WILDFIRE PM MITIGATION PLAN CARSON CITY AND … · Gardnerville Ranchos areas, and for particulate matter less than 10 micrometers in diameter (PM 10) for the Pahrump area (Figure

NEVADA DIVISION OF ENVIRONMENTAL PROTECTION

WILDFIRE PM2.5 MITIGATION PLAN

CARSON CITY AND GARDNERVILLE RANCHOS

NEVADA

FINAL Document

September 2018

State of Nevada – Wildfire PM2.5 Mitigation Plan i

TABLE OF CONTENTS

1.0 INTRODUCTION.....................................................................................................1

1.1 BACKGROUND ..................................................................................................1

1.2 MITIGATION OF EXCEPTIONAL EVENTS REQUIREMENTS ..................................3

1.3 SOURCES OF PM2.5 IN WESTERN NEVADA ........................................................6

2.0 MITIGATION PLAN COMPONENTS .................................................................8

2.1 PUBLIC NOTIFICATION AND EDUCATION ..........................................................8

2.2 MITIGATING MEASURES ..................................................................................9

2.2.1 Minimizing Controllable Contributing Sources ........................................9

2.2.2 Minimizing Public Exposure to High Concentrations ............................11

2.2.3 Monitoring Network ................................................................................11

2.2.4 Communication and Collaboration with other Air Agencies ..................11

2.3 PERIODIC REVIEW AND EVALUATION ............................................................12

3.0 PUBLIC NOTICE ...................................................................................................13

3.1 PUBLIC NOTICE DOCUMENTATION .................................................................13

3.2 PUBLIC COMMENTS AND NDEP BAQP RESPONSES ......................................13

4.0 REFERENCES ........................................................................................................14

State of Nevada – Wildfire PM2.5 Mitigation Plan ii

LIST OF FIGURES

Figure 1. Location Map for Nevada Mitigation Areas ............................................................2

Figure 2. PM2.5 Mitigation Area ..............................................................................................3

State of Nevada – Wildfire PM2.5 Mitigation Plan iii

LIST OF TABLES

Table 1. Regulatory Requirements of Mitigation Plans .........................................................4

LIST OF APPENDICES

Appendix A Sample Public Notifications

Appendix B NDEP BAQP AQI Estimator

Appendix C NDEP BAQP Smoke Management Program

Appendix D Nevada Handbook for Agricultural Open Burning

State of Nevada – Wildfire PM2.5 Mitigation Plan iv

LIST OF ACRONYMS AND ABBREVIATIONS

BAQP Bureau of Air Quality Planning

CFR Code of Federal Regulations

EER Exceptional Event Rule

NAAQS National Ambient Air Quality Standards

NDEP Nevada Division of Environmental Protection

O3 Ozone

PM2.5 Particulate Matter Smaller than 2.5 Micrometers

PM10 Particulate Matter Smaller than 10 Micrometers

SMP Smoke Management Program

USEPA United States Environmental Protection Agency

State of Nevada – Wildfire PM2.5 Mitigation Plan v

This Page Intentionally Left Blank

State of Nevada – Wildfire PM2.5 Mitigation Plan 1

PM2.5 MITIGATION PLAN

1.0 INTRODUCTION

1.1 BACKGROUND

In 2005, Section 319 of the Clean Air Act was amended by Congress in part to provide for the

treatment of data affected by exceptional events. As a result, the United States Environmental

Protection Agency (USEPA) established rulemaking for states to request that data affected by

exceptional events that result in air quality that exceeds the National Ambient Air Quality

Standards (NAAQS) be excluded from regulatory action. The 2016 revision of the Exceptional

Events Rule (EER) requires that states prepare and submit a mitigation plan for areas with

historically documented or known seasonal exceptional events. 40 Code of Federal Regulations

(CFR) 51.930 defines “historically documented or known seasonal events” as three events of the

same type and pollutant that recur in a three-year period, for which affected data has either been

flagged as having been influenced by an exceptional event, or was the subject of an initial

notification to the USEPA of a potential exceptional event (USEPA, 2016).

The Nevada Division of Environmental Protection (NDEP) Bureau of Air Quality Planning

(BAQP) is required, under 40 CFR 51.930, to develop and submit a mitigation plan for

particulate matter less than 2.5 micrometers in diameter (PM2.5) for the Carson City and

Gardnerville Ranchos areas, and for particulate matter less than 10 micrometers in diameter

(PM10) for the Pahrump area (Figure 1). The Carson City and Gardnerville Ranchos sites are

approximately 20 miles apart; for the purposes of this document, the two sites will be treated as

the same “area” for which a mitigation plan is required, and will be referred to as the PM2.5

Mitigation Area. The PM2.5 Mitigation Area encompasses Carson City and Douglas County,

Nevada (Figure 2). The mitigation plan for Pahrump will be submitted under separate cover.


Figure 1. Location Map for Nevada Mitigation Areas


Figure 2. PM2.5 Mitigation Area

1.2 MITIGATION OF EXCEPTIONAL EVENTS REQUIREMENTS

A state requesting to exclude air quality data due to exceptional events must take appropriate and

reasonable actions to protect public health from exceedances or violations of the NAAQS. At a

minimum, the state must:

Provide for the implementation of appropriate measures to protect public health from

exceedances or violations of ambient air quality standards caused by exceptional events;


Provide for public education concerning actions that individuals may take to reduce

exposures to unhealthy levels of air quality during and following an exceptional event;

and

Provide for prompt public notification whenever air quality concentrations exceed or are

expected to exceed an applicable ambient air quality standard.

In order to meet these requirements, each mitigation plan must contain provisions for the

following:

1. Public notification to and education programs for affected or potentially affected

communities. Such notification and education programs shall apply whenever air quality

concentrations exceed or are expected to exceed a NAAQS with an averaging time that is

less than or equal to 24 hours.

2. Steps to identify, study and implement mitigating measures, including approaches to

address each of the following:

a. Measures to abate or minimize contributing controllable sources of identified

pollutants.

b. Methods to minimize public exposure to high concentrations of identified

pollutants.

c. Processes to collect and maintain data pertinent to the event.

d. Mechanisms to consult with other air quality managers in the affected area

regarding the appropriate responses to abate and minimize impacts.

3. Provisions for periodic review and evaluation of the mitigation plan and its

implementation and effectiveness by the state and interested stakeholders.

Table 1 summarizes the regulatory requirements of a mitigation plan and the section of this plan

where each requirement is satisfied.

Table 1. Regulatory Requirements of Mitigation Plans

40 CFR 51.930 Mitigation of Exceptional Events

Regulatory Citation

Plan Section

Number

51.930(a)

A State requesting to exclude air quality data due to exceptional

events must take appropriate and reasonable actions to protect

public health from exceedances or violations of the NAAQS. At a

minimum, the State must:

N/A

51.930(a)(1)

Provide for prompt public notification whenever air quality

concentrations exceed or are expected to exceed an applicable

ambient air quality standard;

2.1

51.930(a)(2)

Provide for public education concerning actions that individuals

may take to reduce exposures to unhealthy levels of air quality

during and following an exceptional event;

2.1

51.930(a)(3)

Provide for the implementation of appropriate measures to protect

public health from exceedances or violations of ambient air quality

standards caused by exceptional events

2.2.2



Regulatory Citation

Plan Section

Number

51.930(b)

Development of mitigation plans for areas with historically

documented or known seasonal events N/A

51.930(b)(1)

Generally. All States having areas with historically documented or

known seasonal events shall be required to develop a mitigation

plan with the components identified in 51.930(b)(2) and submit such

plan to the Administrator according to the requirements in

51.930(b)(3).

N/A

51.930(b)(1)(i)

For purposes of the requirements set forth in 51.930, historically

documented or known seasonal events shall include those events of

the same type and pollutant that recur in a 3-year period and meet

any of the following:

N/A

51.930(b)(1)(i)(A)

Three events or event seasons for which a State submits a

demonstration under the provisions of 40 CFR 50.14 in a 3-year

period; or

N/A

51.930(b)(1)(i)(B)

Three events or event seasons that are the subject of an initial

notification of a potential exceptional event as defined in 40 CFR

50.14(c)(2) in a 3-year period regardless of whether the State

submits a demonstration under the provisions of 40 CFR 50.14.

N/A

51.930(b)(1)(ii)

The Administrator will provide written notification to States that

they are subject to the requirements in 51.930(b) when the

Administrator becomes aware of applicability.

N/A

51.930(b)(2)

Plan components. At a minimum, each mitigation plan…shall

contain provisions for the following: N/A

51.930(b)(2)(i)

Public notification to and education programs for affected or

potentially affected communities. Such notification and education

programs shall apply whenever air quality concentrations exceed or

are expected to exceed a NAAQS with an averaging time that is less

than or equal to 24-hours.

2.1

51.930(b)(2)(ii)

Steps to identify, study and implement mitigating measures,

including approaches to address each of the following: N/A

51.930(b)(2)(ii)(A)

Measures to abate or minimize contributing controllable sources of

identified pollutants. 2.2.1

51.930(b)(2)(ii)(B)

Methods to minimize public exposure to high concentrations of

identified pollutants. 2.2.2

51.930(b)(2)(ii)(C) Processes to collect and maintain data pertinent to the event. 2.2.3

51.930(b)(2)(ii)(D)

Mechanisms to consult with other air quality managers in the

affected area regarding the appropriate responses to abate and

minimize impacts.

2.2.4

51.930(b)(2)(iii)

Provisions for periodic review and evaluation of the mitigation plan

and its implementation and effectiveness by the State & interested

stakeholders.

2.3

51.930(b)(2)(iii)(A)

With the submission of the initial mitigation plan according to the

requirements in 51.930(b)(3) that contains the elements in

51.930(b)(2), the State must:

N/A

51.930(b)(2)(iii)(A)(1)

Document that a draft version of the mitigation plan was available

for public comment for a minimum of 30 days; 3.1



Regulatory Citation

Plan Section

Number

51.930(b)(2)(iii)(A)(2)

Submit the public comments received along with its mitigation plan

to the Administrator 3.2

51.930(b)(2)(iii)(A)(3)

In its submission to the Administrator, for each public comment

received, explain the changes made to the mitigation plan or explain

why the State did not make any changes to the mitigation plan

3.2

51.930(b)(2)(iii)(B)

The State shall specify in its mitigation plan the periodic review and

evaluation process that it intends to follow for reviews following the

initial review identified in 51.930(b)(2)(iii)(A).

