wildland fire in ecosystems - effects of fire on air

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Abstract _____________________________________

Sandberg, David V.; Ottmar, Roger D.; Peterson, Janice L.; Core, John. 2002. Wildland fire on

ecosystems: effects of fire on air. Gen. Tech. Rep. RMRS-GTR-42-vol. 5. Ogden, UT: U.S.

Department of Agriculture, Forest Service, Rocky Mountain Research Station. 79 p.

This state-of-knowledge review about the effects of fire on air quality can assist land, fire, and air

resource managers with fire and smoke planning, and their efforts to explain to others the science

behind fire-related program policies and practices to improve air quality. Chapter topics include air

quality regulations and fire; characterization of emissions from fire; the transport, dispersion, and

modeling of fire emissions; atmospheric and plume chemistry; air quality impacts of fire; social

consequences of air quality impacts; and recommendations for future research.

Keywords: smoke, air quality, fire effects, smoke management, prescribed fire, wildland fire, wildfire,

biomass emissions, smoke dispersion

The volumes in The Rainbow Series will be published through 2003. The larger bold check-mark boxes indicate the volumes

currently published. To order, check any box or boxes below, fill in the address form, and send to the mailing address listed below.

Or send your order and your address in mailing label form to one of the other listed media.

RMRS-GTR-42-vol. 1. Wildland fire in ecosystems: effects of fire on fauna.

RMRS-GTR-42-vol. 2. Wildland fire in ecosystems: effects of fire on flora.

RMRS-GTR-42-vol. 3. Wildland fire in ecosystems: effects of fire on cultural resources and archeology.

RMRS-GTR-42-vol. 4. Wildland fire in ecosystems: effects of fire on soil and water.

RMRS-GTR-42-vol. 5. Wildland fire in ecosystems: effects of fire on air.

Send to: ________________________________________________________________________________Name

________________________________________________________________________________

Address

Fort Collins Service Center

Telephone (970) 498-1392

FAX (970) 498-1396

E-mail rschneider/[email protected]

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Mailing Address Publications Distribution

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Fort Collins, CO 80526-2098


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Cover photoPhoto by Roger Ottmar. Smoke blots out

the sun during the 1994 Anne Wildfire in western Montana.

Wildland Fire in Ecosystems

Effects of Fire on Air

Authors

David V. Sandberg, Research Physical Scientist, Corvallis ForestrySciences Laboratory, Pacific Northwest Research Station, U.S. Depart-

ment of Agriculture, Corvallis, OR 97331

Roger D. Ottmar, Research Forester, Seattle Forestry Sciences Labo-ratory, Pacific Northwest Research Station, U.S. Department of Agricul-

ture, Seattle, WA 98103

Janice L. Peterson, Air Resource Specialist, Mt. Baker-Snoqualmie

National Forest, U.S. Department of Agriculture, Mountlake Terrace,WA 98053

John Core, Consultant, Core Environmental Consulting, Portland, OR

97229


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Preface _____________________________________

In 1978, a national workshop on fire effects in Denver, Colorado, provided the impetusfor the Effects of Wildland Fire on Ecosystems series. Recognizing that knowledge of

fire was needed for land management planning, state-of-the-knowledge reviews wereproduced that became known as the Rainbow Series. The series consisted of sixpublications, each with a different colored cover, describing the effects of fire on soil,

water, air, flora, fauna, and fuels.

The Rainbow Series proved popular in providing fire effects information for professionals,students, and others. Printed supplies eventually ran out, but knowledge of fire effectscontinued to grow. To meet the continuing demand for summaries of fire effects knowledge,

the interagency National Wildfire Coordinating Group asked Forest Service research leadersto update and revise the series. To fulfill this request, a meeting for organizing the revision was

held January 4-6, 1993, in Scottsdale, Arizona. The series name was then changed to TheRainbow Series. The five-volume series covers air, soil and water, fauna, flora and fuels, andcultural resources.

The Rainbow Series emphasizes principles and processes rather than serving as asummary of all that is known. The five volumes, taken together, provide a wealth of information

and examples to advance understanding of basic concepts regarding fire effects in the UnitedStates and Canada. As conceptual background, they provide technical support to fire and

resource managers for carrying out interdisciplinary planning, which is essential to managing

wildlands in an ecosystem context. Planners and managers will find the series helpful in manyaspects of ecosystem-based management, but they will also need to seek out and synthesize

more detailed information to resolve specific management questions.

The AuthorsDecember 2002

Acknowledgments____________________________

The Rainbow Series was compiled under the sponsorship of the Joint Fire Science Program,

a cooperative fire science effort of the U.S. Department of Agriculture, Forest Service, and theU.S. Department of the Interior, Bureau of Indian Affairs, Bureau of Land Management, Fish

and Wildlife Service, National Park Service, and U.S. Geological Survey.Several scientists provided significant input without requesting authorship in this volume. We

acknowledge valuable contributions by Sue A. Ferguson, Timothy E. Reinhardt, RobertYokelson, Dale Wade, and Gary Achtemeier. We also thank the following individuals for theirsuggestions, information, and assistance that led to substantial technical and editorial

improvements in the manuscripts: Scott Goodrick, Allen R. Riebau, Sue A. Ferguson, and PattiHirami. Finally, we appreciate Marcia Patton-Mallory and Louise Kingsbury for persistence and

support.

ii


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Contents________________________________________________

Page Page

iii

Summary ........................................................................ iv

Chapter 1: Introduction .................................................... 1

Objective ............................................................................. 2

Related Publications ........................................................... 2

Scope .................................................................................. 2

Framework .......................................................................... 2Prior Work ........................................................................... 3

Smoke Management Guide For Prescribed

and Wildland Fire: 2001 Edition ............................... 3

Wildland Fire and Air Quality: National Strategic

Plan.......................................................................... 4

Introduction to Visibility ............................................... 4

The Federal Advisory Committee Act White

Papers ..................................................................... 4

Environmental Regulation and Prescribed Fire

Conference .............................................................. 5

Southern Forestry Smoke Management

Guidebook ............................................................... 6

Changes in Fire Policy ........................................................ 6

Joint Fire Science Program ........................................ 6Cohesive Strategy ...................................................... 7

National Fire Plan ....................................................... 7

Chapter 2: Air Quality Regulations and Fire .................. 9

Roles and Responsibilities Under the Clean Air Act ......... 10

National Ambient Air Quality Standards............................ 11

Prevention of Significant Deterioration.............................. 11

Visibility ............................................................................. 12

Regional Haze .......................................................... 13

Reasonable Progress ............................................... 15

Hazardous Air Pollutants .................................................. 15

EPA Interim Air Quality Policy on Wildland and

Prescribed Fires..................................................... 16

Natural Events Policy ........................................................ 16

Collaboration Among Stakeholders .................................. 16Best Available Control Measures ...................................... 16

Reducing Emissions ................................................. 17

Redistributing Emissions .......................................... 17

Ozone and Fire ................................................................. 17

Chapter 3: Overview of Air Pollution from Fire ............ 19

Magnitude of Fire Contributions ........................................ 19

Smoke from Wildland Fires ...................................... 20

Smoke from Prescribed Fires ................................... 24

Impacts on National Ambient Air Quality

Standards .............................................................. 24

Significance of Visibility Degradation........................ 24

Greenhouse Gas Emissions from Fires .................... 24

Smoke Management Programs ........................................ 25

Chapter 4: Characterization of Emissions fromFires ....................................................................... 27

Area Burned ...................................................................... 27

Preburn Fuel Characteristics ............................................ 28

Fire Behavior ..................................................................... 29

Combustion Stages ........................................................... 30

Fuel Consumption ............................................................. 31

Emission Factors............................................................... 32

Source Strength ................................................................ 32

Chapter 5: Transport, Dispersion, and Modeling

of Fire Emissions ................................................... 35

Basic Elements of Trajectory and Dispersion ................... 35

Heat Release ............................................................ 36

Plume Rise and Buoyancy ....................................... 36

Advection and Diffusion ............................................ 37

Scavenging ............................................................... 38

Chemical Transformations ........................................ 38Transport and Dispersion Models ..................................... 38

Plume Models ........................................................... 38

Puff Models ............................................................... 39

Particle Models ......................................................... 39

Grid Models .............................................................. 39

Model Application .............................................................. 40

Chapter 6: Atmospheric and Plume Chemistry ........... 41

Ozone Formation in Plumes ............................................. 41

Factors Affecting Plume Chemistry ................................... 42

Emission Factors for Reactive Species ............................ 43

Particle Formation in Plumes ............................................ 43

Chapter 7: Estimating the Air Quality Impacts of

Fire ................................................................. 45

Emission Inventories ......................................................... 45State Emission Inventories ....................................... 46

