Fw:EPA-R10-OAR-2010-0930 2010-0930

R10-Public Comments Public Comments Public Comments to: Todd Hawes 06/26/2012 04:04 PM

Sent by: Steve Body

History: This message has been forwarded.

----- Forwarded by Steve Body/R10/USEPA/US on 06/26/2012 04:04 PM -----

From: Patti Gora-McRavin <pattigora@gmail.com>

To: R10-Public Comments@EPA, 

Date: 06/20/2012 04:41 PM

Subject: EPA-R10-OAR-2010-0930

June 20,2012

Docket ID No. EPA–R10–OAR–2010–0930

Safe Air for Everyone is a non-profit organization founded by physicians and concerned citizens in 2001 

to address the public health concerns from agricultural field burning in Idaho . Our members live 

primarily in Idaho, Eastern Washington, and Western Montana. 

We have just read the proposal Idaho is submitting regarding its Regional Haze Plan. According to this 

document, none of Idaho’s class I areas are projected to achieve the uniform rate of haze cleanup 

progress needed to achieve natural visibility conditions by 2064.

In fact, Idaho is saying that – with current or planned controls – it will take 112 years to achieve natural

conditions at Craters of the Moon, 161 years at Sawtooth, and 221 years at the Selway-Bitterroot 

Wilderness area. 

It is not reasonable for the state to submit a SIP that provides no additional controls at all to provide for 

additional reasonable progress. Idaho is refusing to adopt even low cost controls on stationary sources 

that could produce additional progress, and stronger controls on field burning are reasonable and 

cost-effective ways of achieving some additional reductions. 

The state’s main rationale for doing nothing seems to be that wildfires are responsible for most of the 

problem, however a closer examination of the facts regarding agricultural burning are in order to 

establish if this is a reasonable approach.

According to the Idaho Regional Haze SIP, on page 76 it states:

8.1.6 Fine Particulate Matter - PM Fine Emissions

PM fine includes particulate matter of 2.5 microns and less. PM fine is composed of

secondary aerosols formed by chemical reactions (excluding particulates of SOx and NOx), fine 

soil , or other materials ground to 2.5 microns or less. The PM2.5 emissions
from the mobile category are captured in the particulates accounted for in the NOx and SOx 

emissions. Table 8-6 shows the largest source category of PM fine is windblown dust at 26% 

(agriculture, mining, construction, and stockpiling of blowable material). Area source is the 

second largest source category with emissions attributed to things like

woodstoves and small manufacturing and industrial source activities.

Future PM fine emissions from both area and point sources are expected to increase with

the growth in population and industrial sources. Some of the increase is expected to be

offset with the 54% reduction anticipated from anthropogenic fire. Overall, PM fine is

expected to grow roughly 12% by 2018.

We see that the State is estimating a 54% reduction in anthropogenic fires. Yet, from the period between 

2002 to present, we have seen a significant increase in agricultural burning. 44,280 acres were burned on 

state lands in 2002 (Source: 2002 Idaho Agricultural Smoke Management Program Statewide

Summary, February 26, 2003) and for the 2011 year, 

Statewide, 65,362 acres were burned under the CRB program in 2011, similar to the amount 

burned in 2010. For most of the SMAs across the state, the number of acres burned during 2011 

was similar to, or lower than, the number of acres burned in 2010. The most notable difference 

for 2011 was a substantial increase in acres burned in the Northern Magic Valley and Southern 

Magic Valley SMAs, which saw increases in acres burned of 39% and 83%, respectively.

http://www.deq.idaho.gov/media/802757-crb-annual-report-entire-2011.pdf

These acreage totals do not count the amount of agricultural burning on Tribal lands within Idaho state 

boundaries. 

So between 2002 to present, there has been a 47.61% increase in acres burned on state lands in Idaho. 

