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### Annual Emission Goal For Fire
**Introduction** As required b y 40 CFR 51.309(d)(6)(v), an Annual Emission Goal will be established y earl y to minimize emission increases from fire, excluding emissions from wildfire. The emissions goal will be determined b y quantifying the emission reductions obtained through the use of emission reduction techniques (ERT) on a burn project specific basis. The emission goal will be established for the planned burn projects for the upcoming ye ar at the beginning of the calendar ye ar. In addition, the emission goal will be established in cooperation with federal, state and private land managers and landowners. The Annual Emission Goal is based on the use of ERT(s) to minimize emissions from fire, in accordance with the WRAP Policy on Annual Emission Goals for Fire . An ERT is a technique for controlling emissions from fires to minimize the amount of emissions produced per acre or unit burned. Research has shown that fire emissions can be minimized through the use of ERT(s) that incre ase combustion efficiency and reduce the smoldering stage of burning. There are six general categories of ERT(s): reduce the area burned, reduce fuel load, reduce fuel production, reduce fuel consumed, schedule burning before new fuels appear, and increase combustion efficiency

. In formation on available ERT(s) will be gathered from the National Wildfire Coordination Group’s (NWCG) Smoke Management Guide for Prescribed and Wildland Fire 1 , Environmental Protection Agency ’s (EPA) Prescribed Burning Backgroun d Document and Technical Information Document for Prescribed Burning Best Available Control Measures 2 , documents issued by Western Regional Air Partnership, and related field experience. Where the emissions reduced or averted through the use of ERT(s) cann ot be quantified with confidence due to the current state of the science, the State of Wyoming commits to participate in the development of further refinements in such calculation methodologies.
**Annual Emission Goal Process** To establish the Annual Emissi on Goal, the State of Wyoming will follow the process described below. The WDEQ will organize a meeting at the beginning of the calendar y ear with land managers and landowners and will work collaboratively to establish the annual goal. The planned burn p rojects for the upcoming year will be reviewed based on the burn project registration form, a requirement of WAQSR Chapter 10, Section 4. The burn project registration form will include identification of the ERT(s) to be implemented, based on consideration of the feasibility criteria listed below.

1 National Wildfire Coordination Group, Smoke Management Guide For Prescribed and Wildland Fire , 2001 Edition. 2 U.S. EPA, Prescribed Burning Background Docum ent and Technical Information Document for Prescribed Burning Best Available Control Measures , September 1992.2

The benefit from using the ERT(s) will be quantified either b y quantifying the emissions averted through the use of ERT(s) using available emission factors or quantifying the percent of total acres on which ERT( s) are applied for all planned burn projects. The quantification of the emission reductions achieved through the use of the ERT(s) constitutes the emissions goal. The planning and reporting of ERT(s) is a minimum element of the quantifiable Annual Emissi on Goal. The Annual Emission Goal should utilize the total planned burn project emissions such that the effect of planned ERT(s) or percent use of ERT(s) are shown in relation to total planned burn project emissions. Should total planned burn project emiss ions not be available, the State of Wyoming will identify a timeline to develop such an emissions inventory

. The ERT(s) applied per burn project during the previous y ear will be identified on the burn project reporting form, a requirement of WAQSR Chapter 10, Section 4. An assessment of the burn project reporting form information will be conducted to verify application and to improve the information base. **Feasibility Criteria** The following feasibility

criteria will be used to evaluate ERT(s) for potentia l use: economic, safet y, technical, environmental, and land management objectives. Examples of how to appl y the feasibility criteria are listed below.
Economic : What are the economic costs of appl yi ng a certain ERT? I s a specific ERT more economical than others? Any ERT that significantly

reduces crop yi elds 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 ERT(s) on wildlands. Safety : Are certain ERT(s) not feasible due to public and firefighter safet y concerns? Are certain ERT(s) not feasible due to concerns related to containment of the fire, i.e. keeping the fire within certain boundaries? Do certain ERT(s) minimize the possibility of nuisance and hazard smoke?
Technica l : Are the equipment and resources available to utilize a specific ERT? Are sufficient training programs available in the use of ERT(s) for the Land Managers?
Environmental : Are there specific air quality and non

- air qualit y environmental limitations (e. g., vegetation/crop t ype, fire ty pe, time of ye ar, area in State, soil compaction, water qualit y, etc.) that influence the use of certain ERT(s)? Land Management Objectives : I s a certain ERT not feasible due to conflicts with land management objectives? D o certain ERT(s) maximize the likelihood of achieving the land management objective of the burn?