VISIBILITY VISIBILITY SIPSSIPSThe Regional Haze RuleThe Regional Haze Rule

Requirements for FireRequirements for Fire

The Role of the RPOsThe Role of the RPOsOpportunities for ParticipationOpportunities for Participation

US FISH AND WILDLIFE SERVICEDennis Haddow

Regional Haze RuleRegional Haze Rule July 1, 1999, EPA promulgated rules July 1, 1999, EPA promulgated rules

for the Regional Haze Regulationsfor the Regional Haze Regulations Rules are designed to address the Rules are designed to address the

National Visibility Goal National Visibility Goal § 169A of the Clean Air Act sets as a § 169A of the Clean Air Act sets as a

national goal “national goal “the prevention of any future, the prevention of any future, and remedying of any existing impairment of and remedying of any existing impairment of visibility, in mandatory class I areas which visibility, in mandatory class I areas which impairment results from manmade air impairment results from manmade air pollution.”pollution.”

Types of Mandatory Federal Types of Mandatory Federal Class I AreasClass I Areas

Wilderness, National Wildlife RefugesWilderness, National Wildlife Refuges– Fish And Wildlife Service, Dept. of the InteriorFish And Wildlife Service, Dept. of the Interior

National Parks and National Memorial ParksNational Parks and National Memorial Parks– National Park Service, Dept. of the InteriorNational Park Service, Dept. of the Interior

Wilderness, National Forests Wilderness, National Forests – U.S. Forest Service, Dept. of Agriculture U.S. Forest Service, Dept. of Agriculture

FLM CONCERNSFLM CONCERNS Visibility impairment due to regional haze affects Visibility impairment due to regional haze affects

all Wilderness Areas, and National Parks in the all Wilderness Areas, and National Parks in the lower 48 States.lower 48 States.

Every year 280,000,000 visitors go to our nation’s Every year 280,000,000 visitors go to our nation’s most treasured parks and wilderness areas.most treasured parks and wilderness areas.

Visitors rank visibility and clear scenic vistas Visitors rank visibility and clear scenic vistas (viewing the air through “clean, fresh air” as one of (viewing the air through “clean, fresh air” as one of the most important aspects of their experience.the most important aspects of their experience.

FLM CONCERNSFLM CONCERNS Haze obscures the clarity, color, texture, Haze obscures the clarity, color, texture,

and form of what we see.and form of what we see. The contaminants that obscure the vistas The contaminants that obscure the vistas

may also be harmful to humans, plants, may also be harmful to humans, plants, animals, and the ecosystem.animals, and the ecosystem.

The need to merge the management of the The need to merge the management of the ecosystem (role of fire) ecosystem (role of fire) and goal of improving visibility.improving visibility.

1980 Visibility Requirements1980 Visibility RequirementsRegulations addressed visibility Regulations addressed visibility impairment “reasonably attributable” to a impairment “reasonably attributable” to a specific source or sources.specific source or sources.Examples: Craig and Hayden Examples: Craig and Hayden Generating Stations impact on the Mt. Generating Stations impact on the Mt. Zirkel Wilderness; Navajo Generating Zirkel Wilderness; Navajo Generating Station impact on Grand Canyon Station impact on Grand Canyon National Park; Centralia Power Plant National Park; Centralia Power Plant impact on Mt. Rainier and Alpine Lakes.impact on Mt. Rainier and Alpine Lakes.

Regulatory Requirements of Regulatory Requirements of Regional Haze RuleRegional Haze Rule

Five multi-state regional planning organizations Five multi-state regional planning organizations (RPO’s) to develop the technical basis for visibility (RPO’s) to develop the technical basis for visibility protection plans.protection plans.

Develop analyses to set reasonable progress goals.Develop analyses to set reasonable progress goals. The Goal is to reach natural background conditions The Goal is to reach natural background conditions

in 60 years.in 60 years. The Goals for each affected Class I AreaThe Goals for each affected Class I Area

– Improve visibility on the 20 % haziest daysImprove visibility on the 20 % haziest days– Ensure no degradation occurs on the clearest Ensure no degradation occurs on the clearest

days.days.

