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 Forum 
i 

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 regulatory authority) and tribes with implementing the 

Regional Haze Rule (Rule). 

The WRAP Policy on Annual Emission Goals for Fire (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 tribes can use to efficiently develop their individual 

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

develop, adopt and implement their regional haze implementation plans, and recognizes the Rule as 

the principal document on which states and tribes should rely. 

The Rule requires states to develop implementation plans (SIPs) for addressing regional haze in the 

Nation’s 156 mandatory Class I areas. Additionally, the Rule requires effective management of fire 

sources. The Rule provides two pathways for western states to follow as they implement the 

requirements of the Rule: 1) develop their regional haze implementation plans per the nationally 

applicable provisions of Section 308, or 2) Transport Region states may choose to incorporate the 

Grand Canyon Visibility Transport Commission (GCVTC) Recommendations into their regional 

haze implementation plans under Section 309 of the Rule. 

The GCVTC recognized that projected increases in fire activity will result in episodic impacts on 

visibility in the West, and called for the development of annual emission goals that would minimize 

these impacts. Section 309 of the Rule specifically requires 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 states, tribes, land management agencies and private 

entities. 

The WRAP defines the annual emission 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 requires 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 Tribal Authority Rule (TAR), 40 CFR 49. The intent 

of this Policy is to assist both states and tribes with the development of their regional haze 

implementation plans (SIPs/TIPs), and therefore, tribes are included in all references to states, 

except where specific requirements and/or deadlines of the Rule are cited. In the case of annual 

emission goals, the WRAP considers them a viable tool 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 related documents listing, (C) 

additional guidance for states/tribes on the implementation 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 16 

 
iv 

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 24 
1 

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 control2 

fire emissions for WRAP states and tribes. Annual emission goals are required for states under 

Section 309 of the Regional Haze Rule. 

 

B) Annual emission goals will achieve the minimum 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 feasibility criteria, and land management objectives. 

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. 

G) States and tribes will need to develop a procedure 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), and 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 States. The GCVTC signed and submitted more than 

70 recommendations to the Environmental Protection Agency (EPA) in a report dated June 1996 that 

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

a comprehensive strategy was needed to remedy regional haze. 

 

2

 “Control” as used in this Policy means the use of techniques 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 Federal land management agencies (Bureau of Land Management, 

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

Commission, and the Environmental Protection Agency. 
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-impairing aerosols, including organic carbon, elemental 

carbon, and particulate matter (PM2.5).”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 strategies 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 processes and approved by consensus of the WRAP. 

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

EPA, environmental groups, industry, academia and other interested parties. There are over 400 

tribes within the WRAP region. The large number of tribes limits the participation of all of them in 

WRAP activities, and accordingly, in the development of this Policy. Therefore, the tribal 

representatives involved in the development of this Policy may not represent all tribal concerns. 

2.3 Regional Haze Rule

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

July 1999 to improve visibility in 156 national parks and wilderness areas across the country. The 

Rule outlines the requirements for states and tribes to address 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 thirteen western states and thirteen 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 Cheyenne Tribe, Salish and Kootenai Confederated Tribes, 

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

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

7 WRAP Charter, Purpose, p. 1. 

8

 64 FR 35759. 
3 

cases, EPA still recognizes that “unlike States, tribes are not required by the TAR to adopt and 

implement CAA plans or programs, thus tribes are not subject to mandatory deadlines for submittal 

of implementation plans.”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 coordinated 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 implementation 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 WRAP region-wide, multi-state/tribe stakeholder 

planning and coordination effort. The intent of the WRAP AEG Policy is to assist states (or the 

delegated authority) and tribes to address smoke impacts 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 techniques (ERTs) to meet the annual emission goals 

requirement of the Rule. Although this Policy promotes the use of ERTs to meet the annual emission 

goals requirement of Section 309 of the Rule, it does 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 framework for annual emissions goals that can be 

reasonably implemented by states and tribes. The WRAP believes that states maintain the ultimate 

responsibility for the implementation of annual emission goals. Further, states are responsible for 

incorporating into their implementation plans federally enforceable processes to minimize emission 

increases from fire, whether they choose to use 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. The WRAP recognizes that the implementation plans 

will be revisited and revised, per the schedule specified 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 implementation of annual emission goals is a 

viable technique to control fire emissions for 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 consistent and equitable framework that states and 

tribes can use to efficiently develop their regional 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 emissions if a state’s or tribe’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’ projection 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 public 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 fire 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 Treatment 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 Prevention 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 associated 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 use 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 currently 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 would need to have emissions inventory data adequate to 

establish an emissions baseline, establish 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 emission goals requirement of Section 309 due to the 

inability to directly control the emissions from wildfires. 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 used 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 entities, federal and non-federal, be subject to the same requirements, 

authorities and processes,25 the WRAP AEG Policy will be applied equitably to all fire sources, 

excluding wildfire. 

