pr ocedure for verifying the use of emission reduction techniques and for tracking the achievement of annual emission goals.



### 2. Background

2.1 Clean Air Act and Grand Canyon Visibility Transport Commission

In 1990, Congress amended the Clean Air Act (CAA), a nd as part of these amendments created the Grand Canyon Visibility Transport Commission (GCVTC). 3 The GCVTC was charged with assessing the current scientific information on visibility impacts and making recommendations for addressing regional haze in the western United St ates. The GCVTC signed and submitted more than

70 recommendations to the Environmental Protection Agency (EPA) in a report dated June 1996 that indicated that visibility impairment was caused by a wide variety of sources and pollutants, and that a comprehensive strategy was needed to remedy regional haze.

2 “Control” as used in this Policy means the use of techni ques that result in a quantifiable reduction in emissions from

individual fire sources.

3 The GCVTC was composed of the governors of eight western states (AZ, CA, CO, NM, NV, OR, UT, WY), four tribes (Acoma Pueblo, Hopi, Hualapai, and Navajo), four Federa l land management agencies (Bureau of Land Management, U.S. Fish and Wildlife Service, U.S. Forest Service, National Park Service) , the Columbia River Inter-Tribal Fish Commission, and the Environmental Protection Agency.2 The GCVTC Report recognized that fire plays a significant role in visibility on the Colorado Plateau. According to the GCVTC Report, emissions from wildfire and prescribed fire are “an important episodic contributor to visibility-imp airing aerosols, including organic carbon, elemental carbon, and particulate matter (PM 2.5 ).” 4 The GCVTC Report also stated that agricultural burning emissions and their effects have been identified as a concern, but have not been quantified due to

insufficient data. 5

2.2 Western Regional Air Partnership

The Western Regional Air Partnership (WRAP) was established in 1997 as the successor organization to the GCVTC. The WRAP is a voluntary organization comprised of western governors, tribal leaders and federal agencies, 6 and is charged “to identify regional or common air management issues, develop and implement strategi es to address these issues, and formulate and advance western regional policy positions on air quality.” 7 These policies and technical tools are developed through inclusive, stakeholder-based pr ocesses and approved by consensus of the WRAP.

WRAP participants include state air quality agencies, tribes, federal/state/private land managers, the EPA, environmental groups, industry, academia and other interested parties. There are over 400 tribes within the WRAP region. The large number of tr ibes limits the participation of all of them in WRAP activities, and accordingly, in the developm ent of this Policy. Therefore, the tribal representatives involved in the development of this Policy may not represent all tribal concerns.

2.3 Regional Haze Rule

Following the issuance of the GCVTC Report, the EPA issued the Regional Haze Rule (Rule) in July 1999 to improve visibility in 156 national pa rks and wilderness areas across the country. The Rule outlines the requirements for states and tribes to address visibility impairment in mandatory Class I areas due to emissions from all sources, including fire activities. EPA incorporated all of the GCVTC recommendations into Section 309 of the Rule, which may be used by some of the WRAP states/tribes. The remaining WRAP states must utilize the nationally applicable Section 308 provisions of the Rule.

Tribes are not subject to the same requirements of the Rule as states, but tribes wishing to assume the regional haze requirements outlined in the Rule may, according to the CAA, seek approval to be treated in the same manner as states, under the Tribal Authority Rule (TAR), 40 CFR 49. 8 In these

4 GCVTC Report, p. 47.

5 Ibid.

6 The WRAP membership is comprised of the governors of th irteen western states and th irteen western tribes. The current WRAP members include the States of AK, AZ, CA , CO, ID, MT, ND, NM, OR, SD, UT, WA, and WY, and the Tribal Nations of Pueblo of Acoma, Campo Band of Kumeyaay Indians, Cortina Indian Rancheria, Hopi Tribe, Hualapai Nation of the Grand Canyon, Nez Perce Tribe, Northern Chey enne Tribe, Salish and Kootenai Confederated Tribes, Pueblo of San Felipe, and Shoshone-Bannoc k Tribes of Fort Hall. Federal WRAP members are the Department of the Interior, the Department of Agriculture, and the Environmental Protection Agency.

7 WRAP Charter, Purpose, p. 1.

8 64 FR 35759.3 cases, EPA still recognizes that “unlike States, tr ibes are not required by the TAR to adopt and implement CAA plans or programs, thus tribes ar e not subject to mandatory deadlines for submittal of implementation plans.” 9 Although provision for flexibility in the submission of programs and implementation plans for tribes is made under TAR, EPA does “encourage tribes choosing to develop implementation plans to make every effort to submit by the deadlines to ensure that the plans [TIPs] are integrated with and c oordinated with regional planning efforts.” 10

EPA recognizes the WRAP as the Regional Planning Organization that is developing the necessary policy and technical tools to implement the Rule in the WRAP region. A WRAP policy, once approved, represents the WRAP's consensus position on the best means for states and tribes to implement the portion of the Rule at issue.

The WRAP recognizes states’ and tribes’ authority and responsibility to develop, adopt and implement their regional haze state and tribal impl ementation plans, and the seminal guidance to do

this is the Rule. 11 States are required by the Rule to submit periodic reports to the EPA to assess the adequacy of the implementation plan. If the state determines that the implementation plan is or may be inadequate to meet reasonable progress goals, the state is required to develop additional strategies to address deficiencies in the plan. These strategies are then submitted to EPA for approval.



### 3. Annotated Policy

3.1 Introduction

The WRAP AEG Policy is the result of the WR AP region-wide, multi-state/tribe stakeholder planning and coordination effort. The intent of th e WRAP AEG Policy is to assist states (or the delegated authority) and tribes to address smoke im pacts on visibility associated with fire in a way that is adequate for SIP/TIP implementation.

The WRAP AEG Policy provides states and tribes with a consistent method for the identification, use, and tracking of emission reduction technique s (ERTs) to meet the annual emission goals requirement of the Rule. Although this Policy promot es the use of ERTs to meet the annual emission goals requirement of Section 309 of the Rule, it doe s not prescribe how each state/tribe integrates this Policy into its regional haze SIP/TIP or limit the use of alternative approaches to the implementation of annual emission goals.

