Update on Smoke and Air Quality Issues

Kara Paintner – March 2008

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

Ways that Smoke is Regulated

•Nuisance

•Visibility – Regional Haze Rule

•Health – National Ambient Air Quality Standards (NAAQS)

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

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

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).

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

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

Will you have the information requested up to 3 years after a prescribed fire?

Fire Management PlanBurn PlanPostfire documentation

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

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.

Interim Policy is currently being revised by EPA

Phone call with Federal Land Managers – Dec 6

Draft Final – February 2008

Final – July 2008

Will include agricultural burning, will not overlap with Exceptional Events Rule

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.

Air Quality Index(AQI) Values

Levels of Health Concern

Colors

When the AQIis in this range:

...air quality conditions are:

...as symbolized by this color:

0 to 50 Good Green

51 to 100 Moderate Yellow

101 to 150 Unhealthy for Sensitive Groups

Orange

151 to 200 Unhealthy Red

201 to 300 Very Unhealthy Purple

301 to 500 Hazardous Maroon

EPA’s PM Standards: Old and New

1997 Standards 2006 Standards

Annual 24-hour Annual 24-hour

PM2.5

(Fine Particles)

15 µg/m3

Annual arithmetic mean, averaged over 3 years

65 µg/m3

24- hour average, 98th percentile, averaged over 3 years

15 µg/m3

Annual arithmetic mean, averaged over 3 years

35 µg/m3

24- hour average, 98th percentile, averaged over 3 years

PM10

(Coarse Particles)

50 µg/m3

Annual average

150 µg/m3

24-hr average,

not to be exceeded more than once per year on average over a three year period

Revoked 150 µg/m3

24-hr average,

not to be exceeded more than once per year on average over a three year period

Air Quality Index (AQI)

Category Index Values Current PM2.5 Levels(ug/m3, 24-hr average)

PM2.5 LevelsUnder Consideration(ug/m3, 24-hr average)

Good 0 - 50 0.0 - 15.4 0.0 - 15.4

Moderate 51 - 100 15.5 - 40.4 15.5 - 35.4

Unhealthy for Sensitive Groups 101 - 150 40.5 - 65.4 35.5 - 55.4

Unhealthy 150 - 200 65.5 - 150.4 55.5 - 140.4

Very Unhealthy 201 - 300 150.5 - 250.4 140.5 - 210.4

Hazardous 301 - 400 250.5 - 350.4 210.5 - 280.4

401 - 500 350.5 - 500.4 280.5 - 350

Air Quality Index

Categories Index Values

Good 0 – 50

Moderate 51 – 100

Unhealthy for Sensitive Groups

101 – 150

Unhealthy 151 – 200

Very Unhealthy 201 – 300

Hazardous 301 – 400

401 – 500

Emergency Episode Plans

Alert Level

Warning Level

Emergency Level

Significant Harm Level (SHL)

Upper End of AQI Range

Differences in AQI Categories between Current and Possible AQI

October 2003-October 2006

Values reflect total number of daysover three year period

Possible AQI

CurrentAQI

Due to fires

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.

• 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.

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

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

National Strategy for Fire Involvement in Smoke Management Regulation

• 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

1. State

2. EPA Region as needed

3. Regional Planning Organization as needed

How would cadres work?

Cadres needed

• Georgia

• Mississippi

• Texas

• Missouri

• Alabama

• Louisiana

• Tennessee

• South Dakota

• Oklahoma

• Kansas

• Michigan

Coordinate and CollaborateStates with Existing Groups

• California• Utah• New Mexico• Florida• Oregon• Alaska• Arkansas• North Carolina

• Colorado• Washington• Arizona• Minnesota• South Carolina• Montana• Idaho• Wyoming

Monitor for Change

• North Dakota

• Hawaii

• Indiana

• Kentucky

• West Virginia

• Virginia

• Iowa

• Wisconsin

• Nebraska

• Maryland

• Illinois

• Nevada

• 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

What would FACT do?

• 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?

Pros and Cons

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

Smoke Management Programs that have been made in a stakeholder process are best

Difficult to change SMP’s

Relationships are important

Why do this….

Questions?

Christie Neill – NPS fire lead on smoke related issues for CA

kara_paintner@

nps.gov

970-267-2121