The WRAP AEG Policy specifically does not apply 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 residential, commercial, or industrial property (e.g., 

backyard burning, garbage incineration, residential 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 practical approach to establishing annual emission goals that 

states and tribes can use in their 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 determined in one year’s time. The annual level of fire 

activity is dependent on a variety of external factors such as crop type planted, funding for federal or 

state fire programs, weather, etc. These factors will 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, November 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 than the specific numeric value (which varies from 

year to year), will be included in implementation plan submittal. In other words, the goal will focus 

on the efforts to minimize emissions; this process, being in the implementation plan, will be 

federally enforceable. 

Third, the WRAP region represents wide variety with 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 must 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 total amount of emissions generated from each fire 

project. Control of fire emissions is accomplished by using emission reduction techniques (ERTs), 

methods proven to reduce fire emissions.28 

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

Additionally, methods exist for tracking and calculating the emissions averted from the use of ERTs 

for a broad array of vegetation types. For the purposes of this Policy, non-burning alternatives are 

not ERTs. Non-burning alternatives are techniques that replace fire as a means to achieve a 

particular land management objective (e.g., reduction 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 impacts 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 sensitive areas (e.g., non-attainment areas, Class I areas, 

nearby communities). Smoke management techniques may give consideration to downwind air 

quality (e.g., nuisance impacts and National Ambient 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 operational phase of the fire project. The decision to burn 

a specific area has already been made prior to the 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 Policy, 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 would be the sum of emission reductions from all 

fire projects where ERTs are used across the state or tribal jurisdiction, for the upcoming year. 

 

28 The GCVTC projected that the use of optimal smoke management measures (which include the use of ERTs) could 

decrease fine particle (PM2.5) emissions from prescribed fires by approximately 15-20%. This resulted in modeled 

visibility improvements over the planning period 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 alternatives, 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 application of ERTs, and allows the calculation of 

an annual numeric value that indicates progress toward minimizing increases from fire emissions. 

The second option is provided for instances where estimates 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 authorities 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 certain ERT to a specific vegetation or crop type, 

although more than one ERT may be feasible for 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 example 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 practices to determine appropriate ERTs for the 

respective vegetation or crop type.

Option 1 

Once applicable ERTs for the respective vegetation or crop type are agreed upon, the 

potential percentage use of ERTs is determined 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 emissions 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 established unilaterally across fire source sectors 

for either Option 1 or 2, there are benefits to establishing them by source sector so as to account for 

differences in management practices between agricultural 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 projects with similar vegetative or crop types and land 

management objectives. The annual goal should be established after the evaluation of all potentially 

applicable ERTs.

This Policy encourages states/tribes to coordinate with neighboring states/tribes to improve the 

knowledge base of ERTs and to maintain consistency 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 dependent 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 appropriately and at levels 

of usage that are feasible. It should be noted that the specific land management 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 moisture 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 Appendix 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 tracking the achievement of annual emission goals. 

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

facilitate the state's/tribe's ability to ensure accountability of individual 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, for 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 that 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 developed to support the tracking of the achievement of 

annual emission goals. 

States/tribes can utilize the tracking procedure for 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 assess the effectiveness of their control measures, 

including “...a summary of the emissions reductions 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 actions to meet specific objectives (i.e., 

managed to achieve resource benefits) on agricultural land. 

Agricultural Land – Agricultural land includes croplands, pasture, and other lands on which crops or 

livestock are produced. Rangeland will be included 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 from 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 impacts of some action. An example of a Best 

Management Practice with respect to air quality would be conducting a prescribed burn when 

atmospheric ventilation is good, which in turn promotes smoke dispersal. 

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 Federal Areas are: 1) international parks, 2) 

national wilderness areas and memorial parks larger than 5,000 acres in size, 3) national parks that 

exceed 6,000 acres in size and which were in existence when the 1977 Clean Air Act amendments 

were enacted. The extent of a mandatory Class 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 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, and 

that has regulatory consequences. See also 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 objectives, 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 inclusively 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-loading, manipulation of fuels, enhancement of 

wildlife habitat, ecosystem restoration, 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-vegetated 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 meadows (Natural Resources Conservation Service 

National Range and Pasture Handbook, 1997.) 

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

numerous sources over a wide geographic area. 

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

the health-based NAAQS due to emissions from fire. 
13 

Smoke Management - Programs, practices, and techniques 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, Nevada, New Mexico, Oregon, 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 cultivated (i.e., the soil is disturbed less frequently than 

once in 10 years), is not fallow, and is not in the USDA Conservation Reserve Program (CRP). The 

land may be neglected altogether or managed for such purposes as wood or forage production, 

wildlife, recreation, wetlands, or protective plant cover (EPA Interim Air Quality Policy on 

Wildlands and Prescribed Fires). The land is not “agricultural land” as operationally defined above. 

 Silvicultural land and rangelands (per the FEJF charge), woodlots, and private timberlands will be 

included with wildlands for the purposes of the FEJF work. 
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 and 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/Archives/2000/Policy/Burning%20Policy.htm

Tribal Authority Rule 

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

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

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 Agricultural 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 Categorization 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 consult the WRAP Fire Categorization Policy for further 

detail. 

