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VISIBILITY SIPS. The Regional Haze Rule Requirements for Fire The Role of the RPOs Opportunities for Participation. US FISH AND WILDLIFE SERVICE Dennis Haddow. Regional Haze Rule. July 1, 1999, EPA promulgated rules for the Regional Haze Regulations

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visibility sips


The Regional Haze Rule

Requirements for Fire

The Role of the RPOs

Opportunities for Participation


regional haze rule
Regional Haze Rule
  • July 1, 1999, EPA promulgated rules for the Regional Haze Regulations
  • Rules are designed to address the National Visibility Goal
  • § 169A of the Clean Air Act sets as a national goal “the prevention of any future, and remedying of any existing impairment of visibility, in mandatory class I areas which impairment results from manmade air pollution.”
types of mandatory federal class i areas
Types of Mandatory Federal Class I Areas
  • Wilderness, National Wildlife Refuges
    • Fish And Wildlife Service, Dept. of the Interior
  • National Parks and National Memorial Parks
    • National Park Service, Dept. of the Interior
  • Wilderness, National Forests
    • U.S. Forest Service, Dept. of Agriculture
flm concerns
  • Visibility impairment due to regional haze affects all Wilderness Areas, and National Parks in the lower 48 States.
  • Every year 280,000,000 visitors go to our nation’s most treasured parks and wilderness areas.
  • Visitors rank visibility and clear scenic vistas (viewing the air through “clean, fresh air” as one of the most important aspects of their experience.
flm concerns1
  • Haze obscures the clarity, color, texture, and form of what we see.
  • The contaminants that obscure the vistas may also be harmful to humans, plants, animals, and the ecosystem.
  • The need to merge the management of the ecosystem (role of fire) and goal of improving visibility.
1980 visibility requirements

1980 Visibility Requirements

Regulations addressed visibility impairment “reasonably attributable” to a specific source or sources.

Examples: Craig and Hayden Generating Stations impact on the Mt. Zirkel Wilderness; Navajo Generating Station impact on Grand Canyon National Park; Centralia Power Plant impact on Mt. Rainier and Alpine Lakes.

regulatory requirements of regional haze rule
Regulatory Requirements of Regional Haze Rule
  • Five multi-state regional planning organizations (RPO’s) to develop the technical basis for visibility protection plans.
  • Develop analyses to set reasonable progress goals.
  • The Goal is to reach natural background conditions in 60 years.
  • The Goals for each affected Class I Area
    • Improve visibility on the 20 % haziest days
    • Ensure no degradation occurs on the clearest days.
regulatory requirements
Regulatory Requirements
  • Must develop long term strategies with enforceable measures.
  • First long-term strategy will cover 10-15 years. Due in the 2003-2008 timeframe.
  • Reassessment and revision of those strategies will be done in 2018. And every ten years thereafter.
  • Strategies need to address State’s and Tribe’s contributions to Class I Areas within and outside the State.

64 FR 51.308 (d)(3)(iv)

  • The State must identify all anthropogenic sources of visibility impairment considered by the State in developing its long-term strategy. The State should consider major and minor stationary sources, mobile sources, and area sources.

64 FR 51.308 (d)(3)(v) - The State must consider, at a minimum the following factorsin developing its long-term strategy:

  • (E) - Smoke management techniques for agricultural and forestry management purposes including plans as currently occur within the State for these purposes.
  • (G) - The anticipated net effect on visibility due to projected changes in point, area, and mobile source emissions over the period addressed by the long-term strategy.

64 FR 51.308 (d)(4) - Monitoring strategy and other implementation plan requirements.

  • (v) - A statewide inventory of emissions of pollutants that are reasonably anticipated to cause or contribute to visibility impairment in any mandatory Class I Federal Area.

64 FR 51.308 (g)(4) - An analysis tracking the change over the past 5 years in emissions of pollutants contributing to visibility impairment from all sources and activities within the State.

  • Emission changes should be identified by the source or activity.
western provisions
Western Provisions
  • Nine western States may implement the Grand Canyon Visibility Transport Commission plan if adopted by 2003
    • This will satisfy the RHR until 2018
    • AZ and UT likely to opt in
    • CA, CO and NV are following the national rule
    • remaining states still weighing the option
recent court decisions
Recent Court Decisions
  • The Court upheld the basic provisions of returning to natural conditions over time.
  • The Court vacated EPA’s group applicability and assessment approach to BART.
    • EPA has asked for full court review
    • EPA is developing options to define source applicability and assessment procedures.
linkage to other provisions
Linkage to other Provisions
  • New Source Review
    • Non-degradation of clear days is tied to NSR/PSD permit reviews
  • Acid Rain / (New Multi Pollutant Bills)
    • Regional reductions of SO2 and NOX are needed
other benefits of the regional haze rule
Other Benefits of the Regional Haze Rule
  • Improving visibility will reduce contaminants that have been linked to serious health and environmental effects.
  • Reduction of small particles associated with increased respiratory illness, damage to lung tissue, and premature death.
  • Reduction of sulfates and nitrates that contribute to the formation of acid deposition.
  • Reduction of pollutants that contribute to ground-level ozone.
flm role
FLM Role
  • Federal Land Managers look at this as an opportunity to support and contribute to the efforts of the States and Tribes to reduce emissions and improve visibility and the overall health of the ecosystems in Class I Areas.
  • The Regional Haze Rule allows us as FLMs to help influence protection of future visibility and air quality related values in Class I Areas.
flm role1
FLM Role
  • Work with States, Tribes, and Federal agencies to improve visibility in Wilderness Areas, and National Parks.
  • Help to develop and implement air quality protection plans (regulations and SIPs) to reduce pollutants causing visibility impairment.
  • Provide policy and technical support.
  • Provide data from IMPROVE monitors.
flm role2
  • Provide information on the role of fire in the ecosystems we manage and the fuel management challenges we face.
  • Provide information on the techniques we have available to minimize the amount and/or impact of smoke we produce.
  • Provide information on the amount and visibility impact of the smoke we produce.
flm role3
  • Working with the RPOs requires a significant amount of work and expertise.
  • Neither the Fire or Air Programs have all the time and expertise needed.
  • It is absolutely critical that the programs work together to ensure that visibility is protected and our fire dependent ecosystems are appropriately managed.
benefit to flms for working with rpos

Benefit to FLMs for working with RPOs

He who writes the rules determines how the game is played.

If we lead we have a much better chance of ending up where we want to go.

need for flm coordination
Need for FLM Coordination
  • Need to stay credible. Credibility is our most important tool in working with the RPOs.
  • The Department of Interior has formed a “Fire/Air Issues Coordination Group”.
  • The Wildfire Leadership Council has requested the development of a similar group that includes the Forest Service.