2.3

51.930(b)(3)

Submission of mitigation plans. All States subject to the provisions

of 51.930(b) shall, after notice and opportunity for public comment

identified in 51.930(b)(2)(iii)(A), submit a mitigation plan to the

Administrator for review and verification of the plan components

identified in 51.930(b)(2).

N/A

51.930(b)(3)(i)

States shall submit their mitigation plans within 2 years of being

notified they are subject to 51.930(b). N/A

51.930(b)(3)(ii)

The Administrator shall review each mitigation plan developed

according to the requirements in paragraph (b)(2) of this section and

shall notify the submitting State upon completion of such review.

N/A

50.14(b)(9) Mitigation plans. N/A

50.14(b)(9)(i)

Except as provided for in 50.14(b)(9)(ii), where a State is subject to

the requirements of 40 CFR 51.930(b), the Administrator shall not

place a concurrence flag in the appropriate field for the data record

in the AQS database, as specified in 50.14(c)(2)(ii), if the data are of

the type and pollutant that are the focus of the mitigation plan until

the State fulfills its obligations under the requirements of 40 CFR

51.930(b). The Administrator may nonconcur or defer action on

such a demonstration.

N/A

50.14(b)(9)(ii)

The prohibition on placing a concurrence flag in the appropriate

field for the data record in the AQS database by the Administrator

stated in 50.14(b)(9(i) does not apply to data that are included in an

exceptional events demonstration that is:

N/A

50.14(b)(9)(ii)(A)

submitted in accordance with 50.14(c)(3) that is also of the type and

pollutant that is the focus of the mitigation plan, and N/A

50.14(b)(9)(ii)(B)

submitted within 2-year period allowed for mitigation plan

development specified in 51.930(b)(3). N/A

1.3 SOURCES OF PM2.5 IN WESTERN NEVADA

Natural Sources

The western United States is increasingly prone to seasonal wildfires. While wildfires can and

do occur in Nevada, they are much more common in California, which is generally upwind from

Nevada. As wildfires continue to occur with higher frequency and severity, smoke associated

with these fires increasingly affects air quality across the region. These emissions result in

elevated PM2.5 levels that can exceed the NAAQS. Consequently, NDEP BAQP has prepared

this mitigation plan in accordance with federal requirements, as a means to ensure that the public


is informed of wildfire smoke events that may lead to elevated ambient PM2.5 levels, and

educated about how to minimize their exposure.

Anthropogenic Sources

Additional sources of PM2.5 in western Nevada include emissions from prescribed fires in both

California and Nevada, from residential woodstoves, and from permitted facilities.


2.0 MITIGATION PLAN COMPONENTS

The three required mitigation plan elements are discussed in the following sections.

2.1 PUBLIC NOTIFICATION AND EDUCATION

40 CFR 51.930 requires prompt notification of affected or potentially affected communities

whenever air quality concentrations exceed or are expected to exceed an applicable ambient air

quality standard. To determine the location of affected or potentially affected communities

impacted by an exceptional event, NDEP BAQP tracks and forecasts regional meteorology and

monitoring data daily, for all communities with ambient air quality monitoring stations within

the state.

Public Notification

The public is notified of air quality conditions via the following avenues:

The AirNow website (www.airnow.gov). This website is run by the USEPA and includes

current air quality data as well as air quality index (AQI) forecasts for the upcoming two

days;

EnviroFlash air quality forecast and alert emails. Through the USEPA’s AirNow

website, the public can sign up to receive air quality forecasts and alerts of unhealthy air

quality via email;

The NDEP’s near real-time monitoring data website, www.nvair.ndep.nv.gov. This site

is accessible from NDEPs main website, www.ndep.nv.gov by clicking on the Check Air

Quality in my Area link;

National Weather Service forecast discussions and air quality alerts (available at this

website https://www.weather.gov/rev/); and

Social Media. The NDEP BAQP is in the process of implementing both Facebook and

Twitter accounts to notify and interact with the public about air quality conditions and

issues.

Examples of public notifications are provided in Appendix A.

Public Education

Each of the public notification avenues discussed above contains information regarding how

individuals can protect themselves from wildfire smoke exposure (Appendix A).

In addition, the NDEP BAQP has developed a tool for estimating the air quality index based on

visibility (Appendix C). This tool includes information regarding how individuals can protect

themselves from airborne particulate matter. NDEP is in the process of making this available on

the NDEP website and distributing it to the following organizations:

Local school districts;

State and Local Health District(s);

http://www.airnow.gov/

http://www.nvair.ndep.nv.gov/

http://www.ndep.nv.gov/

https://www.weather.gov/rev/


State and County Parks and Recreation; and

Local Municipalities.

2.2 MITIGATING MEASURES

2.2.1 Minimizing Controllable Contributing Sources

Natural Sources

Smoke emissions from wildfires is the primary source of PM2.5 emissions in the Mitigation Area.

PM2.5 monitoring was initiated in the area in 2013, with the installation of two PM2.5 monitoring

sites. Since then, there have been eleven exceedances of the 2012 PM2.5 NAAQS in the

Mitigation Area. Of these, ten were due to smoke resulting from wildfires; in particular, smoke

emissions from wildfires burning in neighboring California.

Wildfires in the western United States have increased in both frequency and severity in recent

years. With continued fire suppression efforts, increased growth at the wildland-urban interface,

and ongoing drought, timely relief from such wildfires is not anticipated.

According to the EER, the USEPA considers wildfires on wildland to be natural events, and

therefore not reasonably controllable or preventable. As such, emissions from wildfires are not

controllable.

Anthropogenic Sources

The vast majority of PM2.5 exceedance events in the Mitigation Area are due to smoke emissions

from wildfires. Since PM2.5 monitoring began in the area, 51 of the total 52 exceedance days

were due to wildfire emissions, and one was due to smoke emissions from residential burning.

There have been no exceedances of the PM2.5 NAAQS due to prescribed fires or permitted

facilities in NDEPs jurisdiction within the past five years.

Prescribed Fire

Nevada Administrative Code 455B 22067 Open Burning: Prohibits the open burning of

combustible refuse, waste, garbage, or oil, or for any salvage operations. Depending on their

location, persons/agencies wishing to open burn vegetation (tree cuttings, slash in forest areas,

etc.) for the purposes of weed abatement, conservation, disease control, game or forest

management, personnel training or elimination of hazards must seek a permit from either the

NDEP Smoke Management Program (SMP; Appendix C) and/or their local fire authority.

This regulation applies statewide with the exception of Washoe and Clark County, and

compliance and enforcement of this rule are provided by the NDEP BAQP Monitoring and

Enforcement Branches. The Monitoring Branch manages the SMP, while the Enforcement

Branch addresses SMP violations.


The Nevada SMP serves to coordinate and facilitate the statewide management of prescribed

outdoor burning on lands in the state of Nevada. Land managers must obtain an open burn

authorization permit from the NDEP BAQP SMP for all management-ignited prescribed fires

projected to emit greater than 1.0 ton of PM, and for any fire training conducted regardless of

size. In reviewing the application for an open burning authorization, the SMP considers the

potential of the burn to contribute to area air pollution, among other factors. Authorizations are

not valid during periods of air pollution emergency or alert in the area of burning, and best

smoke management practices and smoke emission reduction techniques are conditions of the

permit. Open burn authorization holders must notify the SMP prior to ignition to receive final

approval for a prescribed fire. The SMP will deny burn permission if forecasted weather

conditions are not favorable or optimal for smoke dispersal, or if ambient air quality conditions

are poor, such as during a wildfire smoke event or meteorological temperature inversion. The

full text of the NDEP BAQP SMP is included as Appendix B. The NDEP BAQP also manages

NV-RxFire, an online map that displays all current open burn authorizations and active ignitions

(http://webgis.ndep.nv.gov/). This online map provides the public with the current status of open

burns in Nevada.

The state of Nevada does not require an open burn permit for agricultural burning; however, land

owners are strongly urged to consult the Nevada Handbook for Agricultural Open Burning

(Appendix C).

Residential Woodstoves

In 2013, the NDEP BAQP initiated the Woodstove Change-out Program in Douglas County and

Carson City with the goal of reduce PM2.5 emissions from old and inefficient woodstoves. Since

that time, more than 300 residential woodstoves have been exchanged for newer, more efficient

models. This program is still active, and continues to reduce anthropogenic PM2.5 emissions in

the Mitigation Area.

Permitted Facilities

The Clean Air Act requires states to submit a plan demonstrating their ability and authority to

implement, maintain, and enforce each of the NAAQS. The elements required in the plan

include enforceable emission limitations, an ambient air monitoring program, an enforcement

program, air quality modeling capabilities, and confirmation of adequate personnel, resources

and legal authority.

Nevada’s State Implementation Plan (40 CFR Part 52, Subpart DD) regulates PM2.5 emissions

from regulated sources throughout the state. These regulations limit PM2.5 emissions from

controllable sources within Nevada.

The lack of exceedances of the PM2.5 NAAQS due to emissions from permitted facilities in

Nevada over the past five years demonstrates that these emission controls are effective at

mitigating this anthropogenic source of PM2.5.


2.2.2 Minimizing Public Exposure to High Concentrations

In addition to minimizing contributions from controllable sources, NDEP BAQP provides for

prompt public notification of conditions that may exceed or are currently exceeding the NAAQS.

Together, these serve to minimize public exposure to high concentrations. The public

notification process is described in Section 2.1.

