Fire Emissions Joint Forum: Section 309 Requirements Continued…

Fire Emissions Joint Forum: Section 309 Requirements Continued… -Enhanced Smoke Management Programs -Annual Emission Goals for Fire -Fire Tracking Systems -Unfinished Business

FEJF Recognition • ESMP • Mike Ziolko – OR DF • Ann Acheson – USFS • AEG • Frances Bernards – UT DAQ • FTS • Darla Potter – WY DEQ • Facilitation–Rebecca Reynolds INC. • The Forum and Outer Circle

WRAPEnhanced Smoke Management Programs for Visibility Policy -Policy Statements Approved by Conference Call -WRAP Action: ESMP Full Policy Document

ESMP Policy Policy Statement Modifications • Some minor modifications were made to two of the Policy Statements in response to comments received since the last WRAP meeting

ESMP Policy Statement A • New Text: • Enhanced smoke management programs under this Policy are defined as those smoke management efforts that specifically address visibility effects,and therefore, may need to be augmented to address public health and welfare issues. • Previous Text: • Enhanced smoke management programs are defined as smoke management efforts that specifically address visibility effects.

Policy Statement A • Rationale for Change: • Concern that efforts to address NAAQS/nuisance in current smoke management programs might be undermined by the Policy if enhanced smoke management program for visibility is interpreted as visibility concerns taking priority over other air quality considerations

Policy Statement D • New Text: • Enhanced smoke management programs are a viable tool forall otherstates and tribes inthe WRAP regionto use in the development of their implementation plans. • Previous Text: • Enhanced smoke management programs are a viable tool for states under Section 308 to use in their SIP development, and for tribes to use in their TIP development.

Policy Statement D • Rationale for Change: • The viability of the enhanced smoke management program as a tool to use in managing smoke impacts on visibility exists for all states and tribes in the WRAP region, regardless of whether they are under Section 308 or not.

ESMP Text and Report • Text Revisions Address: • IOC and TOC comments • Directed Reviewer comments • FEJF final review comments • Documentation of Comments and Responses available on Web or Policy Documentation Package

WRAP Policy Annual Emission Goals for Fire

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 • Required for Section 309 • Control Approach for Section 308.

AEG PolicyMajor Points of Agreement • Annual Emission Goals are “goals” not “limits” • Emission Reduction Techniques (ERTs) are the basis of the Annual Emission Goal • ERTs as defined do not include Non-Burning Alternatives • SIP/TIP submittal is the Process of setting an AEG • SIP/TIP is NOT a number

Goal versus Limit • GCVTC intent: • Recommendations use “goal”, “target” and “cap” – both target and cap are defined as emissions limits (cap has regulatory consequences, target does not) • Goal is a desired future condition that may be represented by a numeric indicator (i.e., quantifiable) • RHR uses GCVTC language • Not currently possible to institute a limit (Science issues & WRAP-wide consistency question) • AEG is quantifiable, but not a limit

ERTs as Basis of AEG • “Minimize emission increases”: RHR focus is emission reduction where possible • ERTs are proven to reduce emissions • The effort to reduce emissions through the use of ERTs is what will be quantified by the AEG, rather than the result of using them • This is a practical & effective method that will work NOW • Process to address choice of 2 tons of PM2.5/acre vs. 1 ton/acre

ERTs Defined • ERTs are methods that control fire emissions; e.g., biomass utilization prior to burning, high fuel moisture, increasing combustion efficiency • Control measures (ERTs) are distinct from smoke management techniques; e.g., the timing of ignitions for better smoke dispersion • ERTs are evaluated and used on a project-specific ANNUAL basis, i.e. in areas that have been designated for the application of fire. Areas where an alternative to fire will be used, do not involve ERTs & are not part of the AEG

Policy Statement A • The establishment and implementation of annual emission goals is a viable technique to control fire emissions for WRAP states and tribes. Annual emission goals are required for states under Section 309 of the Regional Haze Rule.

Policy Statement ARationale • Section 309 requires: “establishment of annual emission goals for fire (excluding wildfire) that will minimize emission increases from fire to the maximum extent feasible.” (64 FR 35771 Section 51.309(d)(6)(v)) • Policy can be considered by non-309 states and tribes as means for controlling fire emissions as needed

Policy Statement B • Policy Statement B: Annual emission goals will achieve the minimum emission increase from fire. Annual emission goals are quantifiable values that are distinct from emission limits.

