vv EPA
United Slates
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-450/2-92-003
September 1992
Air
PRESCRIBED BURNING
BACKGROUND DOCUMENT AND
TECHNICAL INFORMATION
DOCUMENT FOR PRESCRIBED
BURNING BEST AVAILABLE
CONTROL MEASURES
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EPA-450/2-92-003
PRESCRIBED BURNING BACKGROUND DOCUMENT
AND TECHNICAL INFORMATION DOCUMENT FOR
BEST AVAILABLE CONTROL MEASURES
U.S. Environmental Protection Agency
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
September 1992
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Disclaimer
This document reflects the latest information that the
Environmental Protection Agency (EPA) has obtained on measures
for management of prescribed burning smoke emissions. As
additional information becomes available, the document will be
updated, as appropriate. Mention of trade names or commercial
products is not intended to constitute endorsement or
recommendation for use.
Copies
Copies of this document are available through the Library
Services Office (MD-35), U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina 27711; or, for a fee, from
the National Technical Information Services, 5285 Port Royal
Road, Springfield, Virginia 22161.
September 1992
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TABLE OF CONTENTS
-1.0 INTRODUCTION
1.1 Purpose of this Document i-l
1.2 Statutory Background ........... 1-2
1.2.1 Designations . 1-2
1.2.2 Classifications ~ ... . . . . . . . . 1-2
1.2.3 Serious Area Attainment Dates .... 1-4
1.2.4 Key Serious Area SIP Requirements . . 1-4
1.2.5 RACM and BACM Issuance 1-5
1.3 Document Organization 1-7
2.0 PRESCRIBED BURNING
2.1 Introduction 2-1
2.2 Objectives of Prescribed Burns 2-2
2.2.1 Hazard Reduction 2-2
2.2.2 Site Preparation 2-3
2.2.3 Wildlife Habitat Improvement .... 2-3
2.2.4 Range (Forage) Improvement 2-3
2.2.5 Disease and Insect Control . . . . . 2-3
2.2.6 Ecosystem Maintenance ....... 2-3
2.3 Geographic Distribution of Prescribed
Burning : . . . 2-4
2.3.1 Prescribed Forest and Rangeland
Burning 2-4
2.3.2 Prescribed Agricultural Burning . . 2-5
2.4 Emissions from Prescribed Burning 2-15
2.4,1 Emission Estimates 2-15
2.4.2 Relationship to PM-10 Nonattainment
Areas 2-19
iii September 1992
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. 2.5 Regulation of Prescribed Burning . . . . . 2-24
2.6 References 2-26
3.0 SMOKE DISPERSION EVALUATION
3.1 Introduction ................ 3-1
3.2 Smoke Dispersion Evaluation Methods .... 3-1
3.2.1 Weather Categorization Models . . . 3-1
3.2.2 Smoke Dispersion Computer Models . . 3-7
3.3 State Programs ..... 3-11
3.3.1 Arizona 3-12
3.3.2 California 3-14
3.3.3 Montana 3-15
3.3.4 North Carolina 3-20
3.3.5 Oregon . . . . v 3-20
3.3.6 Washington . 3-27
3.4 Effective Implementation Strategy 3-31
3.5 References 3-35
4.0 BURN PLANNING, AUTHORIZATION, AND ADMINISTRATION
4.1 Introduction ......... 4-1
4.2 Requests for Permission to Burn 4-1
4.2.1 Arizona ....... 4-2
4.2.2 California 4-3
4.2.3 Colorado 4-5
4.2.4 Montana 4-6
4.2.5 North Carolina 4-7
4.2.6 Oregon 4-7
4.3 Evaluation of Burn Requests 4-9
4.4 Granting Approval to Burn 4-10
4.4.1 Arizona 4-10
4.4.2 California 4-11
4.4.3 Colorado 4-12
4.4.4 Montana 4-13
4.4.5 North Carolina 4-14
4.4.6 Oregon 4-15
4.4.7 Washington 4-18
4.5 Effective Implementation Strategy 4-19
4.5.1 Burn Requests ........... 4-19
iv September 1992
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4.5.2 Evaluation of Burn Requests .... 4-22
4.5.3 Approval to Burn 4-22
4.6 References 4-25
5.0 REQUIREMENTS FOR ENSURING BURNER QUALIFICATIONS
5.1 Introduction 5-1
5.2 Personnel Organization .... 5-2
5.2.1 Project Coordinator . . . . . . . . 5-2
5.2.2 Prescribed Fire Manager 5-2
5.2.3 Burn Boss 5-7
5.2.4 Fire Behavior and Weather
Specialist 5-7