This WRAP AEG Policy has been developed to embody appropriate regulatory and policy requirements and to provide a predictable fram ework for annual emissions goals that can be reasonably implemented by states and tribes. The WR AP believes that states maintain the ultimate responsibility for the implementation of annual emi ssion goals. Further, states are responsible for incorporating into their implementation plans fede rally enforceable processes to minimize emission increases from fire, whether they choose to us e ERTs or some other method that meets Rule requirements. Tribes, or EPA on their behalf, may choose to utilize, as a severable element, annual

9 64 FR 35758.

10 64 FR 35759.

11 WRAP Charter, p.1.4 emission goals in their implementation plans. Th e WRAP recognizes that the implementation plans will be revisited and revised, per the schedule speci fied in the Rule, giving opportunities to refine individual programs for annual emission goals that reflect technical advances and policy updates.

3.2 Annual Emission Goals Required Under Section 309 Policy Statement A : The establishment and implementa tion of annual emission goals is a viable technique to control fire emissions fo r WRAP states and tribes . Annual emission goals are required for states under Section 309 of the Regional Haze Rule.

In this Policy, the WRAP seeks to provide a cons istent and equitable framework that states and tribes can use to efficiently develop their regi onal haze implementation plans (SIPs/TIPs). Under Section 309, the Rule calls for “establishment of annual emission goals for fire (excluding wildfire)

that will minimize emission increases from fire to the maximum extent feasible.” 12 The Policy can be considered by all other states and tribes as a means to control fire emissions, and annual emission goals are a viable technique for controlling fire emi ssions if a state’s or trib e’s visibility impairment analysis for Section 308 of the Rule shows that fire sources contribute to visibility impairment in a mandatory Class I area.

3.3 Annual Emission Goal Defined Policy Statement B: Annual emission goals will achieve the minimum emission increase from fire. Annual emission goals are quantifiable values that are distinct from emission limits.

In its Report, the GCVTC acknowledged federal and state land managers’ proj ection of “significant increases in prescribed fire in order to reduce the effects of wildfire resulting from past decades of fire suppression.” 13 The Rule also recognized that “forest fuels have built up over many years due to past management practices designed to protect pub lic health and safety through fire suppression.” And further, that this has “...led to an increased risk of catastrophic wildfire... ” which would need to be offset by “the increased use of prescribed fire....” 14

This increase in fire activity prompted the GCVTC to recommend the establishment of annual emission goals that would minimize increases from fi re emissions, which the Rule then adopted as a requirement under Section 309. 15 The Rule utilizes the GCVTC’s terminology in Section 309 and in the Preamble, both in its section on the Treatme nt of the GCVTC Recommendations and in the Annex to the GCVTC Report. 16 Therefore, for its definition of “annual emission goal” the WRAP looked to the GCVTC Report.

Although not formally defined, the term “goal” is specifically used in the GCVTC Report in the

contexts of both Area Sources and Air Pollution Pr evention to focus efforts on a desired outcome. 17

12 64 FR 35771 §51.309 (d)(6)(v).

13 GCVTC Report, p. 23.

14 64 FR 35735.

15 GCVTC Report, p. 50.

16 64 FR 35748 and 35756.

17 GCVTC Report, p. 30.5 This desired outcome may have a numeric measure a ssociated with it, but is distinct from a limit. The GCVTC defines both the terms “cap” and “target” as emissions limits, and uses them in its section on Stationary Sources. 18 The GCVTC also distinguishes between “target” and “cap” as

follows:

... “targets” are intended as firm limitations on emissions and have the same effect as a “cap.” However, we are reserving the term “cap” to refer to the limits set under a regulatory program, which would be triggered if the “targets” are exceeded. 19

In using the term goal, and not target or cap, the GCVTC clearly intended the annual emission goal to be something other than an emission limit, and that it not have the attendant regulatory consequences of a cap, as supported by the specific us e of these terms in its Report. Therefore, the WRAP AEG Policy defines annual emission goals as quantifiable indicators of progress toward the desired outcome of minimizing increases from fire emissions.

In distinguishing between goals and limits, it is not the intent of this Policy to preclude the establishment of emission limits. However, it curre ntly does not appear that an adequate fire emissions inventory exists throughout the WRAP Region to support the establishment of an

emissions limit on fire sources. 20 The WRAP does recognize that scientific advances may support the feasibility of an emissions limit (either target or cap) in the future.

3.4 Applicability Policy Statement C: Annual emission goals are applied to all fire sources (excluding wildfire) due to their potential impacts on visibility.

The Rule, the GCVTC and WRAP policy development to date acknowledge that all types of fire must be addressed equitably as part of a visibility protection strategy since all fire contributes to regional haze. 21 Therefore, the WRAP AEG Policy applies to all fire sources, except for wildfire, which is specifically excluded in Section 309 of the Rule. 22

18 GCVTC Report, p. xi and pp. 32-37.

19 GCVTC Report, p. 34, footnote 4.

20 In order to implement an emission limit, states/tribes woul d need to have emissions inventory data adequate to establish an emissions baseline, establis h the baseline, conduct periodic evaluations of the effectiveness of the baseline, and institute sufficient enforcement mechanisms. Even so, the baseline may not be a reliable tool due to the variability of

fire emissions.

21 GCVTC Report, p. 47, 64 FR 35735, WRAP ESMP and Fire Categorization Policies.

22 64 FR 35771 §51.309 (d)(6)(v).6 The Rule excludes wildfire from the annual emi ssion goals requirement of Section 309 due to the inability to directly control the emissions from w ildfires. The same concern would be relevant to

states under Section 308 or tribes that choose to use annual emission goals as a method to control

fire emissions.

This Policy applies to federal, tribal, and state land managers and to private landowners that use prescribed fire, wildland fire us ed for resource benefits (WFU) 23 or agricultural burning to achieve land management objectives on agricultural land or wildland. 24 In accordance with Section 118(a) of the CAA requiring that all entitie s, federal and non-federal, be subject to the same requirements, authorities and processes, 25 the WRAP AEG Policy will be applie d equitably to all fire sources, excluding wildfire.

The WRAP AEG Policy specifically does not appl y to Native American cultural non-vegetative burning for traditional, religious, or ceremonial purposes (e.g., cremation, sweat lodge fires). 26 Nor does it apply to open burning activities on residen tial, commercial, or industrial property (e.g., backyard burning, garbage incineration, reside ntial wood combustion, construction debris). 27

However, states/tribes may choose to consider the impacts of these fire sources when developing their regional haze implementation plans.