2.2.3 Monitoring Network

NDEP BAQP operates a network of ambient air quality monitors at a variety of locations

throughout the state of Nevada. In 2018, air quality monitoring was represented by eleven

ambient air quality monitoring stations (Carson City (ozone [O3], PM2.5), Elko (PM10), Fallon

(O3), Fernley (O3), Pahrump (PM10) and Gardnerville (PM2.5)) under the jurisdiction of the

NDEP BAQP. The USEPA provides minimum site requirements to monitor for O3 and PM

based on Metropolitan Statistical Area population (40 CFR Part 58, Appendix D). The NDEP

BAQP’s air monitoring network meets or, in most cases, exceeds the minimum network

requirements.

The regulatory data collected and maintained by NDEP BAQPs monitoring network is quality

assured in accordance with 40 CFR Part 58 and submitted to the USEPA’s Air Quality System

database. This data is communicated to the public via the outreach programs discussed in

Section 2.1.

In addition to regulatory air quality monitors, NDEP BAQP has several non-regulatory monitors

that may be deployed as needed during wildfire smoke events. These include:

Two MetOne EBAMs;

Three MetOne E-Samplers;

Two MetOne Neighborhood Monitors; and

Ten PurpleAir Personal Air Sensors.

The number and type of instrument deployed depends on several factors, including available

monitoring locations, available facilities at each location, and the urgency of deployment.

Coordinating with land managers and other air agencies regarding the placement of portable

ambient air quality monitoring equipment in smoke sensitive areas is also part of the NDEP

SMP.

2.2.4 Communication and Collaboration with other Air Agencies

As part of its Smoke Management Program, the NDEP BAQP has developed a LISTSERV to

communicate with other air agencies as well as other interested stakeholders during smoke

events affecting the Mitigation Area. This LISTSERV serves to facilitate coordination about

appropriate responses to abate and minimize smoke impacts to the public. In addition to the


LISTSERV, staff from the SMP are a part of the Nevada Prescribed Fire Alliance, and the BAQP

monitoring staff belong to several regional Exceptional Events Workgroups.

2.3 PERIODIC REVIEW AND EVALUATION

NDEP BAQP will review and evaluate this mitigation plan in the event of new PM-related

rulemaking.

The mitigation plan review will include an evaluation of:

Conditions that result in PM2.5 NAAQS violation in the Mitigation Area (if appropriate);

Effectiveness of public notification and education;

Success of control measures on identified sources; and

Efficacy of communication and collaboration between affected air agencies and

interested stakeholders.

A decision regarding revision and possible subsequent public comment period will be made after

review and evaluation.


3.0 PUBLIC NOTICE

3.1 PUBLIC NOTICE DOCUMENTATION

The Nevada Division of Environmental Protection has prepared this mitigation plan to satisfy the

requirements in 40 CFR 51.930. This mitigation plan was posted on the NDEP website

https://ndep.nv.gov/posts for review and comment by the public, for a minimum of 30 days.

Public comments were directed to:

Sheryl Fontaine, Ambient Air Monitoring Supervisor

Nevada Division of Environmental Protection

901 South Stewart Street, Suite 4001

Carson City, Nevada 89701

Email: [email protected]

3.2 PUBLIC COMMENTS AND NDEP BAQP RESPONSES

This section will be completed after the public comment period.

mailto:[email protected]


4.0 REFERENCES

United States Environmental Protection Agency (USEPA). 2016. The Treatment of Data

Influenced by Exceptional Events (81 FR 68216).

APPENDIX A

Sample Public Notifications

APPENDIX B

NDEP BAQP AQI Estimator

This guidance was developed by the Nevada Division of Environmental

Protection Bureau of Air Quality Planning.

The AQI table and visibility conversions were adapted from the” Wildfire Smoke: A Guide for Public Health Officials” (Rev. July 2008 with 2012 AQI

updates.

VISIBILITY RANGE AS A TOOL FOR ESTIMATING AIR QUALITY

Visibility (AQI) Local Landmark Level of Health Concern Visibility Example

Visibility >10 miles

Good = 0-50

Slide Mountain

Air quality is considered

satisfactory, and air pollution

poses little or no risk

Visibility 6 to 10 miles

Moderate = 51-100

Snow Valley Peak

Air quality is acceptable;

however, for some pollutants

there may be a moderate health

concern for a very small number

of people who are unusually

sensitive to air pollution.

Visibility 3 to 5 miles

Unhealthy for Sensitive

Groups = 101-150

Prison Hill

Members of sensitive groups may

experience health effects. The

general public is not likely to be

affected.

Visibility 1.5 to 2.75 miles

Unhealthy 151-200

Mouth of Ash Canyon

Everyone may begin to

experience health effects;

members of sensitive groups may

experience more serious health

effects.

Visibility 1 to 1.25 miles

Very Unhealthy 201-300

C Hill

Health alert: everyone may

experience more serious health

effects.

Visibility <1 mile

Hazardous 301-500

No visible landmarks

Health warnings of emergency

conditions. The entire population

is more likely to be affected.

This guidance was developed by the Nevada Division of Environmental

Protection Bureau of Air Quality Planning.

The AQI table and visibility conversions were adapted from the” Wildfire Smoke: A Guide for Public Health Officials” (Rev. July 2008 with 2012 AQI

updates.

VISIBILITY TOOL FOR ESTIMATING AIR QUALITY - GUIDANCE

The Nevada Division of Environmental Protection does not operate continuous air quality monitoring in

all Nevada communities. In areas that do not have monitors, visibility can serve as a quick way to

estimate air quality during times of elevated smoke or dust levels. The attached visibility table can be

used to estimate the air quality index (AQI). The AQI is an index for reporting daily air quality. It

indicates how clean or polluted the air is, and what the associated health effects might be. Higher AQI

values indicate higher levels of air pollution, which correspond to greater health concerns. For more

information about the AQI visit https://www.airnow.gov/.

The attached visibility table can be used to estimate the air quality in your area; make sure to take the

following steps:

Face away from the sun;

Determine the limit of your visibility range by looking at something at a known distance (miles).

The visibility range is the point at which even high-contrast objects (e.g. a dark mountain against

the sky at noon) totally disappear;

After determining the visibility in miles, use the table to identify the level of health concern and

the associated protective actions recommended.

As a general rule of thumb, if you can see and/or smell smoke or dust, you may be at risk for exposure to

unhealthy levels of particulate matter. The more smoke or dust you see and smell, the more unhealthy

your exposure. When air quality is poor, stay indoors and reduce levels of outdoor activity.

Smoky or dusty conditions can be unhealthy, especially for sensitive groups, which include young

children, the elderly, those with heart conditions, and anyone with respiratory ailments such as asthma,

emphysema, and bronchitis. Although all residents should use common sense to reduce exposure to

unhealthy levels of smoke and dust, members of sensitive groups in particular are urged to take

precautions whenever smoke or dust is present.

Keep in mind that air quality can change rapidly at different times during the day, depending on fire and

wind conditions. It is important to monitor smoke or dust levels in your area throughout the day and

make outdoor plans accordingly. Air quality is expected to be affected in localized areas until the

wildfire is under control and extinguished or the wind event is over.

Please contact a member of the Nevada Division of Environmental Protection Bureau of Air Quality

Planning Ambient Air Monitoring Group with any air quality questions (775) 687-9349. If you have

questions about your health, please contact your local health department and/or your health care

provider.

https://www.airnow.gov/

APPENDIX C

NDEP BAQP Smoke Management Program

Nevada Smoke Management Program 2013

1

Purpose The public policy of the State of Nevada is to achieve and maintain levels of air quality which will protect human health and safety, prevent injury to plant and animal life, prevent damage to property, and preserve visibility and the scenic and esthetic values of the state. The purpose of the Nevada Smoke Management Program (SMP) is to coordinate and facilitate the statewide management of prescribed outdoor burning on lands in the state of Nevada. This program is designed to meet the requirements of NRS445B.100 through 445B.845, inclusive which deal with air pollution, and the requirements of the EPA Interim Air Quality Policy on Wildland and Prescribed Fires (May 1998). This program in no way supersedes the authority of local governments to regulate and control smoke and air pollution under NRS244.361 and NRS268.410 or the authority of the state forester to regulate controlled fires under NRS527.122 through 527.128. Cooperation An ongoing cooperative effort by all organizations involved in the use of prescribed fire for accepted range, agricultural and forestry practices is essential to the success of this plan. Goals

o To assist in meeting visibility goals required in the Nevada Regional Haze State Implementation Plan.

o Acknowledge the role of fire in Nevada and allow the use of fire under controlled conditions to maintain healthy ecosystems while meeting the requirements of the Clean Air Act

o To encourage the development of better smoke management models and techniques o To provide for a voluntary approach to the implementation of a statewide smoke

management program o Facilitate the enjoyment of the natural attractions of the state o Provide a burning program for the people of this state o Protect human health and safety from the effects of outdoor burning o Foster and encourage the development of reasonable alternative methods for disposing of

or reducing the amount of organic refuse on lands in Nevada o To address interstate smoke transport issues through enhanced communication and the

development of interstate/interagency agreements


2

o Provide the opportunity for forest, rangeland, and crop burning while minimizing air quality impacts

Smoke Management Responsibilities Each land manager involved in the use of prescribed fire is responsible for proper smoke management for the prescribed fires it conducts and shall identify and implement appropriate smoke management techniques to minimize the amount and/or impact of smoke produced and to avoid exceedances of the Nevada and National Ambient Air Quality Standards. The Nevada Division of Environmental Protection (the Division) will work with the land managers and air agencies in other states to ensure that interstate transport of air pollutants does not unfairly restrict the ability of Nevada’s land managers to implement prescribed fire programs. Definitions Agricultural Burning includes crop residue burning, ditch and fence line burning, rangeland burning, and burning for land clearance and general upkeep, but does not include burning of garbage and man-made materials as a form of waste disposal. Class I Area includes all international parks, national wilderness areas which exceed 5,000 acres in size, national memorial parks which exceed 5,000 acres in size, and national parks which exceed 6,000 acres in size and which are in existence on August 7, 1977 (CAA Section 162(a)). The only Class I area designated in Nevada is the Jarbidge Wilderness. Land manager includes any federal, state, local or private entity that administers, directs, oversees or controls the use of public or private land, including the application of fire to the land. National Ambient Air Quality Standards (NAAQS) refers to standards for maximum acceptable concentration of pollutants in the ambient air to protect public health with an adequate margin of safety, and to protect public welfare from any known or anticipated adverse effects of such pollutants (e.g., visibility impairment, soiling, materials damage, etc.) in the ambient air. Open Burn Authorization is a permit issued by the Nevada Division of Environmental Protection