Coarse Mass Nitrate Organics Sulfate Soil Soot (LAC) Day Missing

Okefenokee NWR : 1998 Mean of 20% Worst Days = 146.1 Mm-1

Ext

inct

ion

(Mm

-1)

050

100150200250300350

01/14 02/07 05/23 06/10 06/27 07/08 08/12 08/26 08/29 09/12 09/23 10/03 10/10 10/14 10/28 10/31 11/14 11/18

Okefenokee NWR : 1999 Mean = 155.3 Mm-1

Ext

inct

ion

(Mm

-1)

050

100150200250300350

02/10 03/31 04/24 05/22 05/26 06/05 06/19 06/23 07/24 07/28 07/31 08/04 08/11 08/14 09/11 09/25

Okefenokee NWR : 2000 Mean = 148.7 Mm-1

Ext

inct

ion

(Mm

-1)

050

100150200250300350

02/09 04/01 04/26 04/29 05/03 05/06 06/03 06/07 07/01 07/05 07/08 07/15 07/19 08/12 08/16 08/19 10/15 10/18 11/05 11/08 12/11

Reconstructed Extinction of 20% Worst Days (Nitrogen Adjusted)

OL

C

C

C

Regulatory RequirementsRegulatory Requirements Must develop long term strategies with Must develop long term strategies with

enforceable measures. enforceable measures. First long-term strategy will cover 10-15 years. First long-term strategy will cover 10-15 years.

Due in the 2003-2008 timeframe.Due in the 2003-2008 timeframe. Reassessment and revision of those strategies will Reassessment and revision of those strategies will

be done in 2018. And every ten years thereafter.be done in 2018. And every ten years thereafter. Strategies need to address State’s and Tribe’s Strategies need to address State’s and Tribe’s

contributions to Class I Areas within and outside contributions to Class I Areas within and outside the State.the State.

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

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

64 FR 51.308 (d)(3)(v) - 64 FR 51.308 (d)(3)(v) - The The State must consider, at a minimum the State must consider, at a minimum the

following factorsfollowing factors in developing its long-in developing its long-term strategy:term strategy:

(E) - Smoke management techniques for (E) - Smoke management techniques for agricultural and forestry management agricultural and forestry management purposes including plans as currently occur purposes including plans as currently occur within the State for these purposes.within the State for these purposes.

(G) - The anticipated net effect on visibility (G) - The anticipated net effect on visibility due to projected changes in point, due to projected changes in point, area,area, and and mobile source emissions over the period mobile source emissions over the period addressed by the long-term strategy.addressed by the long-term strategy.

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

requirements.requirements.

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

64 FR 51.308 (g)(4)64 FR 51.308 (g)(4) - - An analysis An analysis tracking the change over the past 5 tracking the change over the past 5

years in emissions of pollutants years in emissions of pollutants contributing to visibility impairment contributing to visibility impairment

from all sources and activities within from all sources and activities within the Statethe State..

Emission changes should be Emission changes should be identified by the source or activity.identified by the source or activity.

Western ProvisionsWestern Provisions

NineNine western States may implement the western States may implement the Grand Canyon Visibility Transport Grand Canyon Visibility Transport Commission plan if adopted by 2003Commission plan if adopted by 2003– This will satisfy the RHR until 2018This will satisfy the RHR until 2018– AZ and UT likely to opt inAZ and UT likely to opt in– CA, CO and NV are following the national ruleCA, CO and NV are following the national rule– remaining states still weighing the optionremaining states still weighing the option

Recent Court DecisionsRecent Court Decisions

The Court upheld the basic provisions of The Court upheld the basic provisions of returning to natural conditions over time.returning to natural conditions over time.

The Court vacated EPA’s group applicability The Court vacated EPA’s group applicability and assessment approach to BART.and assessment approach to BART.– EPA has asked for full court reviewEPA has asked for full court review– EPA is developing options to define source EPA is developing options to define source

applicability and assessment procedures.applicability and assessment procedures.