Regional Emission Inventories ................................. 46

National Emission Inventories .................................. 47

Improving Emission Inventories ................................ 47

Air Quality Monitoring ........................................................ 48

Current Monitoring Techniques ................................ 48

Source Apportionment ...................................................... 49

Source Apportionment Methods ............................... 50

Receptor-Oriented Approaches ................................ 50

Factor Analysis and Multiple Linear Regression ...... 52

Summary .................................................................. 52

Mechanistic Models .......................................................... 53

Chapter 8: Consequences of Fire on Air Quality ......... 55

Health Effects .................................................................... 55National Review of Health Effects ............................ 55

Occupational Exposure to Wildland Fire Smoke ...... 56

Research Issues ....................................................... 57

Welfare Effects .................................................................. 58

Soiling of Materials ................................................... 58

Public Nuisance and Visibility Loss .......................... 58

Economic and Social Consequences ............................... 59

Soiling-Related Economic Losses ............................ 59

Visibility-Related Costs ............................................. 59

Highway Safety ................................................................. 60

Magnitude of the Problem ........................................ 60

Measures to Improve Highway Safety ...................... 60

Climate Change ................................................................ 61

Chapter 9: Recommendations for Future Researchand Development .................................................... 63

Established Research Framework .................................... 63

Emerging Research Needs ............................................... 65

Emissions Source Strength and Emissions

Inventory ................................................................ 65

Ambient Air Quality Impacts ..................................... 66

Effects on Receptors ................................................ 66

Conclusion ........................................................................ 67

References ........................................................................ 69


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SummaryWildland fire is an integral part of ecosystem manage-

ment and is essential in maintaining functional ecosys-tems, but air pollutants emitted from those fires can be

harmful to human health and welfare. Because of thepublic and governmental concerns about the possiblerisk of wildland fire smoke to public health and safety, as

well as nuisance, visibility, ozone generation, and re-gional haze impacts, increasingly effective smoke man-

agement programs and air quality policies are beingimplemented with support from research and land man-

agement agency programs.This state-of-knowledge review of what is known about

the effects of fire on air quality has been prepared toassist those in the fire and air quality managementcommunities for future discussion of management, policy,

and science options for managing fire and air quality. The

introduction sets up a framework in which to discuss theinteraction between pollutants emitted from fire, and airquality at the national, State, and local levels applied to

air resource management, fire management, and geo-graphical scale components. It also provides an over-view of science reviews conducted since 1979 and

discusses recent changes in fire policy, strategies, andfunding. The Clean Air Act and its amendments are

discussed in chapter 2, in the context of how and why fireimpacts each issue, what information is needed, and who

needs it to fulfill legal requirements under the act. Na-tional ambient air quality standards, regional haze andvisibility, hazardous air pollutants, and best available

control methods are some of the topics covered. Chapter3 covers the magnitude of the impacts of prescribed and

wildland fire on air quality, and contains an overview ofsmoke management plans intended to manage those

impacts.

Chapters 4 through 7 present scientific and technical

discussions. Chapter 4 discusses the characterizationand production rate of emissions from fire in terms of

fuels, fire behavior, stages of combustion, fuel consump-tion, and emission factors of various pollutants. The basicelements and modeling of transport and dispersion are

covered in chapter 5, including, plume, puff, particle, andgrid models. Chapter 6 considers plume and atmo-

spheric chemistry, the chemical reactions that occur inplumes, with a focus on ozone formation and particle

formation. Use of emission inventories, air quality moni-toring, and source apportionment methods, and mecha-

nistic models to estimate the impacts of fire on air qualityare covered in chapter 7. Chapter 8 reviews the health,welfare, economic, and safety consequences of these

impacts. The final chapter recommends priorities for

future research to better understand and quantify fire andits effect on air quality.

iv

Metric Equivalents

When you know: Divide by: To find:

Feet (ft) 3.28 Meters

Pounds (lb) 2.21 Kilograms

Acres 2.47 Hectares

Pounds per acre 0.89 Kilograms per

hectare

Fahrenheit (F) 1.8 and subtract 32 Celsius


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USDA Forest Service Gen. Tech. Rep. RMRS-GTR-42-vol. 5. 2002 1

Chapter 1:IntroductionA state-of-knowledge review, E ffects of F i re on A i r,

was writ ten in 1979 to inform environmental agen-

cies, fire managers, and land management planners,

and to guide research strategies in the intervening

year s (Sa ndberg a nd others 1979). Tha t review is st ill

technically sound for the most part , but substantial

new knowledge is now a vaila ble. In t his volume, weupdate th at review of knowledge importa nt for man -

aging t he effects of fire on a ir a nd for adjusting t he

course of new research. In addit ion, we expand the

scope of our review to place the information in the

context of new policies regarding fire management

and a ir quali ty management

Acquisition of scientific knowledge regarding air

pollution from fires is motiva ted by a ctive policy devel-

opment both t o restore the r ole of fire in ecosystems

and to improve air quality . Land managers require

quantitat ive analysis and goal-seeking solutions to

minimize the negative consequences of fire manage-

ment . Managing f ire and a ir quali ty to the standardsset by Congress requires an increasingly detailed base

of scientific knowledge and information systems.

The Federal Wildland Fire Policy(U.S. Department ofthe Interior and U.S. Department of Agriculture 1995)

and the Clean Air Act as Amended 1990 (PL 101-549)resulted in the need to significantly raise the level of

knowledge about fires effects on air in order to meet

regulatory and m an agement requirements. For example,

new information is needed to assess, monitor, predict,

and mana ge:

E m iss ion s a n d a i r qu a li t y im pa c ts f rom w i ld -

fires

Acute hea l th e ffect s of human exposure to

smoke

Na tura l and a n thropogenic sources of v is ib il-ity reduction

Cumula t ive a i r qua l it y impact s f rom expanded

fuel ma na gement programs

Tradeof fs between a i r qua li t y impact s f rom

wildland fire and prescribed fire

Likewise, man agement of fire and a ir qua lity is also

undergoing substa ntia l policy development tha t h as

led to the need for new an d different informa tion to

sat isfy regulatory an d mana gement requirements. As

both legal and management issues mature, there is

less a sense tha t environmenta l regulat ion is a limita -

tion on fire management, and more of a sense thatecosystem management goals, fire safety, and air

quality are goals to be met collectively. For example,

new a ir qua lity rules recognize the importa nce of the

role of fire in susta ining ecosyst ems an d the inherent

tradeoffs between prescribed fire and wildland fire

occurrence. At t he sam e time, land ma na gement pla ns

an d r eal-t ime fire ma na gement decisions increasingly

factor in the expected consequences to air quality.


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2 USDA Forest Service Gen. Tech. Rep. RMRS-GTR-42-vol. 5. 2002

Since 1995, researchers and land managers have

concentrated a great deal of energy to extend what is

known a bout fire and it s effect on a ir qua lity; to expand

information systems that make knowledge readily

ava ilable to policy, ma na gement, and public clients; t o

merge what is known about sustainable ecosystems

an d disturba nce ecology with wha t is known a bout t he

chemistr y, physics, biology, and social im pacts of a ir

pollution; and to redefine the research a genda .

Objective ______________________

This review summa rizes the current sta te of knowl-

edge of the effects of fire on a ir, a nd defines resea rch

questions of high priority for the management of

smoke from fires. We also intend this as a reference

document for future discussion of ma na gement, policy,

an d science options for ma na ging fires a nd a ir qua lity .

This review is limited to readily available published

an d unpublished knowledge an d t o original contribu-

tions by the aut hors. No new a na lysis of dat a or policy,

nor assessment of impacts and options, is includedherein.

Related Publications _____________

This document does not stand alone. There are

several excellent sources for informa tion on th e effects

of fire on a ir. We advise th e reader t o include at lea st

the following publications, each of which will be ab-

stra cted in th is document, in your reference library:

Smoke Management Guide for Prescribed andWildland F i re: 2001 E dition(Ha rdy and oth-

ers 2001) National S trategi c Plan: Modeling and Data

Systems for Wi ldland F i re and Ai r Quali ty(Sandberg and others 1999)

I ntroduction to V isibi li ty(Malm 2000) F i re E ffects on Ai r (Sa ndberg a nd others 1979) Southern Forestr y Smoke Management Gui de-

book (Southern Forest Fire Laboratory Per-sonnel 1976)

Development of Emissi ons I nventory Methodsfor Wi ldland F i re(Ba t tye and Ba t tye 2002)

Why, then, is another state-of-knowledge review

necessary on the subject of fire effects on air? First,because policy and regulatory development in air

quali ty ma nagement and in f ire mana gement is ad-

vancing rapidly, and there is a continuing need to

reassess current knowledge about w ha t is required to

meet new expectations. Second, this document ad-

dresses the adva ncement of science at a much higher

level than the above-mentioned references. Third,

because t he J oint Fire Science Program ha s sponsored

a s eries of reviews, nicknam ed the Ra inbow Series (see

P refa ce), t o compile a broa d reference of fire effects

to serve practit ioners a nd policyma kers charged w ith

using and ma na ging fire, and this is the third volume

in that series. Finally, we hope you will find this

volume a useful at tempt t o abstra ct and fill in the gaps

left by th e previous publications.

