Update on Smoke and Air Quality Issues

1. Update on Smoke and Air Quality Issues Kara Paintner – March 2008

2. Exceptional Events Rule – use by North Carolina EPA Rule and Policy Changes related to fire Fire Air Coordination Team – who are they and what are they doing Questions

3. Ways that Smoke is Regulated • Nuisance • Visibility – Regional Haze Rule • Health – National Ambient Air Quality Standards (NAAQS)

4. Interim Policy for Air Quality from Prescribed and Wildland Fire (1998) Defines what a Smoke Management Program (SMP) ‘looks’ like Two levels – Basic and Enhanced

5. Visibility - Regional Haze Rule In 1977 Congress designated certain National Parks and Wildernesses as Class I. For these areas they declared as a national visibility goal “…the prevention of any future, and the remedying of any existing, impairment of visibility…which impairment results from manmade air pollution.” NPS, USFS and USF&W manage these lands

7. Exceptional Events Rule Section 319 of the Clean Air Act allows states to flag and exclude certain monitoring data affected by emissions from natural and exceptional events when determining attainment of the National Ambient Air Quality Standards (NAAQS).

8. EER Procedures State, Tribe or Local air regulatory agency: • Must submit air quality monitoring data to EPA within 90 days • May flag specific data as affected by exceptional event for EPA within 6 months of measurement • May submit documentation of proof of exceptional event effects to EPA within 3 years of flagging • EPA concurs or rejects proof State and EPA Processes are Discretionary

9. North Carolina example • Stonewall Prescribed Fire on March 27, 2007 Chattahoochee/Oconee National Forests • Basic information on the fire that will assist in showing the influence of prescribed fire emissions on air quality monitors • Document why prescribed burning was selected over other land management alternatives • Document the role of fire in restoring ecological processes and how prescribed fire is being used to mimic natural fire regimes • Document the Smoke Management Practices that were followed for the prescribed fire. • The primary goal of smoke management is to protect public health and safety, and your smoke management practices should demonstrate this

10. Will you have the information requested up to 3 years after a prescribed fire? Fire Management Plan Burn Plan Postfire documentation

11. EPA Rule and Policy Changes Revision of Interim Policy - July 2008 Air Quality Index – any day now Emergency Episode Rule – April 2008 Revision of Ozone NAAQS – March 2008 Streamlining of General Conformity – Fall 2008

12. Interim Policy for Air Quality from Prescribed and Wildland Fire (1998) Air quality and visibility impacts from fires managed for resource benefits should be treated equitably with other source impacts.

13. Interim Policy is currently being revised by EPA Phone call with Federal Land Managers – Dec 6Draft Final – February 2008Final – July 2008Will include agricultural burning, will not overlap with Exceptional Events Rule

14. Air Quality Index - AQI • http://www.airnow.gov/ • An index for reporting daily air quality. • Focuses on health effects experienced within a few hours or days after breathing polluted air. • EPA calculates the AQI for five major air pollutants regulated by the Clean Air Act: ground-level ozone, particle pollution (also known as particulate matter), carbon monoxide, sulfur dioxide, and nitrogen dioxide.

15. EPA’s PM Standards: Old and New

17. Upper End of AQI Range Emergency Episode Plans Alert Level Warning Level Emergency Level Significant Harm Level (SHL)

18. Differences in AQI Categories between Current and Possible AQI Possible AQI Current AQI October 2003-October 2006 Values reflect total number of days over three year period

19. Due to fires

22. What Is General Conformity? The intent of the General Conformity requirement of the Clean Air Act is to insure that air quality impacts from Federal actions do not cause or contribute to a violation of the national ambient air quality standards (NAAQS) or interfere with the purpose of State (SIP), Tribal (TIP), or Federal (FIP) Implementation Plans. Only actions in designated nonattainment and maintenance areas are subject to the conformity regulations.

23. To provide coordination and collaboration between the fire and air resource management programs on fire-related air quality issues. • To facilitate a framework for collaborative approaches in addressing fire and air issues at the local, state, Tribal, and national level. • To establish consistent and cost-effective air quality planning, documentation, and emission reporting processes in implementing the National Fire Plan.

24. USFS – Anne Acheson and Pete Lahm BLM – Paul Schlobohm USF&W – Dennis Haddow and David Brownlie BIA – Ron Sherron and Mary Taber NPS – Kara Paintner and Mike George State Foresters – Darrell Johnston – WA, Gary Curcio – NC NRCS – Susan O’Neill

25. National Strategy for Fire Involvement in Smoke Management Regulation GOAL – Establish Interagency Smoke Cadres Members – BLM, BIA, USFWS, USFS – fire and air, NPS – fire and air, TNC, NRCS, State Forestry agencies, others When – ASAP due to current and looming regulatory deadlines

26. How would cadres work? • Cadres needed in many but not all states • Incorporate existing groups (CA, MT/ID, etc) • Maintain for the long-term due to science & regulatory changes • Cadres updated and supported by FACT • Cadres communicate with • State • EPA Region as needed • Regional Planning Organization as needed

27. Georgia Mississippi Texas Missouri Alabama Louisiana Tennessee South Dakota Oklahoma Kansas Michigan Cadres needed

28. California Utah New Mexico Florida Oregon Alaska Arkansas North Carolina Colorado Washington Arizona Minnesota South Carolina Montana Idaho Wyoming Coordinate and CollaborateStates with Existing Groups

29. North Dakota Hawaii Indiana Kentucky West Virginia Virginia Iowa Wisconsin Nebraska Maryland Illinois Nevada Monitor for Change

30. What would FACT do? • Develop details and process for cadre formation – April 2008 • Provide cadres with general direction, objectives and oversight • Provide policy and technical support • Provide training to cadres – one East and on West workshop – 3 days training with Monday/Friday travel – Fall 2008, Winter 2009

31. Pros and Cons • Proactive rather than reactive • Recognizes the scale a which regulations are made • Builds relationships with local regulators • More work • Is it really necessary? • What’s wrong with what we’re doing now? • Isn’t the NPS air program handling it?

32. What happens next? Training Development with University of Idaho and FACT • Online line officer training – April 2008 • In person workshops for cadre that would also becomes online training course

33. Why do this…. Smoke Management Programs that have been made in a stakeholder process are best Difficult to change SMP’s Relationships are important

34. Questions?

35. Christie Neill – NPS fire lead on smoke related issues for CA kara_paintner@ nps.gov 970-267-2121