Fire Categories36 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 emission goals will be incorporated into the Section 309 implementation 

plans submitted to EPA in order to meet the requirements of the Rule. States/tribes complying with 

Section 309 are required to have a regional haze implementation plan that addresses the 16 

mandatory Federal Class I areas of the Colorado 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 the 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 requires the establishment of annual emission goals 

for fire, the methods that are promoted 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 emission goals for fire (excluding wildfire) be 

established through 2018 as a means for demonstrating 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 annual 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 toward 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 are due every five years. 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. 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 regulatory authorities promote the use of ERTs as part 

of a voluntary management program while others enforce the use of ERTs through rule making. For 

example, the California Agricultural Burning Guidelines enforce the use of ERTs by specifying 

requirements for the burning of rice, barley, oat, and wheat straw. The Guidelines require the use of 

a "crackle test" to determine if the fuel is dry 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 increasing combustion efficiency and reducing the 

smoldering stage of burning. 

Although a few states in the WRAP region do promote 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), Transmittal 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 agricultural 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 specific 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 fields are considered. For prescribed fires on 

wildlands, the Oregon Smoke Management Program requires land managers to consider utilization 

of residue, fuel reduction measures, alternate treatment 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 tracking 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 agricultural 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 National Wildfire Coordination Group’s (NWCG) Smoke 

Management Guide for Prescribed and Wildland Fire, methods used to reduce emissions generated 

from prescribed burning on wildlands are: reducing the area burned, reducing fuel loading, reducing 

fuel production, reducing fuel consumed, scheduling 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 burning under optimum fuel 

moisture.40

4.2 Non-burning Alternatives and Annual Emission Goals

Annual emission goals, under this Policy, are established annually and apply to the upcoming year’s 

projects where fire has been previously determined as the best tool for meeting specific land 

management objectives. Therefore, this Policy makes a distinction between those 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 alternatives that replace fire are typically considered in 

long-term programmatic plans and do not coincide with 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 managers and possibly other land managers are made 

years in advance of actual project implementation 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 different temporal/spatial scale from project level 

operations. In addition, the decision by federal land managers to replace fire is based on other 

environmental considerations that cannot be adequately addressed on an operational basis, which is 

the focus of the application of ERTs for annual emission goals, as defined by the Policy. Although 

specific projects may also go through a NEPA analysis during which non-burning alternatives may 

 

39 NWCG’s Smoke Management Guide For Prescribed And Wildland Fire, 2001 Edition (hereafter referred to as 

“2001 Smoke Management Guide”), pages 143-151. 

40 EPA’s Prescribed Burning Background Document and Technical Information Document for Prescribed Burning 

Best Available Control Measures, September 1992, (hereafter 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 emission 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 used on fire projects and non-burning alternatives used to replace 

fire on other land management projects, it is the WRAP’s intent only to clarify the application of 

ERTs as the basis for annual emission goals. The WRAP 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. Further, the WRAP encourages each state/tribe to 

work cooperatively with land managers to develop 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, including 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 varies greatly. The 2001 Smoke Management Guide 

states, “ERTs vary widely in their applicability 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 vegetative type within a wilderness area may have 

virtually no options for ERT application. Alternatively, 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 burn on wildlands may be to create open space for 

wildlife. A backing fire, which is a firing technique that is used to reduce 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 provided the information and training necessary to 

make informed decisions. 

 

42 See the WRAP Policy on Fire Tracking Systems. 

432001 Smoke Management Guide, p. 141. 
21 

4.4 Feasibility Criteria

The use of ERTs should be based on economic, safety, 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 growers. 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 containment 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 available 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 likelihood 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 control fire emissions and reduce smoke impacts. 

EPA’s BACM Document, the 2001 Smoke Management Guide, and the GCVTC’s Fire Emission 

Project44 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 common ERTs for agricultural burning applications 

may be available. 

 

44 WRAP Report: Integrated Assessment Update and 2018 Emissions Inventory for Prescribed Fire, Wildfire and 

Agricultural Burning (DRAFT), Appendix A, pp. 61-96. 
22 

The 2001 Smoke Management Guide presents information 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 wildlands, 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 the 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 wildland 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 stating, “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 predominantly conducted in the Pacific Northwest. 

Although the general principles are applicable elsewhere 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 method 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 Sciences Laboratory, Consume Software, Version 2.1. 

46Agricultural Air Quality Task Force’s (AAQTF) Air Quality 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 comprehensive guide for estimating potential emission 

reductions achieved through the use of ERTs for agricultural burning and wildland fire. This 

guidance will be developed by the WRAP in a similar 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 corresponding emissions averted by using a particular 

ERT. 

The 2001 Smoke Management Guide contains several tables 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 general 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 Management Guide, as some vegetation 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 nationally, if ERTs were optimally used, emissions 

could probably be reduced by approximately 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. Consume 2.1 User’s Guide. Gen. Tech. 

Rep. PNW-GTRxxx. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 

49 J. Peterson and B. Leenhouts, “What Wildland Fire Conditions 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