Wildland Fire Leadership CouncilMembership

USDA Undersecretary and DOI Associate Deputy Secretary (co-chairs)

Department of Defense, Assistant Secretaries (2)

FS and DOI Bureau Chiefs (BLM, FWS, NPS, BIA, USGS)

FEMA/USFA Administrator

Governor from the West

National Governors’ Association

National Association of Counties

National League of Cities

Intertribal Timber Council

International Association of Fire Chiefs

National Association of State Foresters

Wildland Fire Leadership Council

Mission

Dedicated to consistent implementation of wildland fire policies,

goals and management activities.

Provides strategic oversight to ensure policy coordination,

accountability and effective implementation of long-term

strategies.

“Safely and effectively extinguish fire, when needed; use fire where

allowable; manage our natural resources; and as a nation, live with

wildland fire.”

All Hands – All Lands

• Restore Resilient Landscapes: Landscapes across all jurisdictions are resilient to fire-related disturbances in accordance with management objectives

• Fire Adapted Communities: Human populations and infrastructure can withstand a wildfire without loss of life and property

• Wildfire Response: All jurisdictions participate in making and implementing safe, effective, efficient risk-based wildfire management decisions

PFCs key partners: fire unites…Passionate professional, committed group of prescribed fire practitioners.

Federa

l

StatePrivate

“building

partnerships

around fire”

3%

69%

28%

2014 Forestry & Agricultural Prescribed Fire Activity by Region

Northeast

Southeast

West

Capacity ConcernsLimited personnel, training, private contractor availability,

partnerships, equipment

Weather Concerns Narrow burn windows, drought, available burn days

Air Quality/Smoke Management

Concerns

Visibility, nuisance, emission impacts

Resource Concerns Limited funding, high implementation costs

Public Perception Concerns Lack of public understanding/acceptance

Liability/Insurance Concerns Landowner liability, insurance availability and/or cost

Permitting/Legal Concerns State law, burn bans, local restrictions, NEPA process, ESA

WUI/Population Growth Concerns Urbanization, influx of new residents

Low Priority Agency or landowner priority, too difficult

0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

Pe

rce

nt

of

Re

spo

nse

s

Top Impediment Limiting Prescribed Fire Use - West Ranking

West

National

WILDLAND FIRE AIR QUALITY: 2017 LESSONS &

OPPORTUNITIES

Presented by Pete LahmForest ServiceFire & Aviation ManagementWashington Office202-205-1084 // 602-432-2614 Cell

Partners in this effort: USFS, NPS, NOAA NWS, EPA,

State and local agencies

Living with Smoke and Fire• Wildfires single biggest source of high-level air quality impacts (in U.S.)

• Single wildfires and multiple regional wildfires are known to cause significant impacts to millions

• Health, Safety, Economics, Disruption of Life, Children/School/Athletics impacts• Long durations of high levels of pollutants • Can contribute to fatal traffic accidents

• Public impacts of smoke: 1 in 3 households has someone with respiratory issues, E.g. children with asthma, COPD, emphysema

• Wildland fires contributing to more than 32% of US fine particulate matter (PM2.5) based on the EPA’s 2011 National Emission Inventory (40% if newer emission factors had been used)

2017 was the Summer of Smoke – NPR, Washington Post, Congressional Hearing Focus

NY Times – “What to Know Before Buying an Air Purifier to Clear Wildfire Smoke”

Wildland Fire Air Quality Response Program• Interagency response (2011-Present)

• Operationally addressing wildfire smoke

• Public health

• Transportation safety

• Fire personnel exposure

• Four components:

• Modeling

• Monitoring

• Messaging / Communication

• Air Resource Advisors (ARA)

• Active Coordinated Response

• Integration / coordination

• EPA, NOAA, NASA, CDC, States, and beyond

BlueSky Production Run Domains

Smoke specialists deployed as part of an Incident Management Team (THSP in ICS)

Roughly 48 ARA’s and 24 trainees

Highly diverse group: FS, BLM, NPS, FWS, EPA,

State Forestry, Tribes, NRCS, County FD and AD’s.

Backgrounds: Wildland Fire, Air Quality, meteorology

Training: Annual 2013-2017, 2018 planned

Enables: Reduction of exposure through behavior

modification (public or personnel)

• Allows incident information to be made available for modeling, etc…to develop smoke outlooks and other documents for communications

• Works with state/tribal/local air quality regulatory agencies, public health departments and impacted communities 0

10

20

30

40

50

60

2010 2011 2012 2013 2014 2015 2016 2017

ARA Deployments by Year

Air Resource Advisors

2017

2017 WFAQRP Efforts• Over 100 ARA deployments, 50% multi-fire outlooks

• More than 1100 Smoke Outlooks, 3000 smoke trajectories

• Outlook aligns with EPA’s AQI and Nowcast

• Many state regulatory agencies very engaged in 2017

-Some State Forestry engagement on smoke issues

-Much greater health department engagement

• Challenges in messaging consistency • (1 hr impacts vs Nowcast)

ARA Deployment Map

Moving Forward…• Continued dialogue and work with EPA and CDC on smoke

• Some EPA rules likely need further exploration.

• 100’s of wildfire exceedances for PM2.5 in the west = high Exceptional Event Rule demonstration load for states & EPA

• Unaware of any western prescribed fire EER demos to date…

• Opportunity to discuss best approaches in advance of prescribed fire increases or an exceedance

• General Conformity Rule needs update for consistency

• Critical relationships are with state and local regulators

• Increasing prescribed fire use will need greater commitment to addressing smoke by land managers. Local specialists or part of the job of fire practitioners.

