1. Annual Emission Goals for Fire
12/7/2018
FEJF Meeting: Jackson, WY

2. FEJF Meeting: Jackson, WY
Introduction
WRAP Policy on Annual Emission Goals for Fire provides states/tribes with a tool for addressing regional haze in mandatory Federal Class I Areas.
As you know, states/tribes are directed to… by RHR
12/7/2018
FEJF Meeting: Jackson, WY

3. FEJF Meeting: Jackson, WY
Introduction
Majority of comments contained in Section 3.1, 3.3, 3.5 and Appendix C
Several comments were received on policy statements
Policy statements were approved by WRAP prior to comment period
12/7/2018
FEJF Meeting: Jackson, WY

4. FEJF Meeting: Jackson, WY
Section 3.1 Comments
Comments stated:
Policy needs to address emissions from fire sources in order to fulfill SIP/TIP requirements
Policy does not provide guidance on how to integrate into SIP/TIP
ERT(s) are a subset of Best Management Practices. An ERT is a technique that is used to reduce the amount of emissions generated, which in turn may reduce smoke impacts on air quality.BMP(s) can include burning and smoke management techniques that may reduce emissions or may reduce air quality impacts. The WRAP’s ESMP includes BMPs as well as ERTs.
This Policy focuses only on techniques that reduce the amount of emissions generated prior to or during the combustion phase. It is assumed that the piece of land will be burned to meet some specific land management objectives. Therefore, non-burning alternatives are not included as an ERT under this Policy. This Policy supports the consideration of alternatives to burning in land management and fire management plans or other equivalent plans and encourages each state/tribe to work cooperatively with land managers to identify and implement all feasible non-burning alternatives. The ESMP Policy requires land managers to evaluate the use of non-burning alternatives.
12/7/2018
FEJF Meeting: Jackson, WY

5. FEJF Meeting: Jackson, WY
Section 3.1 Revisions
Emphasizes that states have the ultimate responsibility for the implementation of AEG and fulfilling requirements of RHR
Tribes or EPA on their behalf may choose to utilize the AEG as a severable element in their plans
12/7/2018
FEJF Meeting: Jackson, WY

6. FEJF Meeting: Jackson, WY
Section 3.3 Comments
States may need to establish a backstop measure to address emissions from fire sources
12/7/2018
FEJF Meeting: Jackson, WY

7. FEJF Meeting: Jackson, WY
Section 3.3 Revisions
Section was revised to improve readability
Emphasizes that definition for “goal”, “cap”, and “target” comes from GCVTC Report
Emphasizes that Policy does not preclude the establishment of emission limits
The Policy for Categorizing Fire Emissions approved by consensus by the WRAP in November 2001 establishes the definition of anthropogenic and natural fires for the region. All anthropogenic fires as defined by Policy are subject to the Annual Emission Goals.
Wildfire under suppression is considered a natural source and therefore not covered by this AEG Policy. Although wildfires can still be managed to minimize their impacts on visibility in mandatory Federal Class I Areas.
12/7/2018
FEJF Meeting: Jackson, WY

8. FEJF Meeting: Jackson, WY
Section 3.5 Comments
Advantages of using ERTs should be emphasized
Emphasize that Policy focuses on applying ERTs on a project-specific basis
Key smoke management technique is the timing of ignitions for better smoke dispersion and consideration to downwind air quality
All of the GCVTC recommendations were included in Section 308 of the Rule in specific or by reference.
The GCVTC recommendations also state that agricultural burning emissions and their effects have been identified as a concern, but have not been quantified due to insufficient data.
The recommendations emphasized the need to utilize ERT(s) as a means to reduce the emissions from prescribed burning.
12/7/2018
FEJF Meeting: Jackson, WY

9. FEJF Meeting: Jackson, WY
Section 3.5 Comments
Policy leads readers to believe that there are only two implementation options
AAQTF issued its recommendations that supports fire to function as a tool while protecting public health and welfare by minimizing smoke impacts. The AAQTF recommendation sets up a two-tiered voluntary program, in which the first tier is based on a predetermined set of burning conditions and the second tier emphasizes minimizing air quality impacts by using tools such as ERTs.
12/7/2018
FEJF Meeting: Jackson, WY

10. FEJF Meeting: Jackson, WY
Section 3.5 Revisions
Section focuses on three issues that work collectively to form visibility protection strategy:
Annual emission goals are developed on annual basis for each year (fire activity is variable from one year to the next)
12/7/2018
FEJF Meeting: Jackson, WY

11. FEJF Meeting: Jackson, WY
Section 3.5 Revisions
Goal is based on minimizing emission increases from fire. So Policy focuses on process that will be included in implementation plans (federally approved).
AEG Policy must be practical (capable of being implemented by 12/31/03 and flexible (different needs)
12/7/2018
FEJF Meeting: Jackson, WY

12. FEJF Meeting: Jackson, WY
Section 3.5 Revisions
To address three main issues:
Policy minimizes emission increases through control of emissions
Control is accomplished by using ERTs
12/7/2018
FEJF Meeting: Jackson, WY

13. FEJF Meeting: Jackson, WY
Section 3.5 Revisions
Emphasizes purpose of smoke management techniques
Emission reductions calculated on a project-specific basis
Project-specific basis refers to projects where fire will be used to meet land manager objectives
Option 1 and 2 are not only options
Protection of visibility in mandatory Federal Class I Areas can be accomplished through the management and control of all fire emissions. Management of emissions include, but are not limited to, concepts such as the timing of ignitions for better dispersion and consideration of downwind air quality and visibility which are also BMP. Control of fire emissions is accomplished by using measures, such as the use of non-burning alternatives, biomass utilization and other EMTs.
Therefore, this Policy requires the development of a system to track the use of ERTs on a region-wide basis as a means to demonstrate the use and effectiveness of these techniques in meeting the visibility protection goals of the Rule.
12/7/2018
FEJF Meeting: Jackson, WY

14. FEJF Meeting: Jackson, WY
Section 3.5 Revisions
Clarification on non-burning alternatives:
ERTs are not non-burning alternatives (for purposes of this Policy)
Methods exist for tracking/calculating emissions averted through use of ERTs
Currently, land managers have the option of using specific ERT that are appropriate for common veg/crop types across the West as a means for meeting smoke management goals that address public health and nuisance concerns.
CA: requires use of “crackle test” to determine if fuel is dry enough to burn. If the straw makes an audible crackle when it is bent sharply, it is dry enough to burn.
OR: For prescribed fires, the Oregon Smoke Management Program requires land managers to consider utilization of residue, fuel reduction measures, alternat4e treatment practices, and reduction of prescribed burning emissions to achieve emissions reduction goals established within the Oregon Visibility Protection Plan. Burning during the spring when the 1000-hour and larger fuels have high fuel moisture is promoted.
12/7/2018
FEJF Meeting: Jackson, WY

15. FEJF Meeting: Jackson, WY
Appendix C Comments
Applicability table needs revision
Tracking of non-burning alternatives
In WA, land managers are encouraged to use ERT to meet specific emission reduction targets for prescribed fire.
12/7/2018
FEJF Meeting: Jackson, WY