3.5 Emission Reduction Techniques (ERTs) Policy Statement D: The minimum emission increase from fire is accomplished through the optimal application of emission reduction techniques, which provides the basis for annual emission goals.

The WRAP AEG Policy provides a pr actical approach to establishing annual emission goals that

states and tribes can use in th eir implementation plans. The WRAP has developed the AEG Policy to address three issues central to this visibility protection strategy.

First, annual emission goals are to be developed on an annual basis, for each year, and therefore

need to be based on a measure that can be determin ed in one year’s time. The annual level of fire activity is dependent on a variety of external factor s such as crop type planted, funding for federal or state fire programs, weather, etc. These factors w ill also influence the potential use of fire emission control strategies. In order to accommodate this variability and address the annual nature of the Rule requirement, annual emission goals are to be determined each year through a collaborative process between burners and the regulatory jurisdiction.

Second, since annual emission goals are not emission limits, the goal is based on the sole purpose of minimizing emission increases from fire to the maximum extent feasible; therefore, annual emission

23 Also known as Prescribed Natural Fire (PNF).

24 WRAP Policy for Categorizing Fire Emissions, Nove mber 15, 2001 (hereafter referred to as “WRAP Fire Categorization Policy”), p. 8. See also Appendix C for further details.

25 Clean Air Act §118(a).

26 WRAP Fire Categorization Policy, p. 24.

27 Ibid, however “industrial property” would not include land such as industrial forestland.7 goals can reasonably be tied to actions that have this result. Under this Policy, the process for establishment of the annual emission goal, rather th an the specific numeric value (which varies from year to year), will be included in implementation pl an submittal. In other words, the goal will focus on the efforts to minimize emissions; this proce ss, being in the implementation plan, will be federally enforceable.

Third, the WRAP region represents wide variety w ith regard to basic fire activity tracking, fire emissions data, and fire use, and therefore, the annual emission goals strategy will need to be one that is both flexible and practical. The strategy mu st also be capable of being implemented using tools and information currently available to meet the Section 309 deadline of December 31, 2003.

To address these issues, the WRAP AEG Policy focuses on minimizing fire emission increases through the control of emissions on all fire projects where feasible. Control of fire emissions means utilizing methods that result in a reduction of the to tal amount of emissions generated from each fire project. Control of fire emissions is accomplis hed by using emission reduction techniques (ERTs), methods proven to reduce fire emissions. 28

ERTs include biomass utilization prior to burni ng, increasing combustion efficiency, and others. 29

Additionally, methods exist for tracking and calculati ng the emissions averted from the use of ERTs for a broad array of vegetation types. For the pur poses of this Policy, non-burning alternatives are not ERTs. Non-burning alternatives are technique s that replace fire as a means to achieve a particular land management objective (e.g., reduc tion of fuel-loading, enhancement of wildlife habitat, etc.). 30

Control measures are distinct from smoke management techniques, which are currently used in the West by land managers to minimize smoke imp acts on public health, nuisance and visibility. A key smoke management technique is the timing of ignitions for better smoke dispersion with the intention of avoiding smoke impacts to sensitiv e areas (e.g., non-attainment areas, Class I areas, nearby communities). Smoke management techni ques may give consideration to downwind air quality (e.g., nuisance impacts and National Am bient Air Quality Standards [NAAQS]) and visibility/regional haze.

The emission reductions that are achieved through the use of ERTs are calculated on a projectspecific basis, otherwise referred to as the operati onal phase of the fire pr oject. The decision to burn a specific area has already been made prior to th e implementation of a specific project; therefore, project-specific basis refers to projects where fire will be used to meet land management objectives. Annual emission goals, under this Po licy, are established annually and apply to the upcoming year’s projects where fire has been determined as the best tool for meeting specific land management objectives. The annual emission goal in this case w ould be the sum of emission reductions from all fire projects where ERTs are used across the stat e or tribal jurisdiction, for the upcoming year.

28 The GCVTC projected that the use of optimal smoke manage ment measures (which include the use of ERTs) could decrease fine particle (PM 2.5 ) emissions from prescribed fires by approximately 15-20%. This resulted in modeled visibility improvements over the planning peri od of the GCVTC. GCVTC Report, p. 87.

29 See Appendix C for more examples of specific ERTs and the application of ERTs.

30 For a more detailed discussion of non-burning a lternatives, see Section 4.2 of Appendix C.8 3.5.1 Implementation Options

Two options for the utilization of ERTs to meet the annual emission goal have been outlined below. These options are based on current use of ERTs, science and technology. The first option is based on estimations of emissions averted through the app lication of ERTs, and allows the calculation of an annual numeric value that indicates progress to ward minimizing increases from fire emissions. The second option is provided for instances where es timates of emissions averted are not feasibly calculated due to insufficient data. In this second option, the annual numeric value is based on total percent use of ERTs with subsequent emission reductions inferred.

The two options explored here are not exhaustive or definitive in structure or design. Application of these or any other options can be considered for each individual fire source sector or for combinations of them. All options for use of ERTs are subject to the feasibility criteria as outlined in Policy Statement E. Additionally, state/tribal au thorities will want to be mindful of equitable treatment of sources in the implementation of ERTs.

In either Option 1 or Option 2, state/tribes will need to determine the appropriate ERTs to be used for specific vegetation or crop types that will be treated to allow attainment of land management objectives. It is a common practice to apply a cer tain ERT to a specific vegetation or crop type, although more than one ERT may be feasible fo r a certain vegetation or crop type. Next, in establishing annual emission goals, the designation of all appropriate ERTs for each of the identified vegetation or crop type needs to be completed.

For use in this process, Appendix D provides an ex ample of a table that will correlate the use of ERTs with emissions averted. Appendix D will be augmented by subsequent guidance by the WRAP Fire Emissions Joint Forum (FEJF) that will summarize ERT options for common vegetation and crop types for both prescribed fire on wildlands and agricultural burning. This guidance document can be used in combination with known local pr actices to determine appropriate ERTs for the respective vegetation or crop type.