Linkage to other ProvisionsLinkage to other Provisions

New Source ReviewNew Source Review– Non-degradation of clear days is tied to Non-degradation of clear days is tied to

NSR/PSD permit reviewsNSR/PSD permit reviews

Acid Rain / (New Multi Pollutant Bills)Acid Rain / (New Multi Pollutant Bills)– Regional reductions of SO2 and NOX are Regional reductions of SO2 and NOX are

neededneeded

Other Benefits of the Regional Other Benefits of the Regional Haze RuleHaze Rule

Improving visibility will reduce contaminants that have Improving visibility will reduce contaminants that have been linked to serious health and environmental been linked to serious health and environmental effects.effects.

Reduction of small particles associated with Reduction of small particles associated with increased respiratory illness, damage to lung tissue, increased respiratory illness, damage to lung tissue, and premature death.and premature death.

Reduction of sulfates and nitrates that contribute to Reduction of sulfates and nitrates that contribute to the formation of acid deposition.the formation of acid deposition.

Reduction of pollutants that contribute to ground-level Reduction of pollutants that contribute to ground-level ozone.ozone.

FLM RoleFLM Role Federal Land Managers look at this as an Federal Land Managers look at this as an

opportunity to support and contribute to the efforts opportunity to support and contribute to the efforts of the States and Tribes to reduce emissions and of the States and Tribes to reduce emissions and improve visibility and the overall health of the improve visibility and the overall health of the ecosystems in Class I Areas.ecosystems in Class I Areas.

The Regional Haze Rule allows us as FLMs to The Regional Haze Rule allows us as FLMs to help influence protection of future visibility and air help influence protection of future visibility and air quality related values in Class I Areas.quality related values in Class I Areas.

FLM RoleFLM Role Work with States, Tribes, and Federal Work with States, Tribes, and Federal

agencies to improve visibility in Wilderness agencies to improve visibility in Wilderness Areas, and National Parks.Areas, and National Parks.

Help to develop and implement air quality Help to develop and implement air quality protection plans (regulations and SIPs) to protection plans (regulations and SIPs) to reduce pollutants causing visibility reduce pollutants causing visibility impairment.impairment.

Provide policy and technical support.Provide policy and technical support. Provide data from IMPROVE monitors.Provide data from IMPROVE monitors.

FLM ROLEFLM ROLE

Provide information on the role of fire in the Provide information on the role of fire in the ecosystems we manage and the fuel ecosystems we manage and the fuel management challenges we face.management challenges we face.

Provide information on the techniques we Provide information on the techniques we have available to minimize the amount have available to minimize the amount and/or impact of smoke we produce.and/or impact of smoke we produce.

Provide information on the amount and Provide information on the amount and visibility impact of the smoke we produce.visibility impact of the smoke we produce.

FLM ROLEFLM ROLE

Working with the RPOs requires a Working with the RPOs requires a significant amount of work and expertise.significant amount of work and expertise.

Neither the Fire or Air Programs have all the Neither the Fire or Air Programs have all the time and expertise needed.time and expertise needed.

It is absolutely critical that the programs It is absolutely critical that the programs work together to ensure that visibility is work together to ensure that visibility is protected and our fire dependent protected and our fire dependent ecosystems are appropriately managed.ecosystems are appropriately managed.

Benefit to FLMs for working Benefit to FLMs for working with RPOswith RPOs

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

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

Need for FLM CoordinationNeed for FLM Coordination

Need to stay credible. Credibility is our Need to stay credible. Credibility is our most important tool in working with the most important tool in working with the RPOs.RPOs.

The Department of Interior has formed a The Department of Interior has formed a “Fire/Air Issues Coordination Group”.“Fire/Air Issues Coordination Group”.

The Wildfire Leadership Council has The Wildfire Leadership Council has requested the development of a similar requested the development of a similar group that includes the Forest Service.group that includes the Forest Service.