Scope _________________________

This review includes all hea lth a nd w elfare effects of

a ir pollution from fires, but does not in clude the effects

of air resource management on ecosystem health or

an y other va lue. Unless otherwise specifically st at ed,

the term fires in t his ma nuscript includes all pre-

scribed and wildland fires on wildlands. Prescribed

fires are ignited intentionally to achieve ecosystem

management or fire protection objectives, whereas

wildland fires result from unplanned ignit ions on

wildlands. Wildlands include all the nonagricultural

and nonresidential rural lands of the United States,

including t he w ildland-urban interface, regardless of

ownership, sovereignty, or management objective.Mana gement response to wildlan d fires differs great ly

according to economic efficiency, the values at risk

(including air quality), and the expected ecological

consequences. Wildfires a re a t one end of th e spectru m

of wildland f ires in tha t they a re unwant ed and un-

planned, an d a re ma na ged to minimize cost plus loss.

At the other end of the spectrum are wildland fires

that benefit ecosystem values, and are managed to

ma ximize their benefit . I deally, each w ildland fire is

evalua ted w ith r espect t o expected costs , losses, risks,

an d benefits in order to provide an a ppropriate a nd

preplanned response. B ecause fires a re a significant

emitter of air polluta nts, ma ny other fire ma na gement

activit ies such as fire prevention or fuel treatment

ma y ha ve an indirect effect on a ir quality .

Framework _____________________

The issues, responsibilities, and tools that address

fire and a ir qua lity a re varied a nd complex, sometimes

result ing in confusion about the physical scale and

temporal sta ge of th ree cha racterist ics: the a pplica-

tion to fire management, the application to air re-

source ma na gement, an d th e physical process of air

pollution. National S trategi c Plan: Modeling and DataSystems for Wi ldland F i re and Ai r Quali ty(Sa ndberga nd others 1999) provides a conceptua l fra mew ork for

visualizing fires effects on air by representing the

scope of the problem as a three dimensional array of

air resource mana gement, fire mana gement, and scale

component s (fig. 1-1). The a ir r esource component is

ordered in time from emissions source strength, to

am bient a ir qua lity , and to effects. The fire ma na ge-

ment component includes planning, operations, and


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monitoring. The scale component includes the event ,

landscape, sta te or tr ibal, and r egiona l scales.

We ha ve organ ized this volume around the a ir re-

source component a nd expan ded it t o include a regu-

lat ory perspective (fig. 1-2). F ire in t he context of t he

regulatory environment is the subject of chapters 2

and 3. Biomass consumption and emissions are the

subject of cha pter 4; tra nsport a nd dispersion of pollut-

an ts in t he at mosphere the subjects of cha pters 5 and

6; air qua lity impacts th e subject of cha pter 7; an d the

effect on huma n va lues from exposure to air polluta nt s

th e subject of cha pter 8. We conclude wit h a review of

recommendations for future research in chapter 9.

Prior Work _____________________

Since the publication of E ffects of F i re on Ai r(Sa ndberg a nd others 1979), significan t changes ha ve

come to pass in both the technical and policy issues

that surround the fire and air quality dilemma. The

conferences, sta keholder group discussions, a nd t ech-

nical publicat ions discussed here ha ve helped to shape

the current fire ma na gement programs a nd w ill influ-

ence future programs.

Smoke Management Guide For Prescribedand Wildland Fire: 2001 Edition

Smoke Management Gui de for Prescr ibed and Wi ld-land F i re: 2001 Editi on(H ar dy a nd others 2001) ha sbeen developed by t he Fir e Us e Working Team of the

Na tional Wildfire Coordina ting G roup (NWCG ) a nd

involves most of the same authors as this current

publication. The guide provides fire management

an d smoke mana gement pract i t ioners with a funda-

mental understanding of fire emissions processes

a nd impa cts, regulat ory objectives, and t ools for the

ma na gement of smoke from fires. It is a comprehen-

Figure 1-1Three primary components of the issues, respon-

sibilities, and tools related to wildland fire and air quality: air

resource management, fire management, and scale (Sandberg

and others 1999).

Figure 1-2The relations of air regulations and physical processes to the three categories within the air

resource component. OSHA/NIOSH = Occupational Safety and Health Administration/National Institute for

Occupational Safety and Health (Sandberg and others 1999).


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sive t rea tment of the sta te of knowledge regarding

f ire and a ir qua li ty an d provides guidance to pract i-

t ioners. We will not a t t empt to duplicate its level of

deta i l in th is volume. Rather , w e add some technica l

background a nd a nalysis o f research needs rela t ive

to new requirements for ma nagement .

First published in 1985, the guide is intended to

provide national guidance for the planning a nd ma n-

aging of smoke from prescribed fires to achieve airqua lity requirements t hrough bett er smoke mana ge-

ment practices (NWCG 1985). This guide has been

widely distributed within t he fire community a nd a ir

qua lity regulatory agencies, and to privat e and Tribal

land managers, providing a single comprehensive

source of informa tion on fire and a ir qua lity issues.

Much ha s cha nged since 1985 in prescribed burning

practices, smoke ma na gement programs, an d air qua l-

ity regulatory requirements. These changes are re-

flected in th e 2001 edition of the gu ide, wh ich includes

expanded sections on fire and emissions processes,

smoke impacts on health, welfare, safety, and nui-

sance; regulations for smoke management; and thefundamenta ls o f responsible smoke management

(Ha rdy a nd others 2001). These funda ment a ls include

fire pla nnin g, use of smoke ma na gement met eorology,

techniqu es to reduce emissions, sm oke dispersion pre-

diction systems, air qua lity monitoring methods, and

program assessment.

The most significant change in the guide is the

expanded a nd upda ted section on techniqu es to reduce

emissions a nd impa cts. While th e 1985 guide focused

primarily on minimizing smoke impacts by meteoro-

logical scheduling and dispersion, the 2001 guide

provides detailed informa tion on emissions reduction

techniques, used in different regions of the country,tha t h ave been useful, practicable, and effective in th e

field. This empha sis on a ctua l reduction of emissions

ra ther t ha n dispersion w as provided in response to air

qua lity regulat ions tha t now ta rget regional emissions

reductions.

Readers w ill also find tha t t he 2001 guide has a great

deal more information on the latest developments in

national air quality regulations that affect fire pro-

gram s including th e regional ha ze and visibility pro-

tection program s, Clea n Air Acts conformit y requ ire-

ments, E P As I nter im Ai r Quality Policy on Wildlandand Pr escr ibed F i res(EP A 1998), an d NE P A plan ningguidance. The guide was drafted by 16 authors and

five editor/compilers workin g under t he sponsorsh ip

of the NWCG Fire Use Working Team with support

from the EP A.

Wildland Fire and Air Quality: NationalStrategic Plan

Another recent publication also provides a system-

at ic review of the sta te of knowledge and informa tion

systems. This strategic plan was also sponsored by

the NWCG an d the E nvironmenta l P rotection Agency

(E P A).

In 1997, th e NWCG Fire U se Working Team sa nc-

tioned a sma ll group of fire resear ch scientists a nd a ir

quality managers to develop a National StrategicPlan: Modeling and Data Systems for Wi ldland F i reand Ai r Quality (Sa ndberg a nd oth ers 1999) to foster

development a nd implementa tion of models a nd da tasystems that could be used to manage air quality

impa cts of fires. The result ing report provides a con-

ceptual d esign a nd st rat egic direction towa rd meeting

the increasing need for information required to ma n-

a ge emissions from fire (Sa ndberg a nd others 1999). In

November 1997, after 2 years of drafting and exten-

sive review of a draft plan, 86 experts at tended a

na tional w orkshop, a nd using t he discussion fra me-

work presented in this cha pter, they defined the cur-

rent st at e of knowledge, desired future condit ion, a nd

recommendations for research and development for

each cell in the discussion framework.

The stra tegic plan ta rgets a more technical, scien-tific, and policy-oriented audience than the smoke

ma na gement guide, and recommends a research an d

development stra tegy to reach a desired future stat e

for smoke management information systems. It also

provides a comprehensive treatment of policy and

technical issues that we will not duplicate in this

volume.