Option 1

Once applicable ERTs for the respective ve getation or crop type are agreed upon, the potential percentage use of ERTs is determin ed subject to the feasibility criteria for the specific project. The potential percentage use is estimated by determining the portion of the project where ERTs are to be applied. Then an estimate of the emissions averted can be made. The annual emission goal is the emissions averted through the use of ERTs for all projected fire projects across the state or tribal jurisdiction.9 Option 2

An estimate of emissions averted may not be feasible if ERT emission factors are not available (i.e., the specific amount of emissi ons reduction has not been determined through research). In this case, the annual emission goal is the percent of total acres on which ERTs are used where fire is to be employed across a state or tribal jurisdiction for the upcoming

year.

Although annual emission goals using ERTs can be es tablished unilaterally ac ross fire source sectors for either Option 1 or 2, there are benefits to esta blishing them by source sector so as to account for differences in management practices between ag ricultural and wildland burning, as well as in the availability of ERTs. Establishing the annual goal using ERTs by source sector may also alleviate equity issues since the goal is applied across proj ects with similar vegetative or crop types and land management objectives. The annual goal should be es tablished after the evaluation of all potentially applicable ERTs.

This Policy encourages states/tribes to coordina te with neighboring states/tribes to improve the knowledge base of ERTs and to maintain consiste ncy in calculating emissions averted. Interstate coordination is key for minimizing visibility impacts in mandatory Federal Class I areas and for addressing regional haze in the WRAP region. 31

3.6 Feasibility Criteria Policy Statement E: The use of emission reduction techniques to achieve annual emission goals is subject to economic, safety, technical and environmental feasibility criteria, and land management objectives.

The feasibility of ERT use is variable and depende nt on criteria as established in the WRAP Fire Categorization Policy:

Per the GCVTC Recommendations, economic, safety, technical and environmental considerations are part of the application of emission controls for the implementation of this Policy statement. Due to these considerations, the control of emissions from some fire types may not be feasible, which will be determined by the land manager in
collaboration with the applicable air quality regulatory authority. 32

The WRAP AEG Policy also recommends that land management objectives be included in these criteria during the decision-making process to ensure that ERTs are used appr opriately and at levels of usage that are feasible. It should be noted th at the specific land manageme nt objective for an area could preclude the use of a specific ERT where that ERT would prevent the attainment of the land management objective, e.g., if the land management objective is to reduce downed large fuels in an area, the use of burning under high fuel moistu re of large woody fuels (i.e., the ERT being

31 64 FR 35728.

32 WRAP Fire Categorization Policy, p. 11.10 considered) would not be an option. See Appe ndix C for more detailed information on the application of ERTs.

3.7 Utilizing Collaborative Processes Policy Statement F: States, tribes or the designated authority will establish annual emission goals in cooperation with federal land management agencies and private entities on a yearly

basis.

Section 309 of the Rule requires that annual emission goals are “established in cooperation with States, tribes, Federal land management agencies, and private entities. 33 In addition, the WRAP’s policies on fire to date endorse the importance of using this collaborative process. Annual emission goals will be reviewed and revised on a yearly basis. Coordination within states and across jurisdictional boundaries is key for minimizing visibility impacts in mandatory Federal Class I areas and for addressing regional haze in the WRAP region. 34

3.8 Tracking Procedure Policy Statement G: States and tribes will need to develop a procedure for verifying the use of emission reduction techniques and for tra cking the achievement of annual emission goals.

A procedure for verifying the use of ERTs shoul d be developed. Such a procedure could also

facilitate the state's/trib e's ability to ensure accountability of i ndividual sources in utilizing ERTs. A state’s/tribe’s fire tracking system, as based on the WRAP Fire Tracking System (FTS) Policy, could be augmented to provide a repository for the verification information.

The verification of the use of some ERTs could also be done indirectly, fo r example by tracking fuel

moisture.

Procedures for tracking the actual emissions averted (Option 1) and/or the actual percent of total acres on which ERTs are used (Option 2) should be developed. At year-end, these actual values can then be compared to the estimated value(s) for th at year to assess whether annual emission goals are being met and for the purposes of establishing the next year’s annual emission goals. A state’s/tribe’s fire tracking system could be deve loped to support the tracking of the achievement of annual emission goals.

States/tribes can utilize the tracking procedure fo r the annual emission goal as a means for assessing the effectiveness of the control measures (i.e., ERTs ) in their SIPs/TIPs. States under Section 309 are required to submit periodic reports to EPA that a ssess the effectiveness of their control measures, including “...a summary of the emissions re ductions achieved throughout the State through implementation...” of such measures. 35

33 64 FR 35771 §51.309(d)(6)(v).

34 64 FR 35728.

35 64 FR 35772 §51.309(d)(10)(i)(A).11 

### 4. Appendices

Appendix A Glossary

Agricultural Fire/Burning – Any fire ignited by management acti ons to meet specific objectives (i.e., managed to achieve resource benefits) on agricultural land.

Agricultural Land – Agricultural land includes croplands, pasture, and other lands on which crops or livestock are produced. Rangeland will be include d with wildland for the purposes of the Fire

Emissions Joint Forum work.

Alternatives to Burning – See Non-burning Alternatives definition below.

Best Available Control Measures (BACM) – A term used to refer to the most effective measures (according to EPA guidance) for controlling small or dispersed particulates and other emissions from sources such as roadway dust, soot and ash fr om woodstoves and open burning of brush, timber, grasslands, or trash.

Best Management Practices (BMPs) – A term applied collectively to any administrative or on-theground procedure that reduces the negative impact s of some action. An example of a Best Management Practice with respect to air quality would be conducting a prescribed burn when atmospheric ventilation is good, which in turn promotes smoke dispersal.

Control – To reduce emissions from an individual fire source.

Class I Area – An area set aside under the Clean Air Act to receive the most stringent protection from air quality degradation. Mandatory Class I Fe deral Areas are: 1) international parks, 2) national wilderness areas and memorial parks larger than 5,000 acres in size, 3) national parks that exceed 6,000 acres in size and which were in existence when the 1977 Clean Air Act amendments were enacted. The extent of a mandatory Cla ss I Federal area includes subsequent changes in boundaries, such as park expansions. Class I areas can also include lands designated by states or tribes, but these areas are not deemed mandatory by the Clean Air Act.

Emission – Pollution discharged into the atmosphere from smokestacks, other vents, and surface areas of commercial or industrial facilities; from residential chimneys; from motor vehicle, locomotive, aircraft, or other non-road engines; and from area sources such as fire.