5.2.5 Ignition Boss/Specialist 5-7
5.2.6 Holding Boss/Specialist 5-8
5.2.7 Mop-Up Boss/Specialist . 5-8
5.2.8 Crew Member 5-8
5.3 Necessary Skills and Qualifications .... 5-8
5.4 Federal Burner Qualification Programs . . . 5-10
5.4.1 The Bureau of Land Management . . .5-10
5.4.2. The National Park Service/Bureau
of Indian Affairs 5-11
5.4.3 U.S. Forest Service 5-19
5.5 Effective Implementation Strategy ..... 5-21
5.6 References . . . . . . . 5-24
6.0 PUBLIC EDUCATION AND AWARENESS PROGRAM
6.1 Introduction 6-1
6.2 Informing the General Public . 6-1
6.3 Informing the Burn Community 6-2
6.4 PE&A Techniques 6-3
6.4.1 Direct Public Contact/Public
Education Media 6-3
6.4.2 Broadcast Medium . .'. . 6-6
6.4.3 Print Medium 6-7
6.5 Program Implementation 6-13
6.5.1 Minimum Level of Effort Use of
One Medium Only . . . . . . . . . . 6-15
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6.5.2 Medium Level of Effort Broadcast
Plus Public Contact 6-15
6.5.3 High Level of Effort Multi-
media/Extensive Effort ....... 6-17
6.6 References . . . . 6-19
7.0 SURVEILLANCE AND ENFORCEMENT
7.1 Introduction 7-1
7.2 Surveillance . . 7-2
7.2.1 Colorado ..... 7-3
7.2.2 Montana ..... 7-5
7.2.3 North Carolina ..... 7-5
7*2.4 Oregon ..... 7-5
7.3 Enforcement ............ 7-9
7.3.1 Arizona ..... 7-10
7.3.2 California ...... 7-10
7.3.3 Colorado 7-n
7.3.4 Florida 7-11
7.3.5 Georgia 7-12
7.3.6 Oregon 7-12
7.3.7 South Carolina 7-16
7.3.8 Virginia 7-16
7.3.9 Washington 7-17
7.4 Complaints 7-18
7.5 Effective Implementation Strategy 7-20
7.5.1 Monitoring 7-20
7.5.2 Enforcement Program 7-21
7.5.3 Complaints . '7-22
7.6 References 7-23
8.0 EMISSION INVENTORY SYSTEMS
8.1 Introduction . 3-1
8.2 Emission Inventory Approach _8-l
8.2.1 Activity Level s-2
8.2.2 Emission Factors 8-12
8.3 State Programs 8-12
8.3.1 Slash Burning Emission Inventory
System . 8-12
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8.3.2 Colorado Department of Health . . . 8-18
8.4 Effective Implementation Strategy 8-18
8.5 References 8-22
,0 EMISSION REDUCTION TECHNIQUES
9.1 Introduction 9-1
9.2 Emission Production 9-2
9.2.1 Stages of Combustion ........ 9-2
9.2.2 PM-10 Emissions Generation ..... 9-4
9.3 General Emission Reduction Techniques . . . 9-5
9.3.1 Reduce the Number of Acres Burned . 9-7
9.3.2 Reduce Pre-Burn Fuel Loadings ... 9-8
9.3.3 Reduce Fuel Consumption 9-9
9.3.4 Lower Applicable ^Emission Factor . . 9-11
9.4 Emission Reduction Techniques -
Agricultural Burning 9-12
9.4.1 Reduction in Acres Open Burned . . . 9-12
9.4.2 Factors Affecting Preburn Fuel
Loading, Fuel Consumption, and
Emission Factors 9-26
9.5 Emission Reduction Techniques - Wildland
Burns 9-29
9.5.1 Methods to Reduce Acres Burned . . . 9-30
9.5.2 Reduction is Pre-Burn Fuel Loading . 9-40
9.5.3 Reduction in Fuel Consumption . . . 9-42
9.5.4 Methods to Lower the Applicable
Emission Factor . 9-45
9.6 Incorporation of Emission Reduction Techni-
ques, in State Laws, Smoke Management Guide-
lines, and Memoranda of Understanding . . . 9-52
9.6.1 Alabama ...... 9-53
9.6.2 California 9-54
9.6.3 Colorado 9-56
9.6.4 Florida 9-56
9.6.5 Montana 9-56
9.6.6 New Jersey 9-57
9.6.7 Oregon ...... . 9-59
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9.6.8 Utah 9-59
9.6.9 Virginia . 9-60
9.6.10 Washington . ..... 9-60
9.7 Effective Implementation Strategy ...... 9-61
9.8 References ..... 9-64
10.0 STATE OVERSIGHT
10.1 Introduction 10-1
10.2 Smoke Management Implementation
Responsibilities 10-1
10.3 Coordination of Responsibilities 10-3
10.4 Effective Implementation Strategy .... 10-17
10.5 References 10-19
11.0 COSTS OF AVAILABLE SMOKE MANAGEMENT PROGRAM FOR
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PRESCRIBED BURNING
11.1 Introduction . . . 11-1
11.2 General Cost Assessment of Prescribed
Burning ll-l
11.3 Components and Cost 11-2