Policy Statement BRationale • GCVTC Report/RHR recognized land managers’ projection of significant increases in prescribed fire to reduce effects of wildfire • GCVTC recommended the establishment of annual emission goals to minimize emissions • A goal has a numeric measure but distinct from a limit

Policy Statement C • Policy Statement C: Annual emission goals are applied to all fire sources, excluding wildfire, due to their potential impacts on visibility.

Policy Statement CRationale • RHR/GCVTC acknowledged that all types of fire must be addressed in visibility protection strategy • RHR/GCVTC: Include all fire (except wildfire) is a practical approach to this Policy • Policy does not apply to Native American cultural non-vegetative burning

Policy Statement D • Policy Statement D: The minimum emission increase from fire is accomplished through the optimal application of emission reduction techniques, which provide the basis for annual emission goals.

Policy Statement: DRationale • Projected increase in fire activity will result in episodic impacts on visibility • AEG Policy focuses on strategy for minimizing impacts through reduction of fire emissions on project specific basis • ERTs are proven method for reducing fire emissions

Policy Statement DRationale 2 • AEG Policy applies when fire has been chosen as means to meet land management objectives • There are various ways to establish an annual emission goal based on ERTs: this Policy offers two example approaches

Policy Statement E • Policy Statement E: The use of emission reduction techniques to achieve annual emission goals is subject to economic, safety, technical and environmental feasibility criteria, and land management objectives.

Policy Statement ERationale • Per the GCVTC and WRAP Fire Categorization Policy: Recommendations, economic, safety, technical and environmental considerations are included in this AEG Policy • Land management objectives were added as criterion to ensure that ERTs are used appropriately

Policy Statement F • Policy Statement F: States, tribes or the designated authority will establish annual emission goals in cooperation with federal land management agencies and private entities on a yearly basis.

Policy Statement FRationale • “Establishment of annual emission goals for fire … that are established in cooperation with States, tribes, Federal land management agencies, and private entities.” (64 FR 35771 Section 51.309(d)(6)(v)) • Coordination is key for addressing regional haze in WRAP region

Policy Statement G • Policy Statement G: States and tribes will need to develop a procedure for verifying the use of emission reduction techniques and for tracking the achievement of annual emission goals.

Policy Statement GRationale • Tracking provides the means to achieve verification (checks & balance) • Tracking can also provide a basis for the annual review and possible revision • Basis for five year SIP review

Revisiting Annual Emission Goals • Beginning in 2008, 309 states/tribes are required by RHR to submit periodic reports to EPA. Periodic reports are due every five years subsequently. • Policy encourages state/tribes to refine annual emission goal as advances in research and development are made • E.g., emission limits may be possible and needed for Further Reasonable Progress

AEG PolicyReviewer Comments • Document sent to over 100 potential reviewers including: • Website Posting, IOC, TOC, FEJF, Requested, & ESMP Reviewer List • Eight (8) Reviewers submitted comments to date • Representing: • five (5) states • one (1) industry • one (1) USFS • one (1) Western State Forestry Council • Discussion with Tribal Caucus – comments to be addressed • Comment Period Now Closed

AEG Comment: Goal Definition • Accepted Goal Definition • Asked for some strengthening language to support the intent and implementation of the AEG: AEG process is enforceable

AEG Comment: Non-Burning Alternatives • Still some confusion about the definition of non-burning alternatives (are they ERTs?) • Still some confusion as to how ERTs drive the AEG (project-specific basis) • Still some confusion as to how non-burning alternatives fit vis-à-vis all 309 products

Unfinished Business… • Section 309 – Assess and remove administrative barriers to the use of non-burning alternatives • Four WRAP Policies which may include non-burning alternatives • Agricultural Non-Burning Alternatives Report – Final • Wildlands Non-Burning Alternatives Report - Draft

Alternatives to Burning - FEJF White Paper • Address Alternatives to Burning issues in one document to assist states/tribes • Brainstorm on approaches to address assessment of administrative barriers, document FEJF efforts to date and address interaction of non-burning alternatives with WRAP Policies

Fire Emissions Joint Forum: Section 309 Requirements Continued…