Introduction to Visibility

Air pollution impacts on visibility are discussed in

detail in I ntroduction to V i sibi li ty (Malm 2000). The

discussion isnot specific to th e impacts of fire but isrelevan t because of the regulat ory at tention given t o

fire in th e EP A Regiona l Ha ze Rule (40 CFR P ar t 51

1999) and because Federal land managers have the

responsibility of managing fires and the impacts of

fires and all other pollution sources on visibility in

many Nat ional Pa rks and wilderness areas. We make

no att empt in this volume to duplica te this discussion

of the a tm ospheric physics, meteorology, hist oric vis-

ibility t rends, monitoring a nd a pportionment method-

ologies, or huma n perceptions t ha t ar e so admira bly

covered in I ntroduction to V i sibi li ty.

The Federal Advisory Committee ActWhite Papers

During the 1997 to 1998 development of proposed

national ambient air quality standards (NAAQS) for

P M2.5 (particulate ma tter w ith a n a erodynamic diam-

eter less tha n or equa l to 2.5 microns) and r egiona l ha ze

regulations, E P A used provisions of t he Federal Advi-

sory C ommitt ee Act (FACA) to convene a la rge group of

sta keholders who were interested in providing input t o


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the regulatory process. A FACA committee for the

development of ozone, part iculat e ma tt er, and regiona l

ha ze implementa tion programs w as formed to a ddress

both policy a nd t echnical issu es. The commit tees S ci-

ence and Technology Wildla nd F ire Issu es G roup, one

of several working groups and subcommittees, re-

searched and dra fted five reports th at ar e briefly sum-

ma rized below (E P A 2000c).

Ai r Moni tor ing for Wi ldland F i re Operations pro-vides recommend a tions for conductin g a ir-monitoringprogram s designed to support fire a ctivit ies th at also

monitor for complian ce with NAAQS. I t a lso describes

how monitoring can support burning programs and

how land ma na gers can collaborate wit h air a gencies,

and it provides guidance for selecting monitoring

equipment.

E lements of a Smoke Management Progr am dis-cusses recommenda tions for a ba sic level smoke ma n-

agement program. The document summarized infor-

mation from an EPA-sponsored workshop held to

respond to specific quest ions posed by E P A. The docu-

ment describes the six basic components of a smokemana gement program:

Au t hor iz a t ion to b ur n

M in im iz in g em is si on s

B u rn pla n com pon en ts

P u blic ed uca t ion

S u r vei ll a n ce a n d en for cem en t

P r ogr am eva lua t ion

It also provides examples of monitoring methods,

public aw ar eness programs, a nd program enforcement.

E mission I nventor ies for S tate I mplementation Plan[S I P] D evelopmentdescribes several levels of inven-

tory complexity: a default level based on currentlyavailable information; a basic level program that is

considered the minimal program needed to support

SIP development; and a detailed inventory level wh en

a greater level of an alysis or a ccountability in inven-

tory precision is needed. Elements of each level of

inventory a re described, dat a sources a re identified

and data mana gement issues are discussed.

What Wildland F i re Conditions M inimize E mis-si ons and H azardous A i r Pollutants and C an L andManagement Goals S ti ll be Met? This pa per is a dis-cussion of fire conditions and techniques that mini-

mize pollutant emissions. Both wildland emissions

a nd prescribed fire emissions a re discussed. The dis-

cussion of emissions reduction techniques for pre-

scribed burning is also found in Smoke ManagementGuide for P rescri bed and Wildland Fi re: 2001 edition(H a rdy a nd others 2001).

E stimating Natural E missions from Wildland andPr escri bed F i rea ddresses how best t o define natura lemissions from fire. This is crit ical to implementin g

regiona l ha ze goals of reducing visibility degrada tion

caused by huma n-ma de sources of air pollution. The

paper dis cusses a ma tr ix of choices: (1) emissions from

fire necessary to restore and susta in desired ecosys-

tem cha ra cteristics, (2) fire needed to ma na ge fuels to

a condition where they can be dealt w ith most effec-

tively from a wildfire control standpoint, (3) no net

increase in fire emissions, and (4) no change from

current emissions.St akeholders reviewed, discussed, an d dra fted, ad-

ditional work on these five reports. The reports and

other technical references were considered by EPA

during the formulation of the regional haze regula-

tions and revisions to the par ticulate ma tt er NAAQS.

Environmental Regulation and PrescribedFire Conference

In Ma rch 1995 a conference on new developments in

environmenta l regulat ions related to prescribed fire

wa s held in Tam pa, FL (Conference Proceedings: E nvi -

ronmental Regulation & Prescri bed Fi re: Legal andSocial Challenges, B rya n 1997). This 3-da y m eetingincluded sessions on challenges an d st ra tegies rega rd-

ing the use of fire, air qua lity regulation, and liability ,

as well as social and economic issues. Sponsored by

numerous St at e and Federal environmenta l and for-

estry agencies, the conference provided a forum for

discussion of the Clean Air Act, Endangered Species

Act, and other Federal statutes that guide national,

St at e, and local regulations pertaining t o prescribed

fire.

Significan tly, a joint declar at ion dra fted by the con-

ference steering committee and presented to confer-

ence at tendees w as later signed by representa tives ofthe EP A, Sta te of Florida, Na tional B iological S urvey,

The Wilderness S ociety, F orest S ervice, a nd Ma riposa

County, Florida. In summa ry, the declara tion upheld

th e followin g prin ciples:

Pr a ct i t ioner l iab i li t y is a major obst acle to the

increased use of fire. Legislation should be

considered on the Federal level to protect

properly certified fire pra ctitioners except in

cases w here negligence is proven.

Pa r tnersh ips among a ll of the s t akeholders

are vital to the future use of fire. Efforts to

enhance such partnerships must be encour-aged especially in the exchange of informa-

tion, development of best m an agement prac-

tices, public education campa igns, an d funding

init iat ives.

Ag en cies sh ou ld w o rk t og et h er t o eva lua t e

tradeoffs between public health risks from

fire and ecological damage caused by fire

exclusion.


12/86


Publ ic educa t ion regard ing the use of pre-

scribed fire, ecosystem health, and risks of

w ildfire versus those from prescribed burning

is encouraged.

The role of f ir e in ecosys tem mana gement

needs to be understood by all stakeholders.

The ra mificat ions of not usin g prescribed fire

are serious and must also be appreciated as

limits on fire use may conflict with otherpublic ma nda tes.

Act ions pert a in ing to the use of f ir e must be

based on sound science. There are several

crucial knowledge gaps that must be filled.

Consequences to public safety caused by de-

laying the increases of prescribed fire are

great .

Publ ic and pr iva te proper ty owners need to

retain the right to use prescribed fire to pro-

tect and enhance the productivity of their

lands while also protecting nearby property

owners from a dverse impacts of burning.

Administ ra tors responsible for a l locat ing fundsshould do so on t he ba sis of regiona l priorities

wit h greater emphasis on prevention tha n in

the past .

An increased emphasis on t r a in ing for pre-

scribed fire pra ctitioners is needed to enha nce

public accepta nce.

Southern Forestry Smoke ManagementGuidebook

TheSouthern F orestr y Smoke Management Guide-

book(Southern Forest Fire La boratory P ersonnel 1976)

wa s one of th e first smoke man agement guidebooks

developed in t he U nited St at es for use by la nd, fire,

and air resources managers. The guide provides an

improved understanding of: (1) smoke management

an d a ir qua lity regulat ions; (2) contents of smoke and

variables affecting production; (3) smoke transport

a nd dispersion; (4) potent ial effects on huma n hea lth,

human welfare, and visibility ; and (5) what can be

done to mitigate its impacts. A system for predicting

a nd modifying sm oke concentra tions from prescribed

fires was introduced for Southern fuels.

Changes in Fire Policy ___________

The Federal Wi ldland Fi re Policy(USD I and USDA1995; US DI an d others 2001) requires that fire, as

a crit ical na tura l process, must be reintroduced into

the ecosystem to restore and maintain sustainable

ecosyst ems. This w ill be accomplished a cross a gency

boundaries and will be based on the best available

science. The policy req uires t he use of fire t o susta in

ecosyst em hea lth ba sed on sound scientific principles

an d ba lanced with other social goals including public

health a nd sa fety, air qua lity , and other specific envi-

ronmental concerns. Ea rly in the plan ning process,

action is required to involve public health and envi-

ronmental r egulat ors in developing th e most w orkable

a pplica tion of policies a nd regula tions. Agencies ar e

called on to create a system for coordination and

cooperation among land managers and regulators

tha t explores options with in existing law s t o allow forthe use of fire to achieve goals of ecosystem health

while protecting individual components of the envi-

ronment, huma n healt h, a nd sa fety. The policy a lso

requires that air q uality values be considered during

preparedness and fire protection. When setting pro-

tection priorit ies, land ma na gers must define values

to be protected working in cooperation with state,

local, an d tr ibal governments, permittees, an d public

users. Criteria will include environmental, commod-

ity, social, economic, political, public healt h, a nd other

values.