11.3.1 Smoke Dispersion Evaluation .... 11-2
11.3.2 Costs to Burner 11-4
11.3.3 Costs to the State 11-7
11.3.4 Burning Planning, Authorization,
and Administration 11-7
11.3.5 Public Education and Awareness
Program "... 11-9
11.3.6 Burner Qualifications ...... ll-ll
11.3.7 Surveillance and Monitoring . . . ll-ll
11.3.8 Emission Inventory . 11-13
11.3.9 Emission Reduction Techniques . . 11-13
11.3.10 Emission Reduction Techniques -
Agricultural Burning . .. . . . 11-15
11.3.11 Factors Affecting Preburn Fuel
Loading, Fuel Consumption and
Emission Factors . 11-18
11.3.12 Emission Reduction Techniques -
Forestry Burning . 11-20
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11.3.13 State Oversight 11-31
11.4 References ..... 11-34
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LIST OF TABLES
Page
2-1 Number of Forest and Rangeland Acres -
Burned, by State ; 2-6
2-2 Distribution of Forest and Rangeland Acres Burned
by Resource Management Objective ........ 2-8
2-3 Estimated Agricultural Acres Burned and
Principle Crops, by State 2-11
2-4 Estimated PM-10 Emissions from Prescribed Forest
and Rangeland Burns, by State 2-17
2-5 Prescribed Burning Acres and^Emissions vs.
Nonattainment Areas ....... 2-21
3-1 Meteorological Criteria for Determining
Permissive Burn Days for Agricultural Burning,
Selected Air Basins in California 3-16
3-2 Daytime Burn Category Forecasts, North
Carolina 3-21
3-3 Total Available Tons of Fuel Allowable Per
16,000 Acres for Forestry Burns in North
Carolina 3-22
3-4 Regulatory Criteria Limiting Field Burning in
Willamette Valley, Oregon 3-25
3-5 Meteorological Conditions Restricting Slash
Burning in Oregon 3-28
3-6 Summary of Slash Burning Restrictions for
Smoke Control, Washington 3-29
5-1 Responsibilities of Typical Prescribed Burn
Team Members 5-4
5-2 BLM Standards for Prescribed Burn Positions . . 5-12
5-3 Prescribed Fire Positions and Skills, Training
Courses, and Qualifications Needed for
Certification, National Park Service/Bureau
of Indian Affairs 5-16
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5-4 Service-Wide Minimum Prescribed Fire
Skill/Knowledge Elements Table, U.S. Forest
Service 5-^20
6-1 Strengths and Weaknesses of Three Different
Public Information Media 6-4
6-2 Three Levels of Hypothetical Public Awareness
Program Elements 6-16
8-1 Steps for Developing an Emission Inventory
System ..... 8-14
9-1 Emission Factors for Particulate Matter As A
Function of Fire Behavior 9-13
9-2 General Applicability of Emission Reduction
Techniques to Wildlands Burn ^Objectives .... 9-31
11-1 Cost Elements 11-3
11-2 Parameter Values for Rescheduling a Burn .... 11-6
11-3 Costs for Smoke Dispersion Evaluation . . . . . 11-8
11-4 Costs for Burn Planning, Authorization, and
Administration ll-io
11-5 Costs for Public Education and Awareness
Program 11-12
11-6 Costs for Burner Qualifications . . . .'. . . 11-12
11-7 Costs for Surveillance and Monitoring .... 11-14
11-8 Costs for Emission Inventory 11-14
11-9 Emission Reduction Techniques for
Agricultural Burning .... 11-21
11-10 Costs for Use of Explosives 11-24
11-11 Costs for Increasing the Fuel Moisture Content
for Forestry Burns 11-26
11-12 Costs of Helitorch Ignition 11-28
11-13 Cost of Reducing Mop-Up Times ........ 11-32
11-14 Emission Reduction Techniques for Forestry
Burning 11-33
11-15 Costs for State Oversight '. . 11-33
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LIST OF FIGURES
Page
2-1 Estimated Acres of Prescribed Forest and
Rangeland Burns, by State 2-7
2-2 Seasonal Distribution of Forest and Rangeland
Acres Burned, by EPA Region 2-10
2-3 Counties with More than 10,0(30 Acres of
Agricultural Residues Burned .......... 2-13
2-4 Estimated PM-10 Emissions from Prescribed Forest
and Rangeland Burns, by State ......... 2-18
