Andy Ginsburg, Oregon DEQ IOC TRANSMITTAL LETTER TO THE WRAP BOARD “Recommended Policy for Categorizing Fire Emissions” November 2001 WRAP Meeting Andy Ginsburg, Oregon DEQ Co-Chair IOC Forum

IOC Transmittal Letter on the “Recommended Policy” Presented to IOC 9/5/01 in Seattle WA IOC endorsed the Policy Acknowledges the hard work of the NBTT IOC identified several areas where further clarification needed by FEJF in future policy and technical work. Presented by Pete Lahm, Darla Potter (WY DEQ & NBTT co-chair) and Carl Gossard (BLM & NBTT co-chair) Special thanks and appreciation to the hard work of Darla Potter and Carl Gossard. There was much discussion by the IOC of the fire definitions in the Recommended Policy. While IOC endorsed thePolicy, there were several areas where further clarification is needed by the FEJF in future fire related policy and technical work.

Areas where further clarification needed by FEJF 1. Distinction between “managed” and “controlled” fire. 2. Distinction between ecosystem “maintenance” and ecosystem “restoration”. 3. Coordination and consistency between states. 4. Alternate approach needed to “data flagging”. 1. Managed vs. Controlled fire. The Policy says “all fire, regardless of whether it’s natural or man-made (anthropogenic), must be managed (pg.10). Later (pg.11) it says all anthro fire must be controlled. Is there a distinction between there two? If so clarify in future FEJF work. 2. Maintenance vs. Restoration. Policy says PF used to maintain an ecosystem shall be classified as “natural”(pg.13) This is where PF is being used basically to mimic wildfire. Major increases in Understory Burning are now being planned in the WEST - it is unclear under the Policy if Understory Burning would be considered “maintenance” or “restoration”. 3. Policy says the “classification decision” is a local determination made by the land manager, with some coordination with states and tribes. The FEJF should identify ways to ensure that there is close coordination, so that these decisions are made in a consistent manner in the West. 4. Policy recommends (Appendix B) a special workgroup to study flagging “natural impacts” from fire - IOC supports finding alternative approach to traditional flagging of data, and suggests developing a regional monitoring protocol that will reasonably identify natural impacts.

Areas where further clarification needed by FEJF 5. Address tribal concerns about adding “cultural resources” to decision process. 6. Develop recommendations for “non- mandatory” Class I Areas. 7. Develop recommendations for establishing annual emission goals for fire. 8. Provide clear steps for incorporating Policy management elements into fire programs. 5. The Policy lists factors that should be considered in decisions re: use of PF or alternatives - “cultural resources” (tribal lands) should be added to the list. This consideration should be refected in other FEJF work, such as in smoke management program development. 6. FEJF should consider developing recommendations on how to provide visibility protection for “non-mandatory” Class I areas - those Class I areas not originally designated by Congress. Non-mandatory Class I areas are not covered under the RHR. There are only a few of these areas in the country, mostly on tribal lands. 7. 309 requires “annual emission goals” for PF, except WF. Even though the Policy defines ecosystem maintenance burning as natural, it should still be subject to this requirement. Also, annual emission goals should be set out to 2064, rather than just 2018, as required under 309. 8. The Policy’s Classification Program Management elements (pg. 9) describe how all fire is to managed. Future FEJF policy and technical work need to provide clear steps for incorporating these elements into state and tribal programs.