Several strategies and funding programs were de-

veloped to improve the ability of managers to fullyimplement t his policy.

Joint Fire Science Program

The J oint Fire Science Program (J FS P ) wa s creat ed

by Congress in the 1998 Appropriations to Interior

and Related Agencies bill to augment the delivery of

science and informat ion syst ems necessary t o mana ge

the increas ed use of fire a nd other fuel trea tm ents. The

legislat ion provides a ma nda te to protect air qu ality in

conjunction with economic efficiency and ecological

consequences. The program (National Interagency

Fire Center 2002 unpaginated) recognizes that:Land mana gers are rapidly expanding the use of fire

for mana ging ecosystems while air resource ma na gers

ar e accelerat ing efforts t o reduce the local a nd regional

impacts of smoke. Smoke management (meeting air

qua li ty standa rds) is a legal requirement of the Clean

Air Act, as well as a health and safety issue for the

general populace and fireline personnel. The J FS P will

attempt to define these social relationships and de-

velop ana lytical tools and communication practices to

help ma ngers include social considerations in d ecision

making.

One of the goals of the J FSP is to evalua te various

trea tm ent t echniques for cost effectiveness, ecological

consequences, and air qua lity impa cts. The progra mplan st a t es:

Methods ha ve not been developed to a ssess the oppor-

tunit ies, costs, a nd effectiveness of employing smoke

reduction techniques throughout th e country. Cur rent

models to assess regional sca le cumulative effects on

air qua li ty and w at er quali ty wil l need to be expanded.

The program w ill develop a n at ionally consistent sys-

tem of models for fuel consumpt ion, emissions produc-

tion, and smoke dispersal that can a ssess cumulative


13/86


effect. This research w ould also contribute t o under-

standing t he potential na tional and global impacts of

changes in biomass use, prescribed fire, and w ildland

fire on wood supply, atm ospheric chemistry, a nd car-

bon sequestration.

Cohesive Strategy

Protecting People and Sustaining R esources in F i re-

Adapted E cosystems: A Cohesi ve S trategy (Lavertyand Williams 2000) is the Federal framework estab-lished to restore and maintain ecosystem health to

reduce the threat and consequences of wildfires. It is

presumed that fire suppression over the past 100

year s ha s excluded fire from ma ny ecosyst ems, fueling

conditions for unna tura lly intense fires tha t , a mong

other effects, threat en air qua lity . Cit ing serious a ir

qua lity impacts from long dur at ion w ildfire episodes

in recent years, the report expresses concern that:

The extent to which management for ecosystem resil-

ience can improve air quality over the long term is not

completely known. Pr esent regula tory policies mea sure

prescribed fire emissions, but not wildland fire emis-sions. The emissions policy tends to constrain treat-

ments an d in short interva l fire systems may a ct to

inadvertently compound wildland fire risks. (p 34)

The cohesive strategy directs land management

agencies to collaborate with the EPA in addressing

long-term impa cts, tra deoffs, and issues regarding a ir

quality and other impacts. The report acknowledges

that programma t ic analysis of a ir q uali ty impacts w ill

be a necessary step in implementing the planned

increases in prescribed burning necessary to restore

the h ealt h of fire-prone ecosyst ems. The st ra tegy est i-

mates that the USDA Forest Service Regions would

increase fuel treatments by five-fold in the West andtw o-fold in th e Ea st a nd S outh to achieve restorat ion

goals within 10 years; or employ a slightly smaller

increase t o obta in results in 20 years. Most, but not a ll ,

of the treat ments w ould involve burning.

The relative risk to air quality was projected to

decreas e by about 25 percent a s a result of improving

the resilience of ecosystems, according to current

models.

The cohesive strategy is responsive to regulatory

responsibilities. The planned increase in burning is

constra ined in part by th e consideration to regulatory

obligations, with an acknowledgment that a more

rigorous assessment of impacts could substantially

change the planned extent and schedule of treat-

ments. C oncerns for public health issues an d firefighter

safety in relation to smoke are also expressed. The

stra tegy acknowledges tha t air qua lity issues must beanalyzed more thoroughly at smaller scales as it is

stepped down t o lan dsca pe a nd project level pla nning .

National Fire Plan

The National Fire Pla n wa s established inA R eportto the President I n R esponse to the Wi ldfi res of 2000(US DA and US DI 2000), an d implemented using Col-laborative Approach for R educing Wi ldfir e R isks toCommuniti es and the E nvi ronment: 10-Y ear Compre-hensi ve Strategy(Wester n G overnors Associa tion 2001).St akeholder groups under the sponsorship of the US DA

Forest Service, USDI, and the Western GovernorsAssociation prepared the implementation strategy.

This str a tegy recognizes tha t key decisions in sett ing

priorit ies for restoration, fire, a nd fuel ma na gement

should be made at local levels. As such, the plan

requires a n ongoing process whereby t he loca l, Triba l,

State and Federal land management, scientific, and

regulatory a gencies excha nge th e required technical

information, including the assessment of air quality

tr a deoffs, to inform t his decisionma king process. The

stra tegy has a goal o f mainta ining and enhancing

community health and economic and social well-be-

ing; and requires that public healt h risks from smoke

a re reduced, airs hed visibility is improved, an d smokema na gement plans ar e developed in conjunction with

prescribed fire plan ning a nd implementa tion.


14/86


Notes

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________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

________________________________________________________________

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15/86


This chapt er introduces the regulat ory environment

for smoke from prescribed an d w ildlan d fire, providing

updated discussion of the laws, regulations, stan-

dards, a nd regula tory st ra tegies tha t have changed

since a bout 1980. We explain roles a nd responsibili-

t ies of the regulat ory agencies and land m an agers, an dwe fra me the technical discussion in the cont ext of who

needs w ha t informat ion t o fulfill legal requirements.

Air pollution is the presence in the atmosphere of

one or more conta mina nts of a na ture, concentra tion,

and duration to be hazardous to human health or

welfa re (Sa ndberg a nd others 1999). Welfare includes

potential to harm animal or ecosystem health, eco-

nomic activity, or the comfortable enjoyment of life

and property. Air pollution is created from both hu-

man (that is, anthropogenic) and natural sources.

Anthropogenic air pollution is the presence in the

atmosphere of a substance or substances added di-

rectly or indirectly by a h uma n a ct , in such am ounts asto adversely affect humans, animals, vegetation, or

ma teria ls (Williams on 1973). Air polluta nt s a re clas-

sified into tw o ma jor cat egories: primar y an d second-

ary. Air pollutant emissions, or simply emissions,

are the production and release of air contaminants

emitted from fires that have a potential to cause air

pollution. This definit ion includes pa rt iculat es, hydro-

carbons, car bon monoxide (CO), meta ls, an d a ll oth er

Chapter 2: Air QualityRegulations and Fire

t ra ce gases that may be hazardous or tha t are chemi-

cal precursors to secondary air pollution. Primary

pollutants are those directly emitted into the air .

Un der certa in conditions, prima ry polluta nts undergo

chemical reactions within the atmosphere and pro-

duce new subst an ces known a s secondary polluta nts.Hazardous air pollutants are a special class of air

pollutants identified in the Clean Air Act Amend-

ments of 1990 as constituting a hazard to human

health .

Air quality is a measure of the presence of air

pollution. Ambient a ir qua lity is defined by the C lean

Air Act of 1963 as t he air qua lity a nyw here people have

a ccess, outs ide of indust ria l site bounda ries. Ambient

a ir quali ty standards are standards of a ir quali ty

designed to protect human health or welfare. Air

resource ma na gement includes any activity t o antici-

pate, regulat e, or m onitor a ir pollution, a ir polluta nt

emissions, ambient air quality , or the effects of airpollution resulting from fires or fire management.

In t he past , emissions from prescr ibed f ire were

considered huma n-caused, an d wildla nd f ires were

considered na tura l sources of emissions. But recent

policy deba te ha s focused on wh a t sh ould be consid-

ered na tura l ; tha t i s , t o be reasonably una f fec ted by

human inf luence. This debate resulted from the

paradox that not a l l wildland f ires are vigorously


16/86


suppressed and that some prescr ibed burning is

done to ma in t a in hea l thy na tura l ecosys tems where

fire has previously been excluded.

Air resource mana gement includes any a ctivity to

anticipate, regulate, or monitor air pollution, air pol-

luta nt emissions, ambient a ir qua lity , or the effects of

air pollution r esult ing from fires or fire ma na gement.