2-5 Seasonal Distribution of PM-10 Emissions from
Prescribed Forest and Rangeland Burning,
by EPA Region 2-20
3-1 Visible Indicators of a Stable Atmosphere ... 3-5
3-2 Visible Indicators of an Unstable Atmosphere . . 3-5
3-3 Operational Flow Cnart, Montana 3-19
5-1 Personnel Used in Typical Prescribed Burn . . . 5-3
6-1 Rice Burner Brochure from California 6-9
7-1 Willamette Valley Field Burning Air Monitoring
Network 7-7
8-1 Activity Level Component Accuracy Matrix .... 8-9
8-2 Component Matrix Example 8-9
8-3 Draft Update Smoke Management Reporting System
Coding Sheet 8-16
8-4 Activity Level Component Accuracy Matrix for
Prescribed Slash Burning in Western Oregon . . . 8-19
9-1 Stages of Combustion During a Prescribed Forest
Burn 9-3
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9-2 Typical PM-10 Emission Yields from Prescribed
Forest Burning .... 9-6 IB
9-3 Air Curtain Destructor 9-39
10-1 Colorado Memorandum of Understanding ....... 10-5
10-2 Northern Sierra AQMD Memorandum of Under-
standing ..... 10-7
10-3 Montana Memorandum of Understanding 10-10
10-4 Idaho Memorandum of Understanding 10-12
xiii September 1992
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1.0 INTRODUCTION
1.1 PURPOSE OF THIS DOCUMENT
The purpose of this document is to provide technical
information on prescribed burning. It does so in two ways.
One, it provides background information useful in
determining reasonably available control measures (RACM) and
best available control measures (BACM) for prescribed
burning as required under section 190 of the Clean Air Act
(Act) as Amended in 1990. Two, it provides guidance on
effective implementation strategies for each component of a
smoke management program available* for the development of
BACM strategies for prescribed burning in areas that are
designated serious nonattainment for PM-10 (particles with
an aerodynamic diameter less than or equal to a nominal 10
micrometers). The information is needed by States to
develop control strategies for their serious PM-10
nonattainment area State implementation plan (SIP)
submittals.
Note that while the guidance presented herein lists
available measures which the Environmental Protection Agency
(EPA) is recommending as BACM, and is intended to be
comprehensive, it is by no means exhaustive. It also does
not establish any binding requirements. Consequently, the
State is encouraged to consider other sources of information
and is not precluded from selecting other measures and
*Nothing in a smoke management program available for
area-specific BACM strategies is intended to influence
vegetation management or fire suppression practices so as to
increase the potential for wildfires to the point that
natural resources or public safety are compromised.
1-1 September 1992
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demonstrating to the public and EPA that they constitute
BACH.
1.2 STATUTORY BACKGROUND
1 ..2.1 Des ignat ions
Section -107(d) of the Clean Air Act (Act), as amended
in 1990, provides generally for the designation of areas of
each State as attainment, nonattainment or unclassifiable
for each pollutant for which there is a national ambient air
quality standard (NAAQS). Certain areas meeting the
qualifications of section 107(d)(4)(B) of the amended Act
were designated .nonattainment for PM-10 by operation of law
upon enactment.of the 1990 Amendments to the Act (initial
Xv
PM-10 nonattainment areas). A Federal Register notice
announcing all of the areas designated nonattainment for
PM-10 at enactment and classified as moderate was published
on March 15, 1991 (56 FR 11101). A follow-up notice
correcting some of these area designations was published
August 8, 1991 (56 FR 37654). The boundaries of the
nonattainment areas were formally codified in 40