Well before the first sparks erupted in the '99 western fire season, a firestorm was brewing over proposed changes to air quality regulations. Three fronts caught my eye because of their implications to prescribed fire programs: one on the national political horizon, one in California, and one provoked by scientific debate with implications for ecosystems throughout the West.
This bill was authored by Rep. James Rogan, R-Los Angeles, seemingly without involvement of the namesake agency. According to the April 2ndÝ edition of the Capitol Press of Sacramento, the bill would allow 'unlimited burning on national forest land with complete exemption from Clean Air Act requirements for ten years.' Cal/EPA and the California Air Resources Board (CARB) expressed serious concern that such burning would be done without coordination with local air quality boards. Jim Spagnole of Cal/EPA was quoted in the Press as saying HR 236 would render moot the efforts of at least two collaborative groups: the Interagency Air and Smoke Council and the Grand Canyon Visibility Commission.
The IASC was established to provide a forum for air regulators, land managers, and fire managers to get together and talk about air quality and smoke management issues in California.Ý Their mission is to provide opportunities for informal communication, and education needed to develop workable fire management, land management, and air quality strategies.
The Grand Canyon Commission's purpose is to deal with pollution that blows out of California and other states into the Canyon, impacting visibility. This effort has spawned the Western Regional Partnership, an interstate, interregional commission of western eight states, which does not include California or Nevada so far.
HR 236 has been in committee for months, while the controversy plays big in the California's media as an ad hoc coalition of rural county governments, private landowners and the timber industry voices its understandable concern. They feel that burn targets on public land would nullify their plans to burn on private land, including cleanup of stubble fields and logging slash, and burning for forest health.
In the meantime, the Forest Service and CARB have completed and entered into a memorandum of understanding (MOU) at the state level. The purpose of the MOU is for the two agencies to share decisions that promote doing prescribed fire in ways that have less impact on air quality. One of the agreements is to obtain more site-specific meteorological data to refine project forecasting.
Similarly, in Washington and Oregon, vehicles in place for the Feds to work cooperatively with state air quality agencies. Jim Russell, the Regional Air Program Manager for both the BLM and Forest Service in the Pacific Northwest Region, feels that current smoke management plans included under Oregon and Washington's Implementation Plans are more than adequate for both meeting fuel hazard reduction and air quality goals and objectives.
Title 17 contains the agricultural and forest burning rules for all lands in the state. While the House bill simmers, this effort is on a fast track, and bringing the same issues to a rapid boil. CARB, which is drafting the revision, began holding scoping meetings in January of this year, and is asking for input. Two rounds of workshops have been conducted this spring and summer.Ý A final round of workshops will occur in mid-October.Ý The final proposed language will go to the Board for adoption in December.
Rod Hill of the North Sierra Air Quality Management District, and a vice president of the California Air Pollution Control Officer's Association (CAPCOA), noted that the revision process was triggered in 1995 when EPA began drafting the National Ambient Air Quality Standards for fine particulate matter and regional haze regulations as required by the Clean Air Act of 1990. The Act requires EPA to establish health-based national ambient air quality standards for ozone, particulate matter, CO, lead and other 'criteria pollutants'. The regional haze regulations are designed to protect Class I areas (National Parks and Wilderness Areas). In 1997, EPA promulgated a new standard for fine particulate matter which affects many combustion sources. This standard is termed the PM 2.5 standard, and applies to particulates less than 2.5 microns in diameter.
The local air quality districts are required to maintain the standards, but given the proposed significant increase in prescribed fire (as high as 4-fold increase by the Forest Service alone), the number of different players, unpredictable weather, and winds that don't respect district boundaries, air quality officials needed buy-in from affected parties to avoid the proverbial train wreck. The EPA put together a FACA committee‹one that complies with the Federal Advisory Committee Act‹to come up with an 'Interim Air Quality Policy on Wildland and Prescribed Fires.' The Interim Policy calls for states and tribes to develop and implement smoke management programs (SMP). Local air districts are then expected to follow suit. Districts with certifiable SMPs are allowed three violations of the standards, provided they can show the exceedances were due to fires managed for resource benefit and that the fires were subject to a certified SMP. If there is no certified SMP, then an area becomes a federal nonattainment area after the first violation and Best Available Control Measures would be required for all future prescribed burns.Ý SMPs require that each burn project have mitigations, contingencies, and prescription conditions which are agreed to ahead of time, and adhered to during project operations.
Hill said that the Title 17 rewrite process really gained momentum after the 1996 Beaver Creek smoke intrusion incident on the Stanislas National Forest. That was caused by a controlled fire that went 'out of prescription', according to Hill, when there was a change in weather without appropriate response by project burners. The fire and accompanying inversion caused heavy smoke impacts on Sierra Nevada communities, much of the Sacramento Valley, and parts of the state of Nevada. The phone at the North Sierra AQMD office rang off the hook.
In 1998, CARB began revisiting the state burning guidelines which regulate air quality on all federal lands in the state, along with State and private lands. The revised regulations would not only become more restrictive for agriculture, but would also 'significantly impact the use of fire and prescribed fire in the future' according to the California Fuels Committee (Winter 1999 CFC Newsletter).