Em issions an d impacts on air qua lity from fires ar e

managed and regulated through a complex web ofinterrelated law s an d regulations. The prima ry legal

basis for air qua lity regulation across the na tion is the

Federa l Clea n Air Act (CAA), wh ich is actua lly a s eries

of acts, a mendments, an d regulations that include:

Federa l Air Pollut ion Control Act of 1955 (P L

84-159). P rovides for resear ch a nd technical

assistance and authorizes the Secretary of

Health, Education, and Welfare to work to-

wa rd a bet ter understa nding of the causes a nd

effects of air pollution.

Federa l C lean Air Act of 1963 (P L 88-206).

Empowers the Secretary of Health, Educa-

tion, and Welfare t o define air qua lity criteria

based on scientific studies. Provides gra nts to

state and local air pollution control agencies.

Federal Air Quality Act of 1967 (P L 90-148).

Est ablishes a fra mework for defining air q ual-

ity control regions based on meteorological

and topographical factors of air pollution.

Federa l C lean Air Act Amendments of 1970

(P L 91-604). P rincipal source of sta tut ory au -

thority for controlling air pollution. Estab-

lishes basic U.S. program for controlling air

pollution.

Environmenta l P rotect ion Agency (EP A) pro-mulgates nat ional ambient a ir quali ty stan-

da rds (NAAQS) for pa rticula tes, photochemi-

cal oxidan ts (including ozone), hydr oca rbons,

carbon monoxide, nitrogen dioxide, and s ulfur

dioxid e (1971).

C lea n A ir Ac t Am e n dm e n t s of 19 77 (P L 9 5-

95). Sets the goal for visibility protection

and improvement in C lass I a reas and as-

s igns Federa l l and managers the a f f i rma-

t ive responsibil i ty to protect a ir qua li ty re-

la ted va lues .

Clean Air Act Amendments of 1990 (P L 101-

549). E sta blishes a uthority for regulat ing re-gional ha ze and a cknowledges th e complexity

of the relat ion between prescribed and wild-

land fires.

Reg iona l Haze Regula t ions , F ina l Rule (40

CFR Part 51) (1999). EPA promulgates the

Regiona l Ha ze Rule supported in par t by t he

1998 Int erim Air Quality P olicy on Wildlan d

an d P rescribed Fires.

Roles and Responsibilities Underthe Clean Air Act ________________

St at es have the lead in carr ying out provisions of the

Clean Air Act because appropriate and effective de-

sign of pollution cont rol progra ms req uires a n under-

standing of local industries, geography, transporta-

tion, meteorology, urban and industrial development

patterns, and priorit ies. The EPA has the task ofset t ing a ir quali ty standards (nat ional ambient a ir

qua lity sta nda rds, or NAAQS). In a ddit ion, EP A de-

velops policy and technical guidance describing how

various Clean Air Act programs should function and

what they should accomplish. States develop State

implementa tion plan s (SIP s) tha t define and describe

customized programs they will implement to meet

requirements of the Clean Air Act. Tribal la nds a re

legally equivalent t o Sta te lands , and Tribes prepare

Tribal implementation plans (TIPs) to describe how

they will implement the Clean Air Act. Individual

States and Tribes can require more stringent air

quali ty sta ndards but cannot w eaken clean a ir goalsset by EP A.

Federal land managers have the complex role of

ma naging a f ire as a source of a ir pollutan ts, wh ile

fulfilling monitoring a nd regula tory responsibilit ies

t ied to visibi l i ty and regional haze. Federa l land

ma nagers a re given t he responsibili ty by t he Clean

Air Act for reviewing prevention of significant dete-

riorat ion (P SD ) permits (discussed lat er in this chap-

ter) of ma jor new a nd modified sta t iona ry pollution

sources and comment ing to the Sta te on whether

there is concern for visibility impacts (or other re-

source va lues) in Class I areas downwind of the

proposed pollution source. Some St a tes r equire mod-

eling of source impacts on Cla ss I area s, a nd Federa l

land ma na gers customarily comment on the model

results.

The 1990 Clean Air Act Amendments require

planned Federal actions to conform to SIPs. This

general conformit y rule prohibits Federa l agencies

from taking any act ion within a nonat ta inment or

ma intena nce a rea t ha t (1) causes or contributes to a

new violation of air quality standards, (2) increases

the frequency or severity of an existing violation, or

(3) delays the t imely a t ta inment of a standard as

defined in the applica ble SIP or area plan. The gen-eral conformit y rule covers direct a nd indir ect emis-

sions of criteria polluta nts , or their precursors, w hich

are caused by a Federa l ac t ion , a re reasonably

foreseeable , and can pract icably be controlled by

th e Federa l a gency t hrough i ts cont inuing program

responsibility .


17/86


National Ambient Air QualityStandards______________________

The purpose of the Clean Air Act is to protect

humans against negative health or welfare effects

from air pollution. Nat iona l ambient air qua lity sta n-

dards (NAAQS) are defined in the Clean Air Act as

am ounts of polluta nt above which detrimenta l effects

to public health or welfare ma y result . NAAQS ha vebeen esta blished for the following criteria polluta nt s:

par t icula te mat ter(P M10 and P M2.5; NAAQS for

particulate matter are established for two aerody-

namic diameter classes: PM10 is particulate matter

less tha n 10 microns in diam eter, and P M2.5 is less

tha n 2.5 microns in diameter; tota l suspended part icu-

late matter is called PM or sometimes TSP), sulfur

dioxide (SO2), nitrogen dioxide (NO2), ozone, carbon

monoxide (CO) an d lea d (Pb) (ta ble 2-1). P rima ry

NAAQS are set at levels to protect human health;

secondary NAAQS are to protect human welfare ef-

fects including visibility a s well as plant an d ma terials

damage.An a rea t ha t is found to be in violat ion of a prima ry

NAAQS is la beled a n onat ta inment a rea (fig. 2-1); an

area once in nonattainment but recently meeting

NAAQS, and with appropriate planning documents

approved by EPA, is a maintenance area; all other

areas are at tainment or unclassified (due to lack of

monitor ing). St a t e a ir qua li ty a gencies can provide

up-to-date locations of local nonattainment areas

(P M2.5 is a new ly regulat ed polluta nt , so at t ainment /

nonat t a inment sta tus ha d not been determined a t t he

time of publicat ion of this document; monit oring must

ta ke place for a t least 3 years before designation can be

made, which means PM2.5 status will likely not be

known until a t least 2003). St at es are required through

their SIPs to define programs for implementation,

ma intenan ce, a nd enforcement of the NAAQS w ithin

t h e i r b o u n d a r i e s . W i l d l a n d f i r e i n a n d n e a r

nonattainment areas will be scrutinized to a greater

degree than in a t t a inment areas and may be subject to

general conformity rules. Extra planning, documenta -tion, and careful scheduling of prescribed fires will

likely be required to minimize smoke effects in the

nonatt ainm ent area to the great est extent possible. In

some cases, the use of fire may not be possible if

significant impacts to a nonat ta inment area are likely.

The ma jor polluta nt of concern in sm oke from fir e is

fine part iculat e matt er, both P M10 an d P M2.5. St ud-

ies indicate that 90 percent of all smoke particles

emitted during wildland burning are PM10, and 90

percent of PM 10 is P M2.5 (Wa rd a nd Ha rdy 1991). The

most recent human health studies on the effects of

particulate matter indicate that fine particles, espe-

cially P M2.5, are la rgely responsible for hea lth effectsincluding mortality, exacerbation of chronic disease,

an d increased hospita l a dmissions (Dockery a nd oth-

ers 1993; Schw a rtz a nd others 1996).

Prevention of SignificantDeterioration ___________________

Another provision of the Clean Air Act with some

applicability t o wildland burning a ctivit ies is the pre-

vention of significant deterioration (PSD) provisions.

Table 2-1National ambient air quality standards (NAAQS) (U.S. Environmental Protection

Agency 2000b). Primary NAAQS are set at levels to protect human health;

secondary NAAQS are to protect human welfare.

Pollutant Averaging time Primary Secondary

PM10 Annual arithmetic mean 50 g/m3 a

50 g/m3

24-hour average 150 g/m3

150 g/m3

PM2.5 Annual arithmetic mean 15 g/m3

15 g/m3

24-hour average 65 g/m3

65 g/m3

Sulfur dioxide (SO2) Annual average 0.03 ppm

b

24-hour average 0.14 ppm

3-hour average 0.50 ppm

Carbon monoxide (CO) 8-hour average 9 ppm

1-hour average 35 ppm

Ozone (O3) 8-hour average 0.12 ppm 0.12 ppm

1-hour average 0.08 ppm 0.08 ppm

Nitrogen dioxide (NO2) Annual average 0.053 ppm 0.053 ppm

Lead (Pb) Quarterly average 1.5 g/m3

1.5 g/m3

ag/m

3= micrograms per cubic meter.

bppm = parts per million.