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for all management ignited prescribed fires which emit greater than 1.0 ton of PM10, and for any fire training being conducted regardless of size. This permit was formerly called an Open Burn Variance. PM10 refers to particulate matter 10 microns in diameter or smaller. PM2.5 refers to particulate matter 2.5 microns in diameter or smaller. Prescribed fire includes any fire purposefully ignited by management actions to meet specific land management objectives. An approved Open Burn Authorization must exist prior to ignition. The definition does not include fire training, public open burning or any other type of burning that is not specifically listed in the applicability section of this document. Public open burning is the burning of vegetative yard waste conducted by single family residences within the jurisdiction of and under a permit obtained by the local fire protection agency. The vegetative yard waste must be generated only from the residence conducting the burn. Smoke management includes but is not limited to techniques to reduce emissions and smoke impacts, the identification and avoidance of smoke sensitive areas, the monitoring and evaluation of the smoke impacts of each burn, and coordination among land management agencies to minimize cumulative impacts. Smoke sensitive areas include but are not limited to Class I areas as well as other designated scenic and/or important views especially during times of significant visitor use, urban and rural population centers, homes, schools, hospitals, nursing homes, transportation facilities such as roads and airports, recreational areas, and other locations that may be sensitive to smoke impacts for health, safety, and/or aesthetic reasons. Suppression action includes any activity in which the responsible fire control agency personnel are actively trying to confine, contain or control a fire. Use of natural fire barriers such as cliffs, rocks, or rivers, etc., to contain the fire may be regarded as suppression as long as this is part of the suppression strategy. Wildfire is an unplanned ignition of a wildland fire (such as a fire caused by lightning, volcanoes, unauthorized and accidental human-caused fires) and escaped prescribed fires.


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Wildland Fire is a general term describing any non-structure fire that occurs in the wildland. A wildland fire may be concurrently managed for one or more objectives and those objectives can change as the fire spreads across the landscape, encountering new fuels, weather, social conditions, and governmental jurisdictions. Applicability The provisions of this smoke management program apply to all areas of the state under the jurisdiction of the Nevada Division of Environmental Protection. The Division’s jurisdiction does not include Washoe or Clark Counties or any Bureau of Indian Affairs (BIA) trust lands. Provided no acceptable alternative exists (see Permit Application for Management Ignited Prescribed Fires, Section (a) for a discussion of acceptable alternatives), open burning under this smoke management program may be conducted for the following types of projects:

a. Hazardous fuel reduction; b. Slash disposal from timber sales and roads constructed within contract areas; c. Wildlife and livestock habitat improvement; d. Forest and rangeland improvement; e. Insect, weed and disease control; f. Site preparation for revegetation; g. Watershed management and water yield improvement; h. Maintenance and improvement of natural ecosystems; i. Maintenance of threatened and endangered species; and, j. Other vegetative management improvement projects. k. Agricultural practices.

The permitting requirements described below do not apply to small wood fires for recreational, ceremonial, heating or cooking purposes, to burning conducted for agricultural purposes and management, or to burning conducted at single-family residences, as defined under public open burning, at least one mile beyond the boundaries of the following cities, towns and areas: Babbit, Battle Mountain, Caliente, Carlin, Dayton, Elko, Ely, Fallon, Fernley, Gabbs, Gardnerville, Gardnerville Ranchos, Genoa, Hawthorne, Johnson Lane, Lovelock, McGill, Minden, Tonopah, Topaz Ranch estates, Virginia City, Weed Heights, Wells, Winnemucca, and


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Yerington; and on the Nevada side of the Tahoe Basin, in Carson City and in those portions of Douglas and Lyon Counties that are within one mile of the Carson City line. An Open Burn Authorization must be obtained for burning conducted for any of the other types of projects listed above in items a through j. No permit is required for burning used as an agricultural practice; however, the Nevada Handbook for Agricultural Open Burning should be consulted. For burns conducted at single-family residences within the cities, towns and areas listed above, the local fire protection agency must request a burn permit to allow public open burning. A permit (Open Burn Authorization) must be obtained for any fire training being conducted or any other open burns not specifically listed above regardless of size. A fire training burn is a fire ignited for the purposes of instructing professional firefighters, industrial employees or other personnel in methods of fighting fire. Fire training burns do not include the burning of structures unless authorized in advance by the Director of the Department of Conservation and Natural Resources, or authorized by an officer of the State of Nevada or its political subdivisions and concurred in by the Director, in accordance with open burning regulations under NAC 445B.22067. Smoke Management Contingency Plan In plans for prescribed fires, each land management organization will have contingency plans identified enabling it to reduce smoke emissions. Contingency plans will be implemented when meteorological conditions warrant, the Nevada Division of Environmental Protection, Bureau of Air Quality Planning determines that acceptable limits of smoke accumulation are or will be exceeded, and/or the responsible land management organization anticipates that the prescription for a particular fire will be exceeded. Should prescriptive elements cease to conform to those in the approved open burn permit, the land manager shall assess the merits and risks of all options and if justified take the appropriate corrective action to reduce further impacts, as well as consult with the Division within 24 to 48 hours.


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Permits Authority 1. Federal Clean Air Act. Section 118(a), “Control of Pollution from Federal Facilities”;

Section 110, Implementation Plans”; Section 116, “Retention of Authority”; Section 169(a), “Visibility Protection for Federal Class I Areas”; Section 176(c), “Limitations on Certain Federal Assistance”.

2. Nevada Revised Statutes. Section 445B.100, Declaration of public policy; Section 445B.110, Air pollution defined; Section 445B.210, Powers of the commission; Section 445B.220, Additional powers of the commission; Section 445B.230, Powers and duties of the department; Section 445B.235, Additional powers of the department; Section 445B.240, Power of representatives of department to enter and inspect premises; Section 445B.300, Operating permit for source of air contaminant; notice and approval of proposed construction; administrative fees; failure of commission or department to act; Section 445B.450, Notice and order by Director; hearing; alternative procedures. Section 445B.595, Governmental sources of air contaminants to comply with state and local provisions regarding air pollution; permit to set a fire for training purposes; planning and zoning agencies to consider effects on quality of air.

3. Nevada Administrative Code. Section 445B.22067 Open burning. Section 445B.275, Violations: Acts constituting; notice.

4. Implementation of this program in no way supersedes the authority of local governments to regulate and control smoke and air pollution under NRS244.361 and NRS268.410 or the authority of the state forester to regulate controlled fires under NRS527.122-527.128.

Permit Application for Management Ignited Prescribed Fires Land managers must obtain a permit called an Open Burn Authorization from the Nevada Division of Environmental Protection for all management ignited prescribed fires which emit greater than 1.0 ton of PM10 and for any fire training being conducted regardless of size. The permit must be obtained prior to ignition. For each project emitting between 1.0 and 10 tons of PM10, a one-page permit application form must be completed and submitted to the Division at least two weeks prior to the planned date of ignition. For fires emitting more than 10 tons of PM10, the complete application package must be submitted at least 30 days prior to the planned ignition date. Completed applications will be reviewed by the Division and, if approved, signed and returned to the applicant as soon as possible, but at least one week prior to the planned date


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of ignition. Should circumstances occur which will not allow the land manager to submit a completed permit application 14 or 30 days prior to the burn, the Division will make a good faith effort to work with the land manager to issue the permit as soon as possible. The issuance of a permit does not constitute final approval. Final approval must be requested one business day prior to ignition (see “Pre-ignition Notification”). Final approval will be based on favorable fire weather forecast conditions and ambient air quality conditions. If a request for final approval is denied, the Division can provide the land manager with written record of that denial within 10 days after the verbal denial was issued. Permit Application Requirements 1. For prescribed fires emitting more than 1.0 but less than 10 tons of PM10, the permit

applicant need only complete the application form provided by the Division (Appendix 1). The Division may request additional information from the burn plan if available.

2. For prescribed fires emitting more than 10 tons of PM10 and located more than 15 miles

from a smoke sensitive area, Class 1 area or carbon monoxide or particulate matter non-attainment area, the completed application must be accompanied by a burn plan. The burn plan must include the following: a. The specific location and description of the area to be burned; b. The responsible personnel; c. An emergency telephone number that is answered 24 hours a day; d. The property owner; e The agency/contractor conducting the burn; f. The burn prescription; g. The number of acres to be burned, the type of fuel, fuel loading estimates and the

ignition technique to be used; h. A list of agencies and private parties involved; i. A model predicting the impact of smoke (both visibility and PM10) on smoke

sensitive receptors. The model shall incorporate all known smoke sensitive receptors within 15 miles of the fire. Modeling requirement may be evaluated on a project by project basis with consultation with the land management agency.

j. Discussion of public notification to be conducted; and k. Evaluation of alternative treatments.


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3. For prescribed fire projects emitting more than 25 tons of PM10, or more than 10 tons if the burn is within 15 miles of a Class I area, an area that is non-attainment for particulates, a carbon monoxide non-attainment area, or other smoke sensitive area, the following information must also be submitted with the burn plan: a. A smoke management plan including actions taken to minimize emissions before,

during and after the fire; b. Emission estimates including the models, methods and emission factors used; c. Identification of all smoke sensitive areas located within 15 miles of the project; d. Safety and Contingency plans. e. List of potential affected air regulators to be notified; and f. Air monitoring to be conducted.