Emission Cap - An enforceable limit on the amount of specifi c air pollutants that can be released or on the amount of a specific pollutant that is allowed to be in the air in a de fined geographic area, and that has regulatory consequences. See al so Emission Goal and Emission Target.12 Emission Goal - A desired future outcome that may be represented by a numeric indicator, but without regulatory consequences, and as distinguished from a limit (i.e., target or cap). See also Emission Cap and Emission Target.

Emission Reduction Technique (ERT) - A technique for controlling emissions from prescribed fires to minimize the amount of emission output per unit of area burned.

Emission Target - A firm limit on the amount of specific air pollutants that can be released or on the amount of a specific pollutant that is allowed to be in the air in a defined geographic area, but without regulatory consequences (as distinguished from a cap). See also Emission Cap and Emission

Goal.

Enhanced Smoke Management Program (ESMP) - A program for fire that considers visibility effects, in addition to health and nuisance objec tives, and is based on the criteria of efficiency, economics, law, emission reduction opportunities, management objectives, and reduction of visibility impact.

Fire - When this term appears, it refers inclusively to wildfire, prescribed natural fire/wildland fire managed for resource benefits, prescribed fire, rangeland fire, and agricultural fire.

Land Managers - When this term appears, it refers inclus ively to federal, state, tribal, and private land managers.

Non-burning Alternatives to Fire - Techniques that replace fire as a means to achieve a particular land management objective (e.g., reduction of fuel-l oading, manipulation of fuels, enhancement of wildlife habitat, ecosystem restor ation, etc.). In this Policy, non-burning alternatives do not include techniques used in conjunction with fire. Techniques used in conjunction with fire are referred to as

ERTs.

Prescribed Fire - Any fire ignited by management actions to meet specific objectives, i.e., managed

to achieve resource benefits.

Rangelands - Land on which the historic climax plant community is predominantly grasses, grasslike plants, forbs, or shrubs. Includes lands re-v egetated naturally or artificially when routine management of that vegetation is accomplished mainly through manipulation of ecological principles. Rangeland includes natural grasslands , savannas, shrub lands, most deserts, tundra, alpine communities, coastal marshes and wet m eadows (Natural Resources Conservation Service National Range and Pasture Handbook, 1997.)

Regional Haze - Visibility impairment caused by the cu mulative air pollutant emissions from numerous sources over a wide geographic area.

Smoke Effects - The effects on visibility (both plume bli ght and regional haze), public nuisance, and the health-based NAAQS due to emissions from fire.13 Smoke Management - Programs, practices, and technique s to minimize and/or reduce smoke emissions or impacts from fire.

State Implementation Plan (SIP) - Plans devised by states to carry out their responsibilities under the

Clean Air Act. SIPs must be approved by the U.S. Environmental Protection Agency and include public review.

Transport Region State - One of nine states that make up the Grand Canyon Visibility Transport Region: Arizona, California, Colorado, Idaho, Ne vada, New Mexico, Ore gon, Utah, and Wyoming.

Tribal Implementation Plan (TIP) - Plans devised by tribes to carry out their responsibilities under the Clean Air Act. TIPs must be approved by the U.S. Environmental Protection Agency and include public review.

Wildfire - Any unwanted, non-structural fire.

Wildland - An area where development is generally limited to roads, railroads, power lines, and widely scattered structures. The land is not cultivat ed (i.e., the soil is disturbed less frequently than once in 10 years), is not fallow, and is not in the USDA Conservation Reserv e Program (CRP). The land may be neglected altogether or managed for such purposes as wood or forage production, wildlife, recreation, wetlands, or protective pl ant cover (EPA Interim Air Quality Policy on Wildlands and Prescribed Fires). The land is no t “agricultural land” as operationally defined above. Silvicultural land and rangelands (per the FEJF ch arge), woodlots, and private timberlands will be included with wildlands for the purposes of the FEJF work.14 

### Appendix B Related Documents Listing

Regional Haze Rule Published in the Federal Register on July 1, 1999, 64 FR 35714. http://www.epa.gov/ttn/oarpg/t1/fr_notices/rhfedreg.pdf

EPA Interim Air Quality Policy on Wildland and Prescribed Fire U.S. EPA, Office of Air Quality Planning and Standards, Interim Air Quality Policy on Wildland and Prescribed Fires, April 23, 1998. http://www.epa.gov/ttn/oarpg/t1/memoranda/firefnl.pdf

Prescribed Burning Background Document a nd Technical Information Document for Prescribed Burning Best Available Control Measures U.S. EPA, Office of Air Quality Planning and Standards, September 1992. Research Triangle Park, NC. EPA-450/2-92-003. http://www.epa.gov/ttncaaa1/t1bid.html

AAQTF Recommendation on Air Quality Policy Agricultural Air Quality Task Force, Air Quality Policy on Agricultural Burning, Recommendation to the U.S. Department of Agriculture, November 10, 1999. http://fargo.nserl.purdue.edu/faca/Archiv es/2000/Policy/Burning%20Policy.htm

Tribal Authority Rule Published in the Federal Register on February 12, 1998, 63 FR 7253. http://www.epa.gov/fedrgstr/EPA-AIR/1998/February/Day-12/a3451.htm

Smoke Management Guide for Prescribed and Wildland Fire National Wildfire Coordinating Group Fire Use Working Team (NWCG), 2001 Edition. http://www.nwcg.gov

On the WRAP Website (http://www.wrapair.org ) :

Grand Canyon Visibility Transport Commission Report Grand Canyon Visibility Transport Commission, Recommendations for Improving Western Vistas, Report to the U.S. EPA, June 10, 1996. Go to About WRAP, then the GCVTC link.

WRAP Policy for Categorizing Fire Emissions Approved by the Western Regional Air Partnership, November 15, 2001. Go to the FEJF Task Teams, then Natural Background.

WRAP Policy on Enhanced Smoke Management Programs Approved by the Western Regional Air Partnership, November 12, 2002. Go to the FEJF Task Teams, then Enhanced Smoke Management Programs.15 WRAP Policy on Fire Tracking Systems Approved by the Western Regional Air Partnership, April 2, 2003. Go to the FEJF Task Teams, then Fire Tracking Systems.

Non-Burning Management Alternatives on Ag ricultural Lands in the Western United

States Go to FEJF Task Teams, then Non-Burning Alternatives on Agricultural Lands.

