Fire Emissions Joint Forum: Section 309 Requirements Continued…

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Fire Emissions Joint Forum: Section 309 Requirements Continued…

-Enhanced Smoke Management Programs

-Annual Emission Goals for Fire

-Fire Tracking Systems

-Unfinished Business

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FEJF Recognition ESMP

Mike Ziolko – OR DF Ann Acheson – USFS

AEG Frances Bernards – UT DAQ

FTS Darla Potter – WY DEQ

Facilitation–Rebecca Reynolds INC.

The Forum and Outer Circle

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WRAPEnhanced Smoke Management Programs for Visibility Policy

-Policy Statements Approved by Conference Call

-WRAP Action: ESMP Full Policy Document

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ESMP Policy

Policy Statement Modifications Some minor modifications

were made to two of the Policy Statements in response to comments received since the last WRAP meeting

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ESMP Policy Statement A New Text:

Enhanced smoke management programs under this Policy are defined as those smoke management efforts that specifically address visibility effects, and therefore, may need to be augmented to address public health and welfare issues.

Previous Text:Enhanced smoke management

programs are defined as smoke management efforts that specifically address visibility effects.

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Policy Statement A Rationale for Change:

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

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Policy Statement D New Text:

Enhanced smoke management programs are a viable tool for all other states and tribes in the WRAP region to use in the development of their implementation plans.

Previous Text: Enhanced smoke management

programs are a viable tool for states under Section 308 to use in their SIP development, and for tribes to use in their TIP development.

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Policy Statement D

Rationale for Change: The viability of the enhanced

smoke management program as a tool to use in managing smoke impacts on visibility exists for all states and tribes in the WRAP region, regardless of whether they are under Section 308 or not.

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ESMP Text and Report

Text Revisions Address: IOC and TOC comments Directed Reviewer comments FEJF final review comments Documentation of Comments

and Responses available on Web or Policy Documentation Package

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WRAP Policy

Annual Emission Goals for Fire

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Introduction

WRAP Policy on Annual Emission Goals for Fire provides states/tribes with a tool for addressing regional haze in mandatory Federal Class I Areas

Required for Section 309 Control Approach for Section

308.

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AEG Policy Major Points of Agreement

Annual Emission Goals are “goals” not “limits”

Emission Reduction Techniques (ERTs) are the basis of the Annual Emission Goal

ERTs as defined do not include Non-Burning Alternatives

SIP/TIP submittal is the Process of setting an AEG

SIP/TIP is NOT a number

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Goal versus Limit GCVTC intent:

Recommendations use “goal”, “target” and “cap” – both target and cap are defined as emissions limits (cap has regulatory consequences, target does not)

Goal is a desired future condition that may be represented by a numeric indicator (i.e., quantifiable)

RHR uses GCVTC language Not currently possible to institute a

limit (Science issues & WRAP-wide consistency question)

AEG is quantifiable, but not a limit

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ERTs as Basis of AEG “Minimize emission increases”:

RHR focus is emission reduction where possible

ERTs are proven to reduce emissions

The effort to reduce emissions through the use of ERTs is what will be quantified by the AEG, rather than the result of using them

This is a practical & effective method that will work NOW

Process to address choice of 2 tons of PM2.5/acre vs. 1 ton/acre

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ERTs Defined ERTs are methods that control fire

emissions; e.g., biomass utilization prior to burning, high fuel moisture, increasing combustion efficiency

Control measures (ERTs) are distinct from smoke management techniques; e.g., the timing of ignitions for better smoke dispersion

ERTs are evaluated and used on a project-specific ANNUAL basis, i.e. in areas that have been designated for the application of fire. Areas where an alternative to fire will be used, do not involve ERTs & are not part of the AEG

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Policy Statement A

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

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Policy Statement ARationale Section 309 requires:

“establishment of annual emission goals for fire (excluding wildfire) that will minimize emission increases from fire to the maximum extent feasible.” (64 FR 35771 Section 51.309(d)(6)(v))

Policy can be considered by non-309 states and tribes as means for controlling fire emissions as needed

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Policy Statement B

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

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Policy Statement BRationale

GCVTC Report/RHR recognized land managers’ projection of significant increases in prescribed fire to reduce effects of wildfire

GCVTC recommended the establishment of annual emission goals to minimize emissions

A goal has a numeric measure but distinct from a limit

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Policy Statement C

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

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Policy Statement CRationale RHR/GCVTC acknowledged that

all types of fire must be addressed in visibility protection strategy

RHR/GCVTC: Include all fire (except wildfire) is a practical approach to this Policy

Policy does not apply to Native American cultural non-vegetative burning

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Policy Statement D

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

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Policy Statement: DRationale Projected increase in fire activity

will result in episodic impacts on visibility

AEG Policy focuses on strategy for minimizing impacts through reduction of fire emissions on project specific basis

ERTs are proven method for reducing fire emissions

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Policy Statement DRationale 2 AEG Policy applies when fire

has been chosen as means to meet land management objectives

There are various ways to establish an annual emission goal based on ERTs: this Policy offers two example approaches

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Policy Statement E

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

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Policy Statement ERationale Per the GCVTC and WRAP Fire

Categorization Policy: Recommendations, economic, safety, technical and environmental considerations are included in this AEG Policy

Land management objectives were added as criterion to ensure that ERTs are used appropriately

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Policy Statement F

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

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Policy Statement FRationale “Establishment of annual

emission goals for fire … that are established in cooperation with States, tribes, Federal land management agencies, and private entities.” (64 FR 35771 Section 51.309(d)(6)(v))

Coordination is key for addressing regional haze in WRAP region

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Policy Statement G

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

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Policy Statement GRationale Tracking provides the means to

achieve verification (checks & balance)

Tracking can also provide a basis for the annual review and possible revision

Basis for five year SIP review

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Revisiting Annual Emission Goals Beginning in 2008, 309 states/tribes

are required by RHR to submit periodic reports to EPA. Periodic reports are due every five years subsequently.

Policy encourages state/tribes to refine annual emission goal as advances in research and development are made

E.g., emission limits may be possible and needed for Further Reasonable Progress

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AEG PolicyReviewer Comments

Document sent to over 100 potential reviewers including:

Website Posting, IOC, TOC, FEJF, Requested, & ESMP Reviewer List

Eight (8) Reviewers submitted comments to date

Representing: five (5) states one (1) industry one (1) USFS one (1) Western State Forestry Council

Discussion with Tribal Caucus – comments to be addressed

Comment Period Now Closed

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AEG Comment: Goal Definition Accepted Goal Definition Asked for some strengthening

language to support the intent and implementation of the AEG: AEG process is enforceable

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AEG Comment: Non-Burning Alternatives

Still some confusion about the definition of non-burning alternatives (are they ERTs?)

Still some confusion as to how ERTs drive the AEG (project-specific basis)

Still some confusion as to how non-burning alternatives fit vis-à-vis all 309 products

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Unfinished Business… Section 309 – Assess and

remove administrative barriers to the use of non-burning alternatives

Four WRAP Policies which may include non-burning alternatives

Agricultural Non-Burning Alternatives Report – Final

Wildlands Non-Burning Alternatives Report - Draft

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Alternatives to Burning - FEJF White Paper Address Alternatives to Burning

issues in one document to assist states/tribes

Brainstorm on approaches to address assessment of administrative barriers, document FEJF efforts to date and address interaction of non-burning alternatives with WRAP Policies