In reviewing the application for an open burning permit, the Division will consider the following factors, in addition to ensuring that all required elements have been submitted based on the size of the burn:

a. Consideration and evaluation of alternatives to burning When one management objective is to maintain a fire dependent ecosystem the effects of fire cannot be duplicated by other tools. Fire may be the preferred management tool even when other treatments may be equally effective for meeting other objectives. Fire can also be used to reduce heavy fuel loads and prevent catastrophic wildfires. Wildland owners/managers may have an array of tools, including fire, which can be used to accomplish land use plans, depending on the resource benefits to be achieved. Several factors should be considered when selecting appropriate treatments. Those factors include the environmental impacts (e.g. air and water quality, soil, wildlife, etc.), whether fire must be used to meet management objectives and the costs of treatment. The best combination of treatments are those that meet management goals with the most favorable environmental impacts at the most reasonable costs. A detailed description of the alternatives considered and the rationale for rejecting them must be submitted for all projects estimated to emit more than 10 tons of PM10. The Division recognizes that alternatives are not without potential negatives and that multiple resources must be weighed along with air quality benefits. However, a permit will not be issued if this information has not been submitted. For smaller projects, the certification signed by the responsible party indicating that alternatives have been considered will suffice. However, the responsible signatory should be prepared to discuss the


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alternatives considered should Division staff request the information. Once the Division determines that the description of alternatives considered and the rationale for rejecting them has not been submitted, the Division will immediately notify the permit applicant and request the information. If the applicant is unable to provide the information, the Division will notify the applicant in writing that the application is incomplete and that the permit cannot be issued.

b. Proximity to populated areas and points of nearest public access For any project generating more than 10 tons of PM10, the applicant shall provide information regarding the proximity of all smoke sensitive areas located within 15 miles of the planned project and the points of nearest public access. The applicant shall highlight smoke sensitive areas on a map depicting the project location. Procedures for notifying the public of burn dates in smoke sensitive areas shall be included with the applicant’s burn plan.

c. Climatic conditions on the day or days of burning Where burn plans are required, burns must be conducted within the meteorological conditions indicated in the burn plan, but the Division may limit projects in certain geographic areas during “high pollution periods” when existing air quality or cumulative impacts may warrant such limitations.

d. Potential contribution to area air pollution The applicant shall demonstrate that applicable ambient air quality standards (within and outside of Nevada) will not be violated for projects that will emit more than 25 tons of PM10 or for projects that emit more than 10 tons of PM10 and are located within 15 miles of a Class I area, an area that is in non-attainment for carbon monoxide or particulate matter, or a smoke sensitive area. This demonstration shall be conducted using currently accepted models. The model output shall explicitly show conditions under which the burn will be conducted so as to minimize impacts of emissions.

Valid permit dates. Although the Division would like to monitor potential burns as closely as possible, we recognize that land managers must be able to respond to meteorological conditions appropriate for the burn being permitted. Permits will be issued that are valid for up to three months, or as many as twelve months for fire training projects. If more time is required, the applicant can request additional time when the application is submitted. Each permit shall be valid for the dates listed on the permit. The permittee must note the expiration date of each


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permit. Requests for an extension or modification of dates may be made verbally, but must be approved by the Division in writing prior to the burn taking place. Permit Conditions The following permit conditions shall apply to permits issued by the Division of Environmental Protection for open burning. 1. Air pollution emergencies and alerts: Permits will not be valid during periods of air

pollution emergency or alert in the area of burning. At the determination by the Division of such a period, the Division shall notify each permit holder.

2. Pre-ignition notification and approval: For projects emitting more than 1.0 ton of

PM10, the land manager must notify the Division one business day preceding the burn and received final approval before the prescribed burn can be ignited. See “Pre-ignition Notification” for further information.

3. Smoke Management: In order to minimize smoke impacts and emissions, each

permittee shall apply the best smoke management and emission reduction techniques. It is recognized that no two fires are alike in terms of smoke emissions and impacts. Neither are any two fires alike in the smoke management options available. Therefore, the land manager will select appropriate smoke management techniques on a case-by-case basis. While the application of smoke management is required in order to obtain a permit from the Division, it is a general goal and responsibility of the land manager to select the appropriate emission reduction and impact minimization techniques for each fire.

4. Precautions: Prescribed fires shall be supervised by one or more responsible persons

dependent on the type of burning. Precautions shall be taken to localize the burning and to, in no way, constitute a fire hazard to persons or property within or adjacent to the burn area. The granting authority and the employees or agents thereof, in the issuing of a permit, do not assume any responsibility or liability for any hazardous condition created by the permittee which results in damage to the person or property of the permittee, or the person or property of any third person.

5. Availability of Permit: The approved permit or copy thereof shall be available at the

burn site.


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6. Inspection by the Division: All open burning operations shall be subject to inspection

by the Division. 7. Local Regulations: The permit is for compliance with state air pollution control

requirements only and is not a permit to violate any existing local laws, rules, regulations, or ordinances regarding fire, zoning, or building.

8. Revocation of Permit: If at any time the Division determines that any condition of the

permit is not being complied with, the permit may be revoked for the specific project where non-compliance is occurring. At such time, all burning activities at the site of the non-compliance shall be terminated. In addition to revocation of the permit, the Division may take any other enforcement action authorized under state statutes, rules and regulations.

9. Other Conditions may be added to the permit if deemed necessary by the Division and

approved by the SMP working group. Pre-ignition Notification Pre-ignition notification must be given to NDEP for all prescribed burns for which an Open Burn Authorization has been issued. The land manager must notify the Division as soon as practicable, but no later than 2 pm of the business day preceding the burn. Notifications must be made to the Smoke Management Coordinator at (775) 687-9360 or to [email protected]. The land manager will leave a message including the date of the proposed burn, the permit number, location, responsible agency, estimated number of acres to be burned and a contact name and phone number. For each Open Burn Authorization, NDEP will track and verify that an applicable Open Burn Authorization has been given and that either a pre-ignition notification has been received or a pre-burn approval has been issued. For those prescribed burns estimated to emit 10 tons of PM10 or greater, the land manager shall not ignite the prescribed burn without first receiving the approval of the Division. Notification of the intended ignition shall be made as soon as practicable, but no later than 2 pm of the business day preceding the burn. The Division shall issue a final decision on the burn, either approval, approval with conditions, or disapproval, by 5 pm on the business day prior to ignition. If an ignition is planned for the weekend or Monday, notifications and requests for pre-burn


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approval must be received by noon on Friday. If the Division does not communicate its decision by 5 pm of the business day prior to ignition, the burn is deemed approved. NDEP will disapprove of the burn if forecasted conditions are not favorable; including conditions not favorable for optimal smoke dispersal, or if ambient air quality conditions are poor. In making its decision, NDEP will review forecasted weather conditions for the burn area and discuss the conditions with the agency conducting the burn. At the Division’s discretion, resources used to assess conditions will include: the National Weather Service, Wildland Fire Assessment System, data from nearby ambient air quality monitor stations, the California 13:00 hour call originating daily from USFS Predictive Services in Redding, and adjacent air pollution control agencies burn/no burn decisions. Additionally, for prescribed fires near the California border the California Prescribed Fire Information System (PFIRS) will be consulted. The Division may consider BLUESKY (from CANSEC) or HYSPLIT Trajectory Model outputs if available. If a land manager wishes to receive written notice of any denial, a message to that effect should be left on the Smoke Management Hotline at (775) 687-9360 or at [email protected]. Affected Agency Notification For prescribed fire projects that emit more than 10 tons of PM10 and are within 15 miles of the state border, BIA trust lands managed under the jurisdiction of a tribal air quality agency, or the borders of Washoe or Clark counties, the air regulators of those counties, tribes or bordering states must be notified prior to the burn. A list of the agencies and individuals to be notified must be included in the burn plans. Appendix 2 provides a listing of state, local and BIA/tribal contacts. This list will be updated by the Division at least annually. Wildfire Wildfire will not require a permit. Wildfire Smoke Assessment Coordination Cooperation among land management agencies and air regulatory agencies during a significant wildfire event is essential to protect human health, maintain air quality standards and reduce


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visibility impairment. A significant wildfire event is one that is determined by NDEP or the land management agency to have a high potential to result in serious or sustained smoke impacts to a local community or a region of the state. Concern over smoke from wildfires requires that a strategy be adopted that identifies potential management actions that may be used to identify and mitigate smoke impacts. The goal of Wildfire Smoke Assessment Coordination is to provide land management agencies and NDEP with a list of potential management actions that may be used when unhealthy air quality levels occur so that adverse public health effects caused by smoke from wildfires are mitigated. Communication is critical to meeting this goal. In cases of a significant wildfire event within the state, there should be regular communication between the land management agency in whose jurisdiction the wildfire occurs and NDEP in order to assess ambient air quality conditions and exchange information. Mutual contact should be made when unhealthy air quality conditions exist or when periods of poor atmospheric dispersion are predicted. Coordination should focus on the following elements:

a) Exchange of basic fire information such as the location, daily anticipated growth, estimated control date, and estimated incident size;

b) Providing opportunities for NDEP to partake in conference calls as needed; c) Facilitating NDEP participation in field observations of wildfires if appropriate; d) Coordinating placement of portable ambient air quality monitoring equipment in smoke-

sensitive areas as needed; e) Making provision for the land management agency to make available smoke information

when the agency distributes wildfire information to the public; f) Arranging for joint discussions by the land management agency and NDEP on predicted

smoke plume direction and distribution; g) Collaboration between the land management agency and NDEP on smoke advisories and

other information issued on current and predicted smoke concentrations in order to assist land managers and the public in making informed decisions.

Through mutually beneficial coordination during significant wildfire events, NDEP and the land management agencies will take action to identify smoke impacts and provide information to assist the public in taking reasonable precautions. All parties involved in wildfire smoke coordination will assess the usefulness of the Wildfire Smoke Assessment Coordination policy outlined above, which may be utilized as a template to develop a more formal wildfire smoke response protocol in the future.