18/86


The goal of PS D is to prevent a reas th at ar e currently

cleaner than is allowed by the NAAQS from being

polluted up to the ma ximum ceiling esta blished by t he

NAAQS. Three air q ua lity class es were esta blished by

the Clean Air Act PSD provisions including Class I

(which a llows very lit t le a ddit ional pollution), Cla ss I I

(wh ich allows some incrementa l increase in pollution),

an d Cla ss II I (which allows pollution to increase up to

the NAAQS). Cla ss I ar eas include wildernesses an d

na tional memorial parks over 5,000 acres, Na tional

Parks exceeding 6,000 acres, and all international

par ks tha t w ere in existence on August 7, 1977, as w ell

a s la ter expan sions to th ese area s (fig. 2-2).

Histor ica l ly , E P A has regarded smoke from w ild-

lan d fires as temporar y an d therefore not subject to

issuance of a P SD permit ; wh ether or not wildland

fire smoke should be considered when calculating

P SD increment consumption or PS D ba seline wa s not

def ined. EP A recent ly rea f f irmed tha t St a t es could

exclude prescribed fire emissions from increment

analyses provided the exclusion does not result in

permanent or long-term air quality deterioration

(EP A 1998). St at es a re a lso expected t o consider the

extent t o which a pa r t icular type of burning act ivi ty

is t ruly temporary , as opposed to an act ivi ty tha t

could be expected to occur in a part icular a rea w ith

some regularit y over a long period. Oregon is t he only

St a te tha t ha s chosen to include prescribed fire emis-

sions in P SD increment an d ba seline ca lcula t ions.

Visibility _______________________

The 1977 am endment s to t he Clea n Air Act include

a na tional goal of the prevention of an y future, an d

the remedying of a ny existing, impairment of visibility

Figure 2-1PM10 nonattainment areas as of May 2002. Current nonattainment status for PM10 and all other criteria

pollutants are available from the Environmental Protection Agency (EPA) aerometric information retrieval system(AIRS) Web page at http://www.epa.gov/air/data/index.html (EPA 2002).


19/86


in manda tory Class I F edera l a reas which impairment

results from manmade air pollution (42 U.S.C

7491). St a tes a re required t o develop implementa tion

plans that make reasonable progress toward the

na tional visibility goal.

Atmospheric visibility is affected by scattering and

absorption of light by particles and gases. Particles

and gases in the air can obscure the clarity, color,

texture, and form of wha t w e see. Fine part icles most

responsible for visibility impairment are sulfates, ni-

tra tes, orga nic compounds, elementa l carbon (or soot),

an d soil dust . Sulfat es, nitrat es, organ ic carbon, andsoil tend to scatter light , whereas elemental carbon

tends t o a bsorb light. Fine part icles (P M2.5) a re more

efficient per unit mass than coarse particles (PM10

and larger) at causing visibility impairment. Natu-

rally occurring visual range in the Eastern United

States is estimated to be between 60 and 80 miles,

while natural visual range in the Western United

St a tes is betw een 110 a nd 115 miles(these estima tes

do not consider the effect of na tur a l fire on visibility)

(Trijonis a nd oth ers 1991). Cur rently , visua l ra nge in

the Ea stern U nited Sta tes is about 15 to 30 miles and

a bout 60 to 90 miles in the Western U nited S ta tes. (40

CF R P ar t 51). The theoretical ma ximum visual ra nge

a bout 240 miles.

Regional Haze

Regional haze is visibility impairment produced by

a multitude of sources and activit ies that emit fine

part icles and their precursors and ar e located a cross a

broad geographic ar ea. This contra sts with visibility

impairment th at can be traced largely to a single, large

pollution source. Until recently, the only regulations

for visibility protection a ddressed impairment t ha t is

reasonably at tr ibutable to a permanent, large emis-

sions source or sm a ll group of large sources. In 1999,

EP A issued regiona l haze regulat ions to mana ge and

mitigat e visibility impairment from th e multitude of

diverse regional h a ze sources (40 CFR P a rt 51). The

regiona l ha ze regulat ions call for Sta tes to establish

Figure 2-2Mandatory class 1 areas (Hardy and others 2001).


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goals for improving visibility in Class I Nat iona l Pa rks

a nd w ildernesses, and t o develop long-term st ra tegies

for reducing emissions of air pollutants that cause

visibility impa irment.

Regional Haze Planning ProcessBecause re-giona l haze is a multi-St at e issue, regiona l haze regu-

lations encourage States, land managers, and other

sta keholders t o work together to develop cont rol pro-

grams through regional planning organizations thatcan coordinate development of strategies across a

multi-St at e region. In the Western Unit ed Sta tes, the

Western Regional Air P ar tn ership (WRAP), sponsored

through the Western Governors Association and the

Nat iona l Tribal E nvironmenta l Council, is coordina t-

ing regiona l planning a nd t echnical a ssessments. The

WRAP w as the first of five regiona l planning organiza -

tions to be established and has been active in many

technical and policy developments. Other regional

planning organizations have begun assessments of

fire and air quality in their regions. In the Eastern

United States, four formal groups are addressing

planning issues: CENRAP (Central States Regional

Air Partnership), OTC (Ozone Transport Commis-

sion), VISTAS (Visibility I mprovement S ta te a nd Triba l

Association of the Southeast); and the Midwest Re-

gional Planning Organization (fig. 2-3).

As inter-State smoke transport becomes a larger

issue, agencies are expanding coordination of their

burns. Multi-St at e, interagency par tnerships are de-veloping to help coordinate burning and mitigate cu-

mulative impacts of smoke. For example, the Mon-

ta na /Ida ho airshed group includes private, St a te,

Tribal, and Federal partners in supporting an inte-

grated smoke management program that includes

emissions monitoring a nd smoke foreca sting (Levinson

2001).

Regional Haze and Fire EmissionsThe adop-tion of regional haze regulations marks a turning

point in how fire emissions are treated under the

nations Federal and State air quality regulations,

Figure 2-3Regional air quality planning groups (Hardy and others 2001).


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although the regulations leave several definit ions

open to subsequent policy interpreta tion:

The role of f ire in forest ecosystems is formally

recognized for the first t ime.

Emissions from na tura l sources a re dist in-

guished from anthropogenic sources and

treat ed differently under t he rule.

The rule is the first to require development of

emissions inventories for fire, including w ild-land fires.

Emissions f rom f ire a re now subject to re-

giona l air qu ality pla nning processes as w ell

a s r e q u i r e m e n t s t o a ch ie ve r e a so n a b le

progress in emissions reductions

The policy discussion t o determine w ha t t ypes of fire

emissions are considered natural is still in progress,

but the WRAP has recommended a national policy

that would (1) define natural background as fire

emissions t ha t w ould occur in the futur e without fire

ma na gement; tha t is, w ithout reference to historic fire

occurrence or hist oric vegeta tion t ypes; a nd (2) includeprescribed burning as natural sources of visibility

impacts when fire is used to maintain healthy and

susta inable ecosystems.

Current dat a from a na tional visibility-monitoring

netw ork (Sisler a nd others 1996) do not show fire t o be

the predomina nt long-term s ource of visibility impa ir-

ment in any C lass I a rea (40 CF R P ar t 51), although

emissions from fire are an important episodic con-

tributor t o visibility-impairing a erosols. C ertainly the

cont ribut ion to visibility impairm ent from fires ca n be

significant over short periods, but fires in general

occur relat ively infrequently a nd t hus ha ve a lesser

cont ribut ion to long-term a vera ges. Specific goals forvisibility improvement focus efforts on improving air

qua lity on the most impa ired days, so fires may prove

to be an importa nt ta rget for control efforts in some

areas

Fire Consortia for Advanced Modeling of Me-teorology and Smoke (FCAMMS)Multiagencyconsortia ar e building in the P acific Northw est , Rocky

Mountain region, and Northeastern and Southeast-

ern United Sta tes as par t of the U.S. Depar tment of

Agriculture, Forest Service, Fire Consortia for Ad-

va nced Modeling of Meteorology a nd S moke. The P a -

cific Northwest consortium is developing a real-timesmoke prediction a nd emission t racking system t ha t

addr esses needs of severa l smoke ma na gement plans

from collabora t ing St a t es, Tribes, and local a ir agen-

cies (Ferguson and others 2001). Cali fornia and

Nevada ar e working together through the Ca lifornia

and Nevada Smoke and Air Committee (CANSAC)

with similar object ives of t racking and predict ing

cumulative smoke impacts (Chris F ontana , persona l

communication).