• NWCG requires RX-410 for all RXB2’s (2017 change from previous policy)

• Basic Smoke Management Practices – 2 year window to determine as community what practices are “appropriate”

• Example efforts are the CA Fire MOU Partnership aimed at addressing fuels, AQ and using prescribed fire

• Public Health Department engagement???

• Smoke-Ready Communities and a Smoke-Wise Public

• Transportation and smoke concerns

• Regional Haze Rule – opportunity to include prescribed fire in endpoint of glide path to natural conditions

• Clarity on perceptions of what can be changed in state Smoke Management Plans that have been submitted as part of a State Implementation Plan

Living with smoke from wildland fire is a key of the future discussion.

Prescribed Fire, Smoke Management and Air Quality

Regulations

Prescribed Fire: Smoke Management and Regulatory Challenges

WGA Webinar

December 19, 2017

WESTAR and WRAP region

What is important to know about Exceptional Events?

• Clean Air Act and EPA regulations rely heavily upon monitored air quality data to characterize the attainment of National Ambient Air Quality Standards.

• The Clean Air Act recognizes that some monitor data may not be appropriate to characterize the air quality of a city or region when that data is influenced by “exceptional” events that are not otherwise controllable. Events may be human-caused or natural.

• EPA has developed a regulation specifying how states may identify monitor data influenced by exceptional events, exclude that data and protect public health from unhealthy levels of air pollution during these events.

Prescribed Fire and the EPA Exceptional Events Rule Definitions

• Wildland means an area in which human activity and development are essentially non‐existent, except for roads, railroads, power lines, and similar transportation facilities. Structures, if any, are widely scattered.

• Prescribed Fire is any fire intentionally ignited by management actions in accordance with applicable laws, policies, and regulations to meet specific land or resource management objectives. A prescribed fire is a human-caused event that is eligible for treatment as an exceptional event.

• Wildfire is any fire started by an unplanned ignition caused by lightning; volcanoes; other acts of nature; unauthorized activity; or accidental, human‐caused actions, or a prescribed fire that has developed into a wildfire. A wildfire that predominantly occurs on wildland is a natural event and is eligible for treatment as an exceptional event.

Exceptional Events rule provisions for prescribed fire

• Rule recognizes the need for and benefits of prescribed fire

• Rule criteria looks for:• clear causal relationship,

• human activity unlikely to recur – recurrence is either the natural fire return interval OR the fire frequency needed to establish, restore and/or maintain a sustainable and resilient wildland ecosystem (as documented in a land/resource management plan),

• Not reasonably preventable, and

• Not reasonably controllable – fire conducted under a certified and implemented Smoke Management Program or using basic smoke management practices.

Exceptional Events Rule Requirements for Prescribed Fire

• Land managers, burn managers and air agencies must collaborate regarding the process by which the agencies will work together to include general expectations for selection and application of appropriate Basic Smoke Management Practices

• Land/Resource Management Plans can be relied upon to address recurrence and not reasonably preventable provision

• Requirements of rule apply equally to federal, public and private landowners

Roles and Responsibilities under the Exceptional Events Rule

• Burn manager/agency can provide fire‐specific information (e.g., emissions, acres burned, meteorology, modeling, communication and outreach, etc.)

• Air agency and/or FLM can assess regulatory significance and the usefulness of getting EPA approval for data exclusion

• Air agency and/or FLM can prepare the technical demonstration, which involves several data gathering and analysis tasks

• Air agency is responsible for initial notification to EPA, deciding (with EPA input) whether to submit a demonstration, and submitting the prepared demonstration and/or endorsing the FLM’s submission

What are Smoke Management Plans?

• State-developed plans for states to receive information about burning events and smoke emissions and implement measures to reduce public health impacts from prescribed burning.

• States may develop plans for Exceptional Events or other regulatory requirements, such as regional haze.

• Smoke Management Plans are unique to each states’ needs, may not cover all of the areas of the state and don’t broadly restrict burning.

• Not all western states have smoke management plans.

• Smoke management plan development and implementation is at the state-level. Some states use their air quality state implementation plan to formally adopt a plan, but this is not required.

Smoke Management Plan Elements

• Authorization to burn process

• Requirement to consider alternatives to burning and minimize air emissions from prescribed burning to limit impacts to public health

• Requirement for submission of burn plans• Methods to minimize emissions• Plans to evaluate dispersion• How the public will be notified• How public exposure will be reduced• How burning emissions will be monitored

• Public Education and Awareness of smoke emissions

• How the agency will provide surveillance and enforcement for authorizations

• Program Evaluation for effectiveness on a periodic basis

Fire and Smoke Challenges for Air Quality Managers

• Longer, more intense, and larger fires contributing smoke to monitored air pollution

• Large fires transport smoke well away from the immediate area of the fire, reaching other jurisdictions and impacting public health

• For particulate air quality, exposure to smoke is a chronic as well as an acute issue

• Applications of even small prescribed fires can leave smoke in western valleys under stagnant air conditions on the “day(s) after”, even when dispersion conditions are good on the day of the prescribed fire activities

• Even so:

• There are excellent relationships in place for land managers with air managers through smoke mgmt. programs to deal with prescribed fire.