Again, with the lack of enforcement on weekends and holidays along with anecdotal reports from 

growers and other observers that there is significant illegal burning during those times , (as discussed on a 

panel at the Region X Air workshop in Boise, April 18, 2012) the number is likely much higher. 

The new Crop Residue Burn program created by Idaho in 2008 assumed that acreage burned in North 

Idaho would be more than in South Idaho, or at least roughly equal. We know now that acreage in the 

south is at least double that in the north, and that these acreage increases are positioned in areas closest to 

Class I Wilderness areas of concern. 

It makes good sense then, to make a plan to ramp down the emissions from agricultural field burns in 

those areas to offer the best chance of meeting the Regional Haze goals. The agreement reached with 

SAFE and other stakeholders was designed to be able to accomplish health-based protections from the 

hazards of agricultural burning by linking burn approvals to 75% of any NAAQS. These include not just 

PM 2.5, but also ozone and any other criteria pollutant. Ozone levels have been increasing in the areas 

near Craters of the Moon, and DEQ has responded to that increase in ozone by considering changing the 

basic health protections that are currently in place in order to allow increasing amounts of agricultural 

burning. For the last two years, the DEQ has proposed considering a rule change that would lift that 75% 

of NAAQS limit for ozone, and this would have the effect of actually increasing agricultural burning 

above levels we have today. 

SAFE has worked to convince the DEQ that this would be a bad idea. For the time being, DEQ has 
agreed not to propose such a rule, but they have indicated strong interest in pursuing this path forward in 

the future. Clearly, when reading the Regional Haze SIP and seeing the impacts of agricultural burning 

on the Class I Wilderness areas, it makes sense to us to keep the 75% of NAAQS limits as we all agreed 

to as one way of limiting the growth of agricultural burning to contributing to deterioration of Class I 

Wilderness areas in Idaho and across the border into Yellowstone. Other limits are appropriate to meet 

regional haze goals sooner than 150 or more years. 

The long-term strategy in a SIP must contain enforceable emission limitations, compliance schedules, 

and other measures necessary to achieve the reasonable progress goals. 40 C.F.R § 51.308(d)(3). To 

ensure that the 75% of NAAQS limit on burning remains effective in the event that Idaho DEQ backs 

away from this commitment, EPA should establish this limit as a federally enforceable measure in the 

SIP.

Idaho sources contribute significantly to haze in Montana and Wyoming Class I areas. In particular, 

Idaho contributes 28% of the PM pollution in Yellowstone, is 3rd in contributing to visibility impairment 

at Glacier, and second in contributing to impairment at Bridger Wilderness. These areas are significantly 

off the target of achieving natural conditions by 2064. Yellowstone is projected to reach natural 

visibility conditions in 161 years; Glacier will reach natural visibility in 167 years; the Bridger 

Wilderness is projected to achieve natural conditions in 153 years. 

Under regional haze regulations, when sources within a state contribute to visibility impairment in 

another state’s Class I area or areas, “the State must demonstrate that it has included in its 

implementation plan all measures necessary to obtain its share of the emission reductions needed to meet 

the progress goal for the area. If the State has participated in a regional planning process, the State must 

ensure it has included all measures needed to achieve its apportionment of emission reduction obligations 

agreed upon through that process.” 40 C.F.R §51.308(d)(3)(ii) (emphasis added). Idaho cannot 

demonstrate that it has included "all measures necessary" to improve visibility impairment in 

Yellowstone NP, Glacier NP, and the Bridger Wilderness unless it places limits on pollution from field 

burning.

We ask any Regional Haze plan would include limits to agricultural burning as an important and 

significant tool in haze reduction. One important way is to make the existing 75% of NAAQS 

requirement a part of the Federally enforceable SIP. Secondly, additional acreage restrictions are in 

order. These require no special equipment to purchase, and the ability to grow crops is not hindered by 

using alternative methods to burning. 

Sincerely,

 Patti Gora-McRavin

Executive Director

Safe Air for Everyone