Ea ch group or regiona l consortium mus t respond to

local, Sta te, and Tribal smoke mana gement program s.

In addit ion, each region of the country has its own

part icular at mospheric processes t ha t impact fire be-

havior and smoke dispersion in different ways. For

example, while in the Southeast , t iming of frontal

pas sa ges an d onshore flow r egimes become critica l, in

the Western United States, complex flow through

mountainous terra in is an important consideration inmanaging smoke. These regionally specific demands

a re forcing resea rch to focus on subt le aspects of smoke

emissions a nd dispersion inst ead of tra dit iona l devel-

opment of worst-case a ir pollution scena rios.

Reasonable Progress

Visibility rules require Sta tes to ma ke reasonable

progress towa rd th e Clean Air Act goal of prevention

of any future, and the remedying of any existing,

impairment of visibility. The regional haze regula-

tions did not define visibility ta rgets but instea d ga ve

St at es flexibility in determining reasonable progressgoals for Cla ss I a reas. St at es are required to conduct

an alyses t o ensure that they consider the possibility of

sett ing an ambitious reasonable progress goal, one

that is aimed at reaching natural background condi-

tions in 60 years. The rule requires Sta tes t o establish

goals for each affected Class I area to (1) improve

visibility on the haziest 20 percent of days, and (2)

ensure no degradation occurs on the clearest 20 per-

cent of days over the period of each implementation

plan.

States are to analyze and determine the rate of

progress needed for the implementation period ex-

tending to 2018 such that , if maintained, this ratewould att ain na tura l visibility conditions by the year

2064. To calculate this rate of progress, each State

must compare baseline visibility conditions to esti-

ma te nat ural visibility conditions in Class I a reas a nd

to determine the uniform rate of visibility improve-

ment that would need to be maintained during each

implementa tion period to at ta in na tura l visibility con-

ditions by 2064. B a seline visibility condit ions will be

determined from da ta collected from a na tional net-

work of visibility monitors representing all Class I

a rea s in th e country for th e years 2000 to 2004. Ea ch

Sta te must determine whether this ra te and associ-

ated emissions reduction strategies are reasonablebased on several statutory factors. If the State finds

that this rate is not reasonable, it must provide a

demonstration supporting an alternative rate.

Hazardous Air Pollutants _________

Hazardous air pollutants (HAPs) are identified in

Title II I of th e Clea n Air Act Amendm ents of 1990


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(PL 101-549) a s 188 different polluta nt s w hich present,

or may present, th rough inhala tion or other routes of

exposure, a t hreat of adverse human h ealth or envi-

ronmental effects wheth er through a mbient concen-

tra tions, bioa ccumula tion, deposition, or oth er routes.

The list of HAPs identified in the Clean Air Act are

substa nces t ha t a re known or suspected to be carcino-

genic, mutagenic, teratogenic, neurotoxic, or which

cause reproductive dysfunction.

EPA Interim Air Quality Policy onWildland and Prescribed Fires_____

In 1998, the E P A issued a na tional policy t o address

how best to achieve national clean air goals while

improving the q uality of wildland ecosystems t hrough

the increased use of fire. The I nteri m Air QualityPolicy on Wildland and Prescribed Fires(U.S. Envi-ronmental Protection Agency 1998) was developed

through a partn ership effort involving E P A, the U.S .

Departments of Agriculture, Defense, and the Inte-

rior, St at e foresters, Sta te an d Tribal a ir regulators,

a nd oth ers. The group th a t developed the policy relied

on the assum ption th at properly ma na ged prescribed

fires can improve the hea lth of wildlan d ecosystems

an d reduce the health a nd safety risks associat ed with

wildfire, while meeting clean air and public health

goals through careful planning and cooperat ion

among land ma nagers, air qua lity regulators, and local

communities.

Natural Events Policy ____________

P M10 NAAQS exceedan ces caused by n a tura l eventsar e not counted towa rd nonatt ainm ent designation if

a State can document that the exceedance was truly

caused by a natura l event and prepares a natura l

events a ction plan (NEAP ) to address huma n health

concerns dur ing fut ure events (Nichols 1996). Na tur a l

events a re defined by this policy a s wildfir e, volcanic,

seismic, an d high w ind events.

A wildfire NEAP should include commitments by

the State and stakeholders to:

1. Est ablish public notification and educat ion pro-

grams.

2. Minimize public exposure to high concentra tionsof PM10 due to future nat ural events such a s by:

a . Ident i fy ing the people most a t r isk.

b. Not i fy ing the a t -r isk public tha t a n event is

active or imminent.

c. Recommending a ct ions to be taken by the

public to minimize th eir polluta nt exposure.

d. Suggesting precautions to take if exposure

cannot be avoided.

3. Abat e or minimize controllable sources of P M10

including th e follow ing:

a. P rohibit ion of other burning during pollution

episodes caused by w ildfire.

b. P roactive efforts to minimize fuel loadings in

ar eas vulnerable to fire.

c. P lanning for prevention of NAAQS exceeda nces

in fire ma na gement plan s.

4. Ident i fy , study , and implement pract ica l mit iga t-ing measures as necessar y.

5. P er iodic reevaluat ion of the NEAP.

Collaboration AmongStakeholders ___________________

B ecause smoke from fire can nega tively a ffect public

health a nd w elfar e, air qua lity protection regulations

must be understood and followed by responsible fire

managers. Likewise, air quality regulators need an

understa nding of how an d w hen fire use decisions a re

made and should become involved in fire and smokemanagement planning processes, including the as-

sessment of when a nd how a lternat ives to fire will be

used. Cooperation and collaboration between fire

ma na gers and air qua lity regulat ors is of great impor-

tance. Table 2-2 contains recommendations for vari-

ous types of cooperat ion by th ese tw o groups depend-

ing on the a pplicable air qua lity protection instrum ent.

Best Available ControlMeasures ______________________

The application of best available control measures(BACM) for prescribed fire is a required element of

St at e implementa tion plans for PM10 nonatt ainm ent

areas that are significantly impacted by prescribed

fire smoke (EPA 1992a). The application of BACM is

also a requirement of EPAs Ai r Quali ty Poli cy onWildland and Prescr ibed F i res (EP A 1998) (see P riorWork section in chapter 1). EPAs BACM guidance

includes basic smoke mana gement program elements

an d emissions reduction t echniques tha t can be used

by land managers to minimize air quality impacts

from fire. These program elements and emissions

reduction techniques are fully documented in the

Smoke Management G ui de for Prescribed and Wi ld-land F i re: 2001 Edition (H a rdy a nd others 2001).

B r iefly , the BACM guidance notes tha t t here are

two basic approaches to minimizing the impact of

prescribed fire on air qua lity : reducing t he a mount of

pollutants emitted, or reducing the impact of the

pollutants emitted on sensitive locations or regional

ha ze through smoke dilution or tra nsport (redistribut-

ing emissions). Alth ough each meth od ca n be discussed


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independently, fire pra ctitioners often choose fire an d

fuels ma nipulation techniques tha t complement or are

a t least consistent wit h meteorologica l scheduling for

ma ximum smoke dispersion a nd fa vora ble plume tra ns-

port. The following emissions reduction a nd redist rib-

uting emissions techniques are a compilation of our

knowledge base, and depending on specific fire use

objectives, the project locations, time, and cost con-

stra ints ma y or may not be applicable.

Reducing Emissions

At least 24 methods w ithin six m ajor classifications

have been used to reduce emissions from prescribed

burning (Hardy and others 2001). These techniques

include methods designed to minimize emissions by

reducing th e area burned; reducing th e fuel load by

reducing t he fuel production, or fuel consum ption, or

both; scheduling burns before new fuels appear; and

increasin g combust ion efficiency. Ea ch of these meth -

ods has specific pra ctices a ssociat ed with it .

Redistributing EmissionsThese measures are commonly practiced in smoke

management programs and include burning when

dispersion is good, cooperat ing w ith oth er burners in

Table 2-2Recommended cooperation between wildland fire managers and air quality regulators, depending on air quality

protection instrument (Hardy and others 2001).

Air quality protection instrument Wildland fire managers Air quality regulators

National ambient air quality standards (NAAQS) Awarea

Leadb

Attainment status Aware Lead

State implementation plan (SIP) planning and development Involvedc

Lead

Conformity Involved Lead

Smoke management programs Partnerd

Lead

Visibility protection Involved LeadRegional planning groups Partner Lead

Natural emissions Partner Lead

Natural events action plan Partner Lead

Land use planning Lead Involved

Project NEPA documents Lead Involved

Other fire planning efforts Lead Involved

aAware: Responsibility to have a complete working knowledge of the air quality protection instrument but likely little or no involvement in its

wildland fire in ecosystems - effects of fire on air

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