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Post Burn Emissions Reporting Permitted users of prescribed fire are required to submit a Post Burn Emissions Report following the completion of the prescribed fire project. Post burn reporting applies to every burn authorization issued, except those authorizations issued for fire training and weed abatement projects, and those that result in emissions of less than 1 ton of PM10. The Post Burn Emissions Report is in spreadsheet form and will be provided by the Division (Appendix 4). Information to be reported includes: the permit number, the project name, the agency name, dates of burning, project location, project acres and actual acreage burned, burn type, fuel type, fuel loading, PM10 emissions estimates, emission factors used, emission reduction techniques, and contact name. The Post Burn Emissions Report will be submitted by email to the Division smoke management coordinator within 30 days of project completion. Several projects may be listed on the same Post Burn Emissions Report. Burn Oversight, Fire Behavior and Environmental Monitoring Requirements for Agency-Conducting Burn

1. Prescribed fire --

a. If at any time the responsible land management agency determines that the prescription for a particular prescribed fire has been exceeded (including impacts on visibility) and/or conditions of the permit are not being met (i.e., designated areas for burn, proper notification, etc.) the responsible parties shall promptly initiate suppression action, modify the prescription, or other appropriate action. The responsible signatory must monitor the actual fire to a sufficient level to provide information regarding whether or not the fire is within prescription. Monitoring data collected before, during and after the burn should be used to evaluate the achievement of specific smoke management objectives, and to provide feedback for refinement of future prescriptions.

b. If at any time it is determined by the Division, in consultation with the responsible land management agency, that the prescribed fire is degrading air quality to levels expected to violate air quality standards and/or permit conditions, the responsible parties shall promptly initiate suppression action unless, after consultation with the Division, the prescription is modified, or other appropriate


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actions are taken. Factors that the Division will consider in this determination include, but are not limited to: i. Modeled data that indicates expected violations of any Ambient Air

Quality Standard (e.g. carbon monoxide (CO), particulate matter under 10 microns in diameter (PM10), or particulate matter under 2.5 microns in diameter (PM2.5);

ii Air quality monitoring data that indicates expected violations of any Ambient Air Quality Standard;

iii. Proximity of the fire to smoke sensitive areas; iv. Citizen complaints; v. National Weather Service Fire Weather Forecast predictions; vi. Fuel conditions; vii. Existing and predicted size of the fire.

Checklist for Field Oversight of Prescribed Fire The Division may provide staff oversight of prescribed burns. Staff conducting field oversight of prescribed burning may verify the following:

• Nature of the burn, field conditions, and location of smoke sensitive areas match information provided in the Open Burn Authorization and the burn plan developed by agency conducting burn;

• Onsite weather conditions are favorable for smoke dispersal, including wind speed and direction;

• Test burn was conducted and results suggest favorable conditions, including mixing height and dispersion;

• Fuel conditions are favorable for smoke mitigation (how wet or green are the fuels); • Public notifications were made in accordance with the smoke management plan

submitted by the agency conducting the burn; • Smoke is not impacting nearby residents or smoke sensitive areas as the burn progresses; • Other factors necessary to demonstrate compliance with the SMP.

A land manager conducting a prescribed burn shall permit Division staff to enter and inspect


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burn sites, before, during and after burns, to verify the accuracy of the permit information and compliance with the burn plan and smoke management plan, if appropriate. The burn boss, their designee, or other onsite official of the agency conducting the prescribed fire should be prepared to answer Division questions involving the items listed above. Site inspections conducted by the Division during and after fires shall be coordinated with the appropriate the land manager as necessary to ensure the safety of Division employees and land managers. Should protective equipment be required, Division employees will have been properly trained in its use prior to entering any restricted area. Except under extraordinary circumstances, inspections will be conducted during reasonable business hours. Inspections on private property will be limited to valid permit days and within one week following the prescribed fire. The permit may be revoked and enforcement actions taken should the Division determine that any condition of the permit is not being complied with, if the project is degrading air quality to levels expected to violate air quality standards, or if smoke is impacting smoke sensitive receptors. Air Quality Monitoring and Sampling Requirements for Agency Conducting the Burn The extent of air quality monitoring should match the size of the fire and potential human health impacts. For small fires or fires that are remote enough to result in no noticeable impact on the public, visual monitoring of the direction of the plume and monitoring nuisance complaints by the public may be sufficient. Other monitoring techniques include posting personnel on vulnerable roadways to look for visibility impairment and initiate safety measures for motorists; posting personnel at other smoke sensitive areas to look for smoke intrusions; using aircraft to track the progress of smoke plumes; and continued tracking of meteorological conditions during the fire. For larger fires of extended duration locating real-time particulate matter sampling at smoke sensitive areas may be warranted to facilitate timely response to smoke impacts. If pollutant levels are anticipated to create a significant threat to human health, the Division may require the responsible land management agency to sample air quality in or near population centers impacted by smoke generated from a particular prescribed fire or wildfire. The Division will assist in identification of instrumentation, site selection, installation of instrumentation, operation, calibration, quality assurance, quality control, laboratory analysis, data interpretation and supplies. Impact from wildfire will be monitored by the Division.


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Due to the cooperative interagency nature of this Smoke Management Plan, cost sharing and pooling of resources associated with monitoring and/or modeling is understood. For monitoring and sampling of smoke generated by prescribed fire, the Division may ask the responsible land management agency for financial reimbursement as negotiated and mutually agreed upon on a case-by-case basis between the Division and the responsible land management agency before resources are expended on modeling or air quality sampling. Division Sampling for National Ambient Air Quality Standards by means of a Smoke Trailer at Large Burns with Potential for Impacts to Smoke Sensitive Areas The Division will consider deployment of a smoke monitoring trailer for large prescribed burns, defined as those that are in excess of 10 tons of PM10, or greater than 500 acres in size, or those that may pose a risk to smoke sensitive areas. Factors that will be considered in the decision to deploy the trailer include:

• Coordination with burn boss or other authority • Size of burn (acres/piles) and estimated tons of PM10 and PM2.5; • Proximity to smoke sensitive areas; • Sufficient lead time, staff availability, and travel approval; • Ease of access and availability of secure location.

The trailer-mounted E-BAM monitor will be positioned in the anticipated downwind location nearest the most likely-impacted smoke sensitive area. It will be used to collect 24-hr PM-10 and/or PM2.5 data. The data will either be read by the on-site staff member or will be electronically transmitted back to the Division. Daily readings will be forwarded by the on-site staff member or the Monitoring Supervisor to the BAQP Chief. PM10 or PM2.5 data that attain 80% of the ambient standard concentration level (24 hour standard) may trigger:

• A revocation of the Open Burn Authorization and a requirement to cease further burning issued to the agency conducting the burn.

• An alert or warning to protect the public drafted in accordance with NRS 445B.560 and issued in conjunction with local or state health officials, should the smoke constitute an imminent and substantial danger to the health of persons.


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Program Support Land managers and air regulators will work together to assess program implementation needs and to develop a mechanism for providing adequate program support. Program support may be in the form of in-kind services, equipment and space. Program support agreements will be formalized under an MOU and an Interagency Agreement between the Nevada Division of Environmental Protection and the land management agencies. The agreement will be evaluated periodically to ensure that implementation needs continue to be met. Smoke Management and Emission Reduction Techniques Each land manager conducting prescribed burning shall implement as many smoke management and emission reduction measures as are feasible for the specific burn and shall include a description of the emission reduction techniques used in the post-fire activity report submitted. The following smoke management and emission reduction techniques are considered best management practices. However, the Division understands that emission reduction techniques (or best available control measures) are not without potential negatives and must be prescribed and used with careful professional judgment and full awareness of possible tradeoffs. 1. Reducing the biomass by use of techniques such as yarding or consolidation of

unmerchandisable material, multi-product timber sales or public firewood access, when economically feasible. When allowing public firewood access, the public must also be informed of the adverse impacts of using green or wet wood as fuel;

2. Burning in seasons characterized by meteorological conditions that allow for good smoke dispersion;

3. Using mass ignition techniques such as aerial ignition by helicopter to produce high intensity fires with short duration impacts;

4. Igniting burns under good-to-excellent ventilation conditions and suspending operations under poor smoke dispersion conditions;

5. Considering smoke impacts on activities conducted by local communities and land users; 6. Burning only those fuels essential to meet resource management objectives; 7. Minimizing duff consumption and smoldering through fuel moisture considerations; 8. Minimizing dirt content when slash piles are constructed by using a root rake on

material-moving equipment and by constructing piles under dry soil conditions or by using hand piling methods;


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9. Burning piles when other burns are not feasible, such as when snow or rain is present; 10. Using all opportunities that meet the burn prescription and all burn locations to spread

smoke impacts over a broader time period and geographic area; 11. Burning during optimum mid-day dispersion hours, with all ignitions in a burn unit

completed by 3 p.m. to prevent trapping smoke in inversions or diurnal wind flow patterns;

12. Using chunking of piles and other consolidations of burning material to enhance fuel consumption and to minimize smoke production;

13. Implementing maintenance burning in a periodic rotation mimicking natural fire cycles to reduce excessive fuel accumulations and subsequent excessive smoke production through smoldering or wildfire; and,

14. Managing smoke impacts as follows: a. Limiting smoke impacts to roads, highways, and airports to the amounts,

frequencies, and durations consistent with any guidance provided by highway and airport personnel;

b. Using appropriate signing if smoke will impact any point of public access, i.e. highways, dirt roads, trails, campgrounds, etc.

c. Notifying the public at potentially impacted smoke sensitive areas; and d. Determining nighttime impacts and taking appropriate precautions.