Hill feels that some agricultural burn programs won't need to become more restrictive, while others will, depending on location.Ý The same is true for prescribed burn programs‹some will become more restrictive; others won't need much adjustment.Ý One thing that is certain is that there will be more coordination required.Ý Title 17 will require air districts to develop a daily burn authorization system that regulates the amount, timing, and location of burn events in order to minimize the smoke impacts on smoke sensitive areas, avoid cumulative smoke impacts, and prevent public nuisance.Ý Therefore, if there is a significant increase in prescribed burning (and smoke) then this added smoke could effectively reduce the amount of agricultural burning allowed.
The Landowners Association of California and the California Foresters Association are both critical of any relaxation of requirements on public, land like HR 236. They point out that land management agencies' fire suppression policies of the past resulted in nearly 100 years' worth of forest fuels buildup. They note that this accumulation has caused more intensive wildfires over larger areas than there would otherwise have been. The solution they propose is to thin the forest first, utilizing timber for 'social benefits'. Following harvest, prescribed fire can be conducted in low moisture conditions which produce less air pollution than would fall or spring burning. Some industry representatives feel that the more intensively managed private timberlands should be up first in the queue for allocated emissions, since they would produce less particulates per acre. In the case of biomass burning, some of the forest 'waste' can be utilized to capture energy while emissions are controlled via smokestack burning. Bill Keye of Wheelabrator Shasta Energy Company, a major biomass consumer in California, fears that any increase in burn targets on federal land will divert efforts away from mechanical solutions to managing fuels. Meanwhile the Feds could dominate the already limited number of burn days.
While the National and State Parks cannot utilize timber harvest to accomplish vegetation management goals, state and national forests and the BLM can and do, but on an ever-shrinking number of acres. Public forest managers use prescribed fire after harvest, as on private land, and also where mechanical treatment is incompatible with management zone objectives. And sometimes fire must be used to reduce fuel loading prior to harvest to get background fuel loading to the point where the additional logging slash can be safely treated. This does not even get into other resource management objectives for burning, such as silvicultural improvement or restoration of native habitats.
Environmental groups are openly distrustful of both private and public foresters. For example, the Sierra Club has come out in support of an end to logging on national forests. This was articulated by Bruce Hamilton in a September edition of Plain Dealer, an Ohio newspaper: 'Rather than promote an activity (logging) it knows is unpopular, the timber industry now cleverly claims that it is logging for the forest's own good. This doesn't even pass the laugh test.' He goes on to blame the Forest Service for logging's effect on fuel accumulation and microclimate, then notes that 'the club supports prescribed burning, where necessary, as a means of fire management, like the National Park Service has been doing for many years.'
A couple of different fire ecology studies are relevant to the arena of air quality and fire management. One has to do with the effect of prescribed burning on wildfire size, and the other with its effect on smoke. The first of these was conducted by Jon E. Keeley of the USGS and associates C.J.Fotherington and Marco Moriasformer, whose results were published in the June 11 issue of Science. They examined a database of California shrub fires since 1910, and concluded that in chaparral ecosystems, large fires occur regardless of the age of the fuels, and that over this period there has been no significant change in the rate of large shrub fires in spite of fuel treatment efforts. Keeley argues that the major factor in the propagation of big fires is the weather, particularly the wind (especially Santa Ana's), rather than the age of vegetation. Therefore prescribed fire should be used mainly around homes. Critics in the field of fire science say that the study based its conclusions on inadequate scientific and historical data. But with all the media coverage following the Science article release, experts do agree that the debate highlights a need for better understanding of how fires behave.
The second study, just now underway in Oregon is the development of a Fire Effects Tradeoff Model, or FETM. The study will test the hypothesis that smoke from wildfires is more harmful than that of prescribed fire, acre per acre. Many fire scientists have long believed this to be true, and the smoke from the 1999 wildfire season was rather convincing. But it hasn't been until Ken Snell of the Forest Service's Pacific Northwest Region (formerly the Regional Air Program Manager for the Forest Service and BLM in Portland) proposed this study to the Joint Fire Sciences Program Board that a controlled study has been implemented. The purpose of this board, now two years old, is to decide on whether to fund proposed studies. FETM, one of the first projects approved, will build a model to enable the user to compare emissions tradeoffs. A contract has been let and the initial data has been collected. Model outputs should be useful for planning on a regional or landscape scale.
Results of this study will not be ready in time to influence the course ofÝ Title 17, but they could help guide future land management policy. Watch for research progress on the Forest Service's Region 6 webpage. And keep an eye out in the news for the outcome of legislation like HR 236 and other tinkering with the Clean Air Act while that law is buffeted about in the courts.
Land managers from all persuasions are watching the air quality theater. The upcoming annual meeting of the California Pest Management Council includes a day-long symposium on air quality covering new regulations, and smoke management considerations for pest management. If you wish to provide input to the Title 17 re-regulation, the CARB scoping workshops will be over by the time you read this. However, there will be formal hearings and written comments accepted on the proposed regulations once they are out, in preparation for a decision by the Board, probably in December. For the schedule, go to their website, www.arb.ca.gov, and click on 'what's new', then select 'smoke management program'. This site has tons of information, including a full draft of the current Title 17 language. Contact Bill Wilson of CARB (916) 324-9747, wwilson@arb.ca.gov for further information on Title 17.-