WRAP Report: Integrated Assessment Update and 2018 Emissions Inventory for Prescribed Fire, Wildfire and Agricultural Burning (DRAFT). Go to FEJF Task Teams, then Emissions.

WRAP Charter Go to About, the to Charter.

Class I Area Map Go to About, then the WRAP Map.16 

### Appendix C Annual Emission Goal Implementation Guidance

1. Applicability

As this Policy builds on the WRAP Fire Categoriza tion Policy, the scope and applicability in regard to the “anthropogenic” or “natural” classifications defined by the WRAP Fire Categorization Policy

is clarified below. Those interested should consu lt the WRAP Fire Categori zation Policy for further

detail.

Fire Categories 36 WRAP AEG Policy Applicability

“Natural” Sources

• Wildfire

• Prescribed fire (including WFU) used for ecosystem maintenance

purposes

• Native American cultural burning for traditional, religious, and ceremonial purposes Exempted by Rule

Covered

Covered

“Anthropogenic” Sources

• Prescribed fire (including WFU) used for any purpose except ecosystem maintenance Covered

Other Sources

 Native American cultural nonvegetative burning

 Other open burning activities Not Covered

Not Covered

2. Regional Haze Implementation Plans

2.1 Section 308/309 Requirements

It is anticipated that annual em ission goals will be incorporated into the Section 309 implementation plans submitted to EPA in order to meet the require ments of the Rule. States/tribes complying with Section 309 are required to have a regional h aze implementation plan that addresses the 16 mandatory Federal Class I areas of the Co lorado Plateau submitted by December 31, 2003, with implementation of certain control measures, including annual emission goals, by the following year. All other mandatory Federal Class I areas in th e GCVTC transport region will be addressed by 2008 under the Section 308 or 309 implementation plan schedule.

36 WRAP Fire Categorization Policy, p.8.17 Although Section 309 of the Rule specifically requi res the establishment of annual emission goals for fire, the methods that are prom oted in this Policy could be considered by states/tribes that choose to follow the requirements of Section 308 of the Rule as a viable means to control fire emissions.

The Rule requires under Section 309 that annual em ission goals for fire (excluding wildfire) be established through 2018 as a means for dem onstrating reasonable progress requirements. 37 The WRAP considers this approach to have merit beyond 2018. 38 Section 309 states may need to consider developing further contingency measures , e.g., a regional application of annual emission goals, in their implementation plans if the a nnual emission goals do not adequately minimize

emission increases from fire. The annual emission goal approach is a viable strategy to control fire emissions and, thereby, make reasonable progress to ward the attainment of natural conditions by 2064, as required by the Rule.

2.2 Submission of Periodic Reports

Beginning in 2008, states are required by the Rule to submit periodic reports to the EPA to assess the adequacy of its implementation plan, including assessing the adequacy of certain elements, such as the annual emission goals. These periodic reports ar e due every five years. If the state determines that the implementation plan is or may be inadequa te to meet reasonable progress goals, the state is required to develop additional strategies to address de ficiencies in the plan. These strategies are then submitted to EPA for approval.

3. Use of ERTs

ERTs are proven to be effective methods to control fire emissions and are applied in different ways by regulatory authorities. For example, some regulat ory authorities promote the use of ERTs as part of a voluntary management program while others en force the use of ERTs through rule making. For example, the California Agricultural Burning Guid elines enforce the use of ERTs by specifying requirements for the burning of rice, barley, oat, and wheat straw. The Guide lines require the use of

a "crackle test" to determine if the fuel is dr y enough to burn. In the state of Washington, wildland land managers are encouraged to use techniques, such as fans, crane piling, mass ignition, accelerated mop-up, and other methods of increas ing combustion efficiency and reducing the smoldering stage of burning.

Although a few states in the WRAP region do prom ote or require the use of ERTs and specify burning conditions that must be met in order to burn, currently no systems are in place to track the emissions averted from the application of such methods across all fire source sectors. Currently programs do exist in some areas for tracking of emissions averted through the use of ERTs for wildland prescribed fires.

37 64 FR 35771 §51.309 (d)(6)(v).

38 WRAP Initiatives Oversight Committee (IOC), Transm ittal Letter, November 15, 2001, Appendix C of the WRAP Fire Categorization Policy.18 The following paragraphs provide a summary of some of the current efforts by regulatory entities to use ERTs as a means to reduce emissions from prescribed fire and agricultural burning.

3.1 California

Title 17 of the California Code of Regulations requires district smoke management programs to include general burning requirements for agricultu ral burning, prescribed burning, and prescribed

fires in wildland and wildland/urban interface areas. In addition to the general requirements, the law includes specific requirements for rice, barley, oat, and wheat straw, such as certain firing techniques and specific burning windows. There are also specifi c fuel moisture burning requirements for rice straw burning.

3.2 Oregon

In Oregon the rules for agricultural burning include, but are not limited to, measures to ensure that crop residues are evenly distributed and in good burning condition, rapid ignition techniques are employed, and alternatives to open burning of fi elds are considered. For prescribed fires on wildlands, the Oregon Smoke Management Program requires land managers to consider utilization of residue, fuel reduction measures, alternate tr eatment practices, and reduction of prescribed burning emissions to achieve emissions reduction goals established within the Oregon Visibility Protection Plan. Burning during the spring when the 1000-hour and larger fuels have high fuel moisture is promoted. Post-burn reports require the tracking of fuel moisture content, ignition method, and other information to support calculation of ERT use.

3.3 Washington

In Washington, wildland land managers are encouraged to use techniques, such as fans, crane piling, mass ignition, accelerated mop-up, and other methods of increasing combustion efficiency and reducing the smoldering stage of burning. No tracki ng of specific ERTs is required. The Washington Smoke Management Plan for silvicultural burning does establish a tracking system to measure progress toward specific emission reduction targets. Burn days and specific burning conditions are established by the Department of Ecology for ag ricultural burning and a permitting system is in place.