Burner Qualifications All burns conducted by state and federal land managers shall be conducted by personnel trained in prescribed fire and smoke management techniques to the minimum level required by the land management agency in charge of the burn. The local fire management officer of the state or federal land management agency having jurisdiction over the prescribed burn shall have had smoke management training obtained through successful completion of a National Wildfire Coordinating Group (or equivalent) course dedicated to smoke management. Enforcement The Division stresses the importance of compliance with the provisions of this SMP by the agencies conducting prescribed burning. Adherence to the SMP helps maintain levels of air


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quality which are protective of human health, as well as sustain visibility and the scenic and esthetic values of the state. Failure to comply with the procedures and conditions specified in the Open Burn Authorization may result in enforcement action. The Division has been granted a number of authorities in the Nevada Revised Statutes and the Nevada Administrative Code to assist in enforcing requirements that preserve air quality. NRS 445B.230 provides broad authority to make determinations and issue orders as may be necessary to implement the programs that protect air quality. Violations are addressed in NRS 445B.450, which provides authority for the Division to serve written notice upon the person or persons responsible for alleged violations. Regulations under NAC 445B.275 specify the types of violations for which written notice may be issued. A notice may be issued that includes an order to take corrective action within a reasonable time, or may require the person or persons responsible for the alleged violation to appear before the State Environmental Commission. The action may require further coordination and mutually agreeing to refine strategies or methods that utilize experiences to reduce the risk of public health issues. Violations may result in penalties of up to $10,000 per day per violation being assessed. Appendix 1 -- Copy of the Open Burn Authorization Permit Application Appendix 2 -- Local, State and Tribal Air Quality Agency Contacts Appendix 3 -- Applicable State and Local Statutes and Regulations Appendix 4 -- Post Burn Emissions Report Form

APPENDIX D

Nevada Handbook for Agricultural Open Burning

Department of Conservation and Natural Resources

Division of Environmental Protection

Bureau of Air Quality Planning

The Nevada Handbook for Agricultural Open Burning

Self-Instruction Handbook

• Air Pollutants In Smoke

• Burn With Less Smoke

• Manage Smoke

This handbook discusses the burning of agricultural materials on cultivated farmland, rangeland, and

along ditches or fence lines. It does not cover forest management, wildland vegetation management,

or wildlife habitat improvement projects, nor does it cover other open burning, such as for personnel

training or residential cleanup. Contact your local fire protection district for more information about

these types of burns.

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Table of Contents SMOKE MANAGEMENT FOR AGRICULTURE .................................................................. 1

WHY SMOKE MANAGEMENT? ............................................................................................. 2

WHAT IS AGRICULTURAL BURNING? ............................................................................... 2

SMOKE MANAGEMENT .......................................................................................................... 3

BURN NOTIFICATION .............................................................................................................. 4

ADDITIONAL INFORMATION ................................................................................................ 6

Forms Contact Information .........................................................................................................................7

Notice of Open Burn Activity Instruction Sheet ..............................................................................8

Notice of Open Burn Activity Form ................................................................................................9

SMOKE MANAGEMENT FOR

AGRICULTURE

You may wonder why there has recently been

increased attention directed toward

agricultural burning. In past years, the health

effects of smoke resulting from agricultural

burning were not always considered to be

significant. The smoke was viewed more as an

inconvenience than a potential health risk.

Smoke was simply accepted by agrarian

communities as a necessary part of successful

agriculture. While smoke will always be an

important component of agricultural

management, we are more keenly aware of its

health effects.

Due to natural growth rates and an influx of

people from other parts of the country,

Nevada’s population is growing rapidly. Many

of these people are not from agricultural areas

or come from states where stringent

regulations limit agricultural burning. They

may consider your burning to be both a

serious nuisance and a health risk.

In recent years, the U.S. Congress directed the

Natural Resources Conservation Service to

establish an agricultural air quality task force.

The task force recommended that states adopt

a smoke management program that reduces

the health impacts of agricultural burning. The

Nevada Bureau of Air Quality Planning

(BAQP) developed voluntary guidelines in the

Nevada Handbook for Agricultural Burners

with the assistance of state and federal land

management agencies, fire protection districts,

and agricultural representatives.

The handbook has three main goals:

• Allow the continued use of fire as an

accepted agricultural management

practice.

• Protect public health and welfare by

reducing the impacts of open burning

on air quality and visibility.

• Encourage the use of non-burning

alternatives.

We hope to achieve these goals by promoting

good burning practices, improved

communication, and the utilization of non-

burning alternatives. All federal, state, and

local agencies conducting open burns on

public and private lands in Nevada have

agreed to comply with smoke management

practices similar to those provided in this

handbook. We hope that this handbook will

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help you appreciate the value of smoke

management practices in your agricultural

operations. By being a responsible burner, you

help ensure we maintain good air quality for

all Nevadans.

WHY SMOKE MANAGEMENT?

Industry, transportation, and open burning all

affect the air quality in Nevada. The most

common air pollutant in rural Nevada is

particulate matter. Microscopic particulates

that have an aerodynamic size less than or

equal to 10 microns are called PM10. By

comparison, a human hair is about 70 microns

in diameter. The small size and weight of

PM10 allows some particles to remain airborne

for weeks and to travel long distances. Toxins

and gases readily absorb into or coat these tiny

particles.

Smoke is a mixture of gaseous air pollutants

and particulate matter. About 90% of smoke is

PM10. The particulate matter produced by

burning consists of particles of soot (unburned

carbon), ash (unburned minerals), condensed

fumes (including toxic and cancer causing

aerosols) and other products of incomplete

combustion. When inhaled, PM10 particles and

any sorbed toxins can travel past the

protective linings of the airways and into the

deepest part of the lungs. Not all the particles

are expelled when you exhale. Those retained

in the lungs can cause serious harm.

The gaseous pollutants include: carbon

monoxide, hydrocarbons, and oxides of sulfur

and nitrogen. Carbon monoxide reduces the

blood’s ability to supply oxygen. Those most

at risk are infants, the elderly and those having

heart, lung or anemic diseases. When oxides

of nitrogen and sulfur mix with atmospheric

moisture, the acid rain produced can damage

plants and aquatic life. Ozone develops when

oxides of nitrogen react with hydrocarbons in

the presence of sunlight. Ozone aggravates

allergies, asthma and emphysema and impairs

overall lung function.

Because of the health and environmental risks

associated with PM10, both Nevada and the

federal government have established standards

to control ambient concentrations. In addition,

these pollutants have caused a noticeable

deterioration in visibility. Consequently, it has

become a priority to minimize pollutants in

order to maintain or improve visibility in and

around our nation’s most impressive vistas.

Applicability. This handbook outlines

voluntary guidelines that are useful tools for

successful smoke management in Nevada.

The voluntary guidelines contained within

this handbook apply to all agricultural fires

and are good practices to follow anywhere in

the State. In addition, counties, cities and

fire departments may have local ordinances

that restrict open burning. Therefore, you

should always check with local officials

before burning to ensure compliance.

WHAT IS AGRICULTURAL

BURNING?

Agricultural burning can be defined as the

burning of materials that are wholly produced

from growing and harvesting crops or raising

animals for the primary purpose of providing a

livelihood. In this handbook, we have divided

agricultural burning into four categories.

Crop Residue Burning. Crop residue burns

remove vegetative

debris from farming

operations. Fires used

to clear fields for

planting or seeding,

control disease or

pests, and/or improve crop propagation are

examples of crop residue burns.

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Ditch and Fence Line Burning. Ditch and

fence line burns are initiated to remove

weeds and other plants that collect along

ditches, drains, and fence lines. Burning

reduces the fire hazard and can improve

water management efficiency.

Rangeland Burning. This type of open

burning includes grasses, shrubs, trees, or

other vegetative matter burned to improve

rangeland. The Nevada Division of Forestry

conducts many rangeland burns and may be

able to assist you.

Land Clearance and Upkeep. Brush piles,

branches, stumps and other vegetative debris

removed while clearing new land or while

maintaining the property are included in this

category.

Burning that is not covered in this program.

We prohibit the burning of garbage, tires,

and any material containing plastics. When

burned, plastics are a major source of air

pollution, and much of the resulting

pollutants can have serious health

consequences. Bringing these types of

materials to a municipal dump is the

preferred option.

SMOKE MANAGEMENT

There are several methods of smoke

management most techniques involve

minimizing smoke production and burning

in conditions that allow smoke dispersal. In

this section we outline these methods and

tell you how to achieve good results with

specific types of burning (i.e. crop residue,

ditch and fence line, rangeland, and land

clearance and upkeep).

Smoke Reduction. The most effective

method of smoke reduction is the use of a

non-burning alternative. However, if you

decide that burning is necessary to achieve

your objectives, the vegetation will burn

hotter, more completely and produce less

smoke if it is dry, loosely stacked and

contains very little soil. Fuel moisture has

the biggest influence on combustion

efficiency and the amount of smoke

generated. This moisture must be boiled off

before the fire is hot enough to burn

efficiently. Because of its high moisture

content, green wood smokes more and burns

cooler. Loosely stacked material smokes less

because the flame is exposed to more air.

Conversely, dirt keeps air away from the

fuel causing it to smolder and generate

additional smoke.

Burning Hours. For best smoke dispersion,

it is preferable to start the burn after 10 am

and make sure it is completely out by 4 pm.

You probably have noticed a breeze moving

up hill in the morning and down hill in late

afternoon. The breeze is caused by thermal

updrafts that develop after the sun warms the

earth in the morning. The air near the ground

is warmer and less dense than the overlying

air causing it to rise like a hot air balloon.

When air cools, it becomes denser causing it

to flow down the side of the mountain in the

evening.

Late-morning ignition allows the ground to

heat up and the dew to evaporate, producing

less smoke and allowing the smoke produced

to rise. If you ignite late in the day, cooling

temperatures will hold the smoke close to the

ground and keep it there until

the following morning

when the sun starts the

thermal lift process again.

Following recommended

burning hours is one of the

easier methods to minimize smoke impacts on

yourself and the surrounding community.

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By lighting a test fire, you will be able to see

how well the material burns and where the

smoke is going. Wait a day if the fuel is too

damp, the smoke is not lifting or is blowing

towards a sensitive area such a school,

hospital, nursing home, airport, or recreational

area.

Burning days. Consider rescheduling your

burn if there is a high risk of wildfire or there

is a lot of smoke in the air. Additionally, it is

always a good idea to evaluate non-burning

alternatives. Ask yourself if you can

economically achieve similar results with

methods that do not require fire.

You may wish to limit burning activity on

weekends, holidays or when

nearby sporting activities are

scheduled. Limited burning

on these days can enhance the

quality of life, reduce

nuisance complaints and may

enhance tourism if near a popular recreational

area.

