Incorporating Smoke Management Plans into SIPs: THE OREGON 309 SIP

1. Smoke Management Planning Workshop WRAP 308 Planning Committee & Fire Emissions Joint Forum Portland, Oregon - June 16, 2004 Incorporating SmokeManagement Plans into SIPs:THE OREGON 309 SIP Brian Finneran Oregon Department of Environmental Quality

2. Sec. 309 Requirements for Fire • Document if PF programs address visibility in planning and application. • PF programs must have 7 Basic smoke management elements (BMP): • Actions to minimize emissions • Evaluate smoke dispersion • Promote non-burning alternatives • Public notification of burning • Air quality monitoring • Surveillance and enforcement • Program evaluation.

3. Sec. 309 Requirements for Fire • Statewide inventory & emissions tracking system. • Identify barriers to non-burning alternatives & a process to overcome these barriers. • Adopt Enhanced Smoke Management Program (ESMP). Add to BMP: 8) Burn Authorization 9) Regional Coordination • Establish Annual Emission Goals

4. Oregon Section 309Regional Haze Plan • Adopted December 6, 2003 • Submitted to EPA by 12/31/03 deadline • Oregon SIP Fire Section titles: • Prescribed Fire Program Evaluation • Emission Inventory & Tracking System • Identification and Removal of Administrative Barriers • Enhanced SMP • Annual Emission Goal

5. How much Fire did we address in our 309 SIP? • Under Sec. 309, 1st SIP addresses only the 16 Class I areas of the Colorado Plateau. 2nd SIP in 2007 to address all other Class I areas (e.g. Oregon’s). • Given long distance to the CP, our SIP addressed only larger fire sources. • Most of Oregon is identified as a Clean Air Corridor. We did not believe smaller fire sources were significant – except to make sure we track their emissions. • Greater effort will be made to address smaller fire sources in 2007 SIP.

6. How much Fire did we address in our 309 SIP? SIP addressed two largest fire sources:* • Forestry prescribed burning • Willamette Valley field burning % Fire Emissions in Oregon (PM 2.5) 1% • 69% 5% • 25% * Does not include rangeland burning and some ag burning for which ODEQ does not have reliable emission estimates.

7. Preparing the 309 SIP:What we already had in place • A mandatory SMP for prescribed fire on state and federal forest lands statewide. • A mandatory SMP for Willamette Valley field burning. • Both SMPs “advanced programs”. Meet EPA’s criteria for BACM (NAAQS protection). • We knew both SMPs would meet most of Sec. 309 requirements for Fire.

8. Preparing the 309 SIP:Work we conducted for fire • Work needed mostly to address the Annual Emission Goals requirement. • Statewide prescribed fire SMP also needed work on Alternatives to Burning. No formal mechanism in place to show how to overcome barriers. • Minor work needed to ensure fire emissions tracking consistent with the WRAP FTS Policy.

9. Oregon 309 SIP:Work we conducted for fire On Alternatives to Burning for PF: • Put in SIP commitment to follow WRAP Nonburning Alternatives To Prescribed Fire document. Still need to figure out how to incorporated it into planning process. On Annual Emission Goals: • Put in SIP commitment to follow WRAP Annual Emissions Goals for Fire Policy. Still need to figure out how to track ERTs and quantify emissions. • Will provide EPA with SIP supplement upon completion.

10. Next 309 SIP (2007):Work anticipated to address Fire • Unregulated Ag Burning – estimate emissions, then assess significance to regional haze and how to best control. • Problem: Ag burning currently exempt under state law. May have to rely on enforceable local measures (e.g., county ordinances) as alternative. • Rangeland burning – evaluate same as unregulated Ag Burning. • Determine if any improvements can be made to existing mandatory SMPs.