3.4 Utah

Agricultural burning is not regulated by the State of Utah. However, counties require such burns to be conducted during optimal dispersion conditions. State air quality regulations require wildland land managers to take measures to prevent smoke impacts. State law requires identification of best management practices including the use of ERTs. Land managers are required to identify the techniques that are employed in addition to fuel moisture and ignition method in their daily emissions report.19 4. Establishment of Annual Emission Goals

4.1 Current ERT Application

Research has shown that ERTs can result in emission reductions, which, in turn, reduce smoke impacts on air quality. According to the Nati onal Wildfire Coordination Group’s (NWCG) Smoke Management Guide for Prescribed and Wildland Fire , methods used to reduce emissions generated from prescribed burning on wildla nds are: reducing the area burned, reducing fuel loading, reducing fuel production, reducing fuel consumed, sche duling burning before new fuels appear, and increasing combustion efficiency. 39

EPA’s Prescribed Burning Background Document and Technical Information Document for Prescribed Burning Best Available Control Measures states that the methods for reducing the amount of emissions generated from agricultural burning include: reducing the acres burned annually, altering the fuel distribution, improving firing techniques, and bur ning under optimum fuel

moisture. 40

4.2 Non-burning Alternatives and Annual Emission Goals

Annual emission goals, under this Po licy, are established annually and apply to the upcoming year’s projects where fire has been previously determin ed as the best tool for meeting specific land management objectives. Therefore, this Policy makes a distinction between thos e ERTs that are used

with fire and those techniques that replace fire (i.e., non-burning alternatives, sometimes grouped with ERTs). 41 For public lands, non-burning alte rnatives that replace fire are typically considered in long-term programmatic plans and do not coincide w ith annual operational plans for fire projects. By the time the project plan is being implemented, the decision to use fire as a tool to meet the land management objective has been made.

Land management decisions for federal land manage rs and possibly other land managers are made years in advance of actual project implementati on and for multi-year periods, under long-term land management plans or project plans. These plans, and the supporting NEPA analyses, are the process under which alternatives to burning and levels of management application of fire are established. This land management decision process is on a diffe rent temporal/spatial scale from project level operations. In addition, the decision by federal la nd managers to replace fire is based on other environmental considerations that cannot be adequa tely addressed on an opera tional basis, which is the focus of the application of ERTs for annua l emission goals, as defined by the Policy. Although specific projects may also go through a NEPA anal ysis during which non-burning alternatives may

39 NWCG’s Smoke Management Guide For Prescribed A nd Wildland Fire, 2001 Edition (hereafter referred to as “2001 Smoke Management Guide”), pages 143-151.

40 EPA’s Prescribed Burning Background Document and Tec hnical Information Document for Prescribed Burning Best Available Control Measures, September 1992, (hereafte r referred to as “EPA’s BACM Document”), p. 9-13.

41 See the Glossary in Appendix A for the definition of non- burning alternatives as used in this Policy. This

definition is not meant to contradict EPA’s as described in its BACM Document, but rather refers to the application of non-burning alternatives specific to annual em ission goals, as defined in this Policy.20 be assessed, again, these are typically done well in advance of the operational effort.

In distinguishing between ERTs us ed on fire projects and non-burning alternatives used to replace fire on other land management projects, it is the WR AP’s intent only to clarify the application of ERTs as the basis for annual emission goals. The WR AP supports efforts to utilize alternatives to burning (such as collection and removal of residue for use offsite with no subsequent on-site burning) in land management and fire management plans or other equivalent long-term plans. The use of non-burning alternatives is one of the key elements of the enhanced smoke management program as defined by the WRAP ESMP Policy. Furthe r, the WRAP encourages each state/tribe to work cooperatively with land managers to devel op ways to identify, implement, and track all feasible non-burning alternatives. 42

Several guidance documents provide information on the use of various types of non-burning alternatives that could be used by land managers. WRAP's 2001 Non-Burning Management Alternatives on Agricultural Lands in the Western United States identifies potential non-burning

management alternatives for agricultural burning including methods for assessing the impacts of

alternatives. The WRAP's draft Comprehensive Manual on Non-Burning Alternatives provides a catalogue of alternatives to prescribed burning on wildlands, includi ng a risk versus benefit decisionmaking process related to the use of alternatives. Although these guidance documents are useful for identifying non-burning alternatives, methods for calculating the benefits of using non-burning alternatives are not universally available for the WRAP region.

4.3 Determination of Appropriate ERTs

The opportunity for the application of ERTs va ries greatly. The 2001 Smoke Management Guide states, “ERTs vary widely in their applicab ility and effectiveness by vegetation type, burning objective, region of the country, and whether fuels are natural or activity-generated.” 43

For example, a maintenance burn in a brush vege tative type within a wilderness area may have virtually no options for ERT application. Alterna tively, multiple ERTs may be applicable in a ponderosa pine vegetation type where activity such as logging or thinning has occurred. The applicability of a particular technique or practice will depend, in part, on the objectives of that burn. For example, the objective of a prescribed bur n on wildlands may be to create open space for wildlife. A backing fire, which is a firing technique that is used to redu ce the amount of emissions generated, may not produce sufficient fire characteristics to achieve the management objective.

It is important to note that while ERTs offer an excellent tool for meeting goals for visibility protection, ERTs may cause negative effects such as soil compaction, nutrient loss, and impaired water quality on other valuable resources. Therefore, it is imperative that ERTs are used carefully, and that land managers and air regulators are pr ovided the information and training necessary to

make informed decisions.

42 See the WRAP Policy on Fire Tracking Systems.

43 2001 Smoke Management Guide, p. 141.21 4.4 Feasibility Criteria

The use of ERTs should be based on economic, sa fety, technical and environmental feasibility criteria, as well as land management objectives. The WRAP recommends that education and training are also included as feasibility criteria. It is imperative that education and training are provided to ensure that ERTs are used appropriately. All of the above criteria will affect the application of certain ERTs for vegetation or crop types, burning objectives, and area in the WRAP region.

Examples of how to apply the feasibility criteria are listed below.

Economic : What are the economic costs of applying a certain ERT? Is a specific ERT more economical than others? Any ERT that significantly reduces crop yields or exceeds the cost of a crop is not likely to be accepted by farmers or grow ers. The same concern is relevant to the application of ERTs on wildlands.

Safety : Are certain ERTs not feasible due to public and firefighter safety concerns? Are certain

ERTs not feasible due to concerns related to cont ainment of the fire, i.e., keeping the fire within certain boundaries? Do certain ERTs minimize the possibility of nuisance and hazard smoke?

Technical : Are the equipment and resources availabl e to utilize a specific ERT? Are sufficient training programs available in the use of ERTs for the land managers?