Ignition Techniques. Your ignition

technique has a big influence on the amount

of smoke produced. If burning a field, light

the fire at the downwind edge. Backfires

force the fire to creep into the wind allowing

greater fire control and more complete

combustion. This method produces fewer

particulates and does not leave smoking

patches behind that require additional

attention. The strip-fire method is a variation

of the backfire. Light the field in strips while

walking straight through into the wind.

Use an ignition device that does not produce

black smoke, such as butane, propane or

diesel oil burners. A burning tire is a poor

choice for an ignition device – this method

generates excess smoke and is dangerous.

Crop Residue Burning. Allow the crop

residue to dry as much as possible before

burning to reduce the amount of smoke. You

might allow 3 days for spread straw or 10

days for rowed straw depending on

conditions. The preferred ignition methods

are backfiring and strip-firing.

Ditch/Fence-Line Burning. Kill the grass

and/or weeds first and allow them to dry.

Once the material is dry and conditions are

favorable, use one of the preferred ignition

techniques discussed above if possible.

Rangeland Burning. Nevada Division of

Forestry regularly performs burns on

rangeland – they may be able to assist with

your burn. If you would like to perform the

burn yourself, ensure the fuels are dry,

control measures are in place and local

authorities are notified. Use one of the

preferred ignition techniques discussed

above.

Land Clearance and Upkeep. Stack the

material and allow it to dry. Prunings and

small branches may take three weeks. Allow

six weeks for large branches and stumps.

Arrange stacked material to allow air to

freely circulate. Allow the pile to breathe by

making smaller piles. Avoid pushing soil

into the pile.

BURN NOTIFICATION

Letting other burners know when you are

going to burn is key to effective smoke

management. The primary goal is not to

reduce the number of fires during the year, but

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to reduce those on a single day. Burning

activities can be coordinated through the

Bureau of Air Quality Planning or a local

coordination network. When neighbors

cooperate, you improve air quality and reduce

complaints. Regardless of whether you

coordinate your burning activity, it is helpful

to notify local fire officials before you burn.

Effective notification will prevent an

unnecessary emergency response to your

smoke plume.

Effective methods of notifying the public

include fliers at grocery stores and the local

Post Office, and press releases with the local

newspapers or television stations. These

notification actions can help prevent various

inconveniences and dangers on the part of the

public and local fire department.

Too frequently, people are injured or killed

due to reduced visibility when a dense smoke

plume drifts across the highway. Posting signs

and monitoring smoke on the roadway will

warn motorists of reduced visibility ahead.

Most agricultural burns in Nevada are less

than 50 acres per day1. Smoke impacts are

relatively small, but as with all open burns,

you should contact local authorities before

ignition. Local authorities may have additional

1 The Nevada Farm Bureau and Nevada Cattleman’s

Association helped the Bureau of Air Quality

Planning complete a survey of open burning on

private lands. This allowed us to assess the amount of

burning conducted each year by agriculture and what

impact it has on Nevada’s air quality. Based on the

survey response, a typical agricultural open burn is

around 5 acres and emits less than 1 Ton of PM10 per

day. A small percentage of the burns emit over 10

Tons PM10 per day.

requirements and notification will prevent a

needless response from the fire department.

For larger burns of 50 to 500 acres, or burns

that are closer to populated areas, a completed

one-page notice of your intent to burn is

appropriate. Notification will be most useful

if it precedes the projected burn date(s) by at

least two weeks.

A copy of the Bureau’s Notice of Open Burn

Activity and instructions are included with

this handbook. Please follow the instructions

and submit the notice via mail or fax to the

location provided with the Notice. Additional

copies of the notice of Open Burn Activity are

available at http://ndep.nv.gov/baqp/technical

/smoke.html or you may call the Smoke

Management Coordinator at (775) 687-9360

to have a copy mailed or faxed to you.

To alert the Bureau of your plans, please

notify the Bureau the day preceding the burn.

When notifying the Nevada Bureau of Air

Quality Planning, contact the Smoke

Management Coordinator at (775) 687-9360.

If no one is available, leave a message that

includes:

o The date

o Burner’s name

o Your phone number

o Burn location

o Date of burning

o The burn number – as shown on the

notice of burn activity

o Estimated acreage to be burned

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There may be rare instances when we will ask

you to postpone your burn until conditions

improve if you have poor air quality in the

area, a large burn is planned, or the weather

conditions will not dissipate the smoke. If you

do not receive a response by 5 pm on the day

before your burn, proceed with your burn.

For burns of 500 – 1500 acres per day, or

burns close to population centers and

roadways, a burn plan may be necessary. A

burn plan contains more detailed information,

such as:

1. The specific location and description of

the area to be burned;

2. The responsible personnel;

3. An emergency telephone number;

4. The property owner;

5. The agency/contractor conducting the

burn;

6. The burn prescription;

7. The number of acres to be burned, the type

of fuel, fuel loading estimates and the

ignition technique to be used;

8. A list of agencies and private parties

involved;

9. A map depicting the potential impact of

the smoke for 15 miles from the burn site.

Please delineate the daytime and nighttime

smoke path and smoke sensitive areas on a

map at a scale that allows identification;

10. A discussion of your public notification

procedures; and

11. An evaluation of alternative treatments.

For burns larger than 1500 acres or burns with

smoke sensitive receptors nearby, (such as

hospitals and schools) additional plans should

be made, including:

1. A smoke management plan that includes

actions taken to minimize emissions

before, during and after the fire;

2. An emissions estimate including the

models, methods and emission factors;

3. Safety and contingency plans;

4. A list of potentially impacted jurisdictions

and the names and telephone numbers of

the respective regulators; and

5. The type of air monitoring proposed.

We recommend contacting the air district

officer in Washoe or Clark County, an

adjacent state, or Indian Tribal Lands the day

before the burn, if the burn is within 15 miles

of the border. You also may wish to include

nearby agricultural burners. If the open burn is

coordinated through the Bureau, we will

notify the appropriate regulator for you.

ADDITIONAL INFORMATION

If you have any questions about the program,

health and environmental issues, burning

techniques, or you are interested in

establishing a local coordination network

please call the Nevada Bureau of Air Quality

Planning at (775) 687-9360, or visit our web

site at http://ndep.nv.gov/baqp/index.htm.

NDEP wishes to thank the Nevada Cattleman’s Association, Nevada Farm Bureau, Lovelock Smoke

Management Committee, the Nevada Department of Agriculture and the Nevada Conservation

Districts for their assistance and cooperation in preparing this handbook.

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Need More Information?

If you live outside Clark or Washoe County, and are not on Indian lands, call:

The Nevada Division of Environmental Protection


(775) 687-9360

If You Live in Washoe Co., Contact: Air Quality Management Division

District Health Department

PO Box 11130

Reno, NV 89502

(775) 784-7200

If You Live in Clark Co., Contact:

Clark County Department of

Air Quality

4701 W. Russell Rd Suite 200

Las Vegas, NV 89118

(702) 455-5942

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Instructions for the Notice of Open Burn Activity

1. Please fill out the notice completely.

2. Each burn incident will require its own notice. Burn plans may include all burns anticipated

for long term planning but each phase of the plan will need its own notice. ______________________________________________________________________________

Line-by-Line Instructions:

� Name: The business name and responsible person.

� Mailing Address: The mailing address if different from the street address.

� Phone: Include a FAX number if available.

� Organization Conducting The Burn: Enter organization name, contact person & phone number if

applicable.

� Location Of Burn: Enter the name of the farm/ranch, distance and direction from town or

landmark and township, range, & section if known.

� Burn Date(s): The dates you plan to burn at this location.

� Burn Duration: The start and completion times as well as total burn hours.

� Type of Open Burn: Crop residue, ditch/fence-line, rangeland or land clearance.

� Burn Material: The type of crop or other vegetation you intend to burn.

� Burn Acreage: The total acres you plan to burn with this notice.

� If the open burn is within 15 miles of the State Border, Washoe/Clark Counties or BIA Lands we

ask that you notify the air quality agency for that jurisdiction of your burn.

You may use additional sheets, but please insert “see attached” at the bottom of the first page if

additional sheets are necessary.

Notify this office or your local coordination network one working day before burning.

To Notify the Smoke Management Coordinator:

Call: (775) 687- 9360 (leave a message)

Monday through Friday 8:00 am to 5:00 pm

Nevada Division of Environmental Protection


901 S. Stewart Street

Carson City NV 89701

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NEVADA BUREAU OF AIR QUALITY PLANNING NOTICE OF OPEN BURN ACTIVITY

Name:

Mailing Address:

City, State, Zip Code:

Phone: (775) Fax: (775)

Organization Conducting

Burn:

Location of Burn: (Be Specific)

Burn Date(s):

Burn Duration (hrs): (Both Flame and smoldering phases)

Type of Burn: (Crop Residue, Ditch/Fence-line, Rangeland, Land

Clearance)

Burn Material: (Crop or Other Vegetation)

Burn Acreage:

Return application to: Nevada Division of Environmental Protection PHONE (775) 687-9360

Bureau of Air Quality Planning FAX (775) 687-6396

901 S. Stewart Street

Carson City, NV 89701

To be completed by BAQP No. 04-

CONCURRENCE

The Nevada Division of Environmental Protection recognizes your intention to conduct an open burn as described

above. This concurrence is limited by the following conditions: 1) All open burning will be attended and controlled at

all times to eliminate fire hazards; and 2) The concurrence is in effect from through

This authorization does not prohibit, in any way, the local fire department from extinguishing any fire if a hazard exists

or develops during the course of burning. The applicant may be required to comply with additional state and local laws

regarding air pollution and fire safety including obtaining required permits or approvals. Prudence requires reasonable

safety and air-pollution-control precautions before ignition. Please notify the Bureau of Air Quality Planning one (1)

working day before each burn. The fire department or fire warden may require prior notification of the time and place of

each fire.

Date: By:

December 19, 2014

Smoke Management Coordinator

Nevada Bureau of Air Quality Planning

Documents

WILDFIRE PM MITIGATION PLAN CARSON CITY AND … · Gardnerville Ranchos areas, and for particulate matter less than 10 micrometers in diameter (PM 10) for the Pahrump area (Figure