Environmental : Are there specific air quality and non-air quality environmental limitations (e.g., vegetation/crop type, fire type, time of year, area in WRAP region, soil compaction, water quality, etc.) that influence the use of certain ERTs?

Land Management Objectives : Is a certain ERT not feasible due to conflicts with land management objectives? Do certain ERTs maximize the like lihood of achieving the land management objective

of the burn?

4.5 Existing Guidance Documents

Several guidance documents provide information on the use and effectiveness of various types of ERTs that could be used by land managers to c ontrol fire emissions and reduce smoke impacts. EPA’s BACM Document, the 2001 Smoke Manageme nt Guide, and the GCVTC’s Fire Emission Project 44 are three examples.

EPA’s BACM Document provides information on ERTs for both wildland and agricultural burning. The BACM Document is one of the best comprehensive references on potential ERTs for agricultural burning. Most of the WRAP states do not have agricultural smoke management programs, so the demand for additional research is minimal. Once agricultural smoke management programs are developed, further research on comm on ERTs for agricultural burning applications may be available.

44 WRAP Report: Integrated Assessment Update and 2018 Emi ssions Inventory for Prescribed Fire, Wildfire and Agricultural Burning (DRAFT), Appendix A, pp. 61-96.22 The 2001 Smoke Management Guide presents inform ation on the use and effectiveness of ERTs, frequency of specific ERT usage, and qualitative assessment of emission reductions achieved through the use of ERTs. The majority of the information presented in the Guide was gathered from fire practitioners at three national workshops held during the fall of 1999. Much of the research into ERTs and subsequent emissions benefits for w ildlands, such as the Consume software program, 45

has been conducted in the Pacific Northwest, although the general principles are applicable elsewhere in the WRAP Region.

The GCVTC’s Fire Emission Project assessed th e potential application of ERTs by wildland vegetation type and fire type on a region-wide basis. Included in the assessment was percentage of

feasible use of ERTs for these w ildland vegetation and fire types, with the emissions reduced as a

result of the use of ERTs also evaluated.

4.6 Research Needs

ERTs have been proven to reduce fire emissions through documented research, but more research is needed to make them a more quantifiable tool for land managers. The 1999 Air Quality Policy on Agricultural Burning emphasized this fact by st ating, “Emission reduction technology to reduce the impact of pollutants emitted from agricultural burning on ambient concentrations is needed”. 46

The identification of common ERTs for agricultural burning is a difficult task since most of the WRAP states do not have smoke management programs to address agricultural burning, and

therefore the demand for such information is not great. Information regarding availability, applicability, and cost effectiveness of ERTs can be found in various research documents, but a comprehensive guide does not currently exist.

The research on ERTs for wildland fire was pre dominantly conducted in the Pacific Northwest. Although the general principles are applicable el sewhere in the WRAP Region, more research is needed on ERTs for wildland fire, with emphasis placed on vegetation types located outside of the

Pacific Northwest.

4.7 Calculation of Averted Emissions

According to the 2001 Smoke Management Guide, “The overall potential for emission reductions from prescribed fire depends on the frequency of use of emission reduction techniques and the

amount of emission reduction that each method offers.” 47 Therefore, in order to determine the potential for emission reductions from prescribed fire, land managers will need to calculate the specific amount of emission reduction that each me thod offers. Consume 2.1, a fuel consumption and emissions model, can be used to estimate potential emission reductions that may be achieved by

45 Pacific Northwest Research Station, Forestry Scie nces Laboratory, Consume Software, Version 2.1.

46 Agricultural Air Quality Task Force’s (AAQTF) Air Qua lity Policy on Agricultural Burning, Recommendation to the U.S. Department of Agriculture, November 10, 1999.

47 2001 Smoke Management Guide, p. 152.23 employing certain ERTs. 48

The WRAP recognizes the need for a more comp rehensive guide for estimating potential emission reductions achieved through the use of ERTs fo r agricultural burning and wildland fire. This guidance will be developed by the WRAP in a sim ilar format to that of Appendix D to support states’ and tribes’ use of annual emission goals. Appendix D provides a table that lists ERT options that can be applied by land managers and the co rresponding emissions averted by using a particular

ERT.

The 2001 Smoke Management Guide contains several ta bles that may be useful to states/tribes in order to establish annual emission goals. The tables include information on the frequency of use of specific ERTs by region of the country, the genera l effectiveness of specific ERTs, the significant constraints limiting the wider application of ERTs, and the potential emission reductions that may be achieved by employing various ERTs as estimated by Consume 2.1. There are some limitations to the information contained in the 2001 Smoke Manageme nt Guide, as some ve getation types that are found in the WRAP region are not included.

These tables should be utilized with the understanding that the effectiveness of a particular ERT may vary considerably. Considering all burning nati onally, if ERTs were optimally used, emissions could probably be reduced by appr oximately 20-25 percent assuming all other factors (vegetation types, acres, etc.) were held constant and land management goals were still met. 49 Individual states/tribes or regions may be able to achieve greater emission reductions than this or much less depending on the states’ or regions’ individual situations.

48 Ottmar, Roger D.; Reinhardt, Timothy E. ; Anderson, Gary; DeHerrera, Paul J. C onsume 2.1 User’s Guide. Gen. Tech. Rep. PNW-GTRxxx. Portland, OR: U.S. De partment of Agriculture, Forest Service, Pacific Northwest Research Station.

49 J. Peterson and B. Leenhouts, “What Wildland Fire Condi tions Minimize Emissions and Hazardous Air Pollutants and Can Land Management Goals Still Be Met?” (Draft), August 20, 1997.24 

### APPENDIX D
Example of ERT & Associated Emission Averted Table (This example demonstrates the future guidance that will be issued by the FEJF.)

ERT Category Practice Treatment Size

Class Vegetation Type Smolder Equation Reduction

Factor

All Ponderosa Pine N/A ERT Emissions =

Total Emissions x

0.9 0.1

First Entry

All Pinyon/Juniper Woodland, Oak Brush, Sage, Desert Shrub, Annual Grass,

Perennial Grass N/A

ERT Emissions =

Total Emissions x

0.9 0.1 Increased

Combustion Efficiency Backing

Fires

Maintenance All Ponderosa Pine, Pinyon/Juniper, Woodland, Oak Brush, Sage, Desert Shrub, Annual Grass,

Perennial Grass N/A

ERT Emissions =

Total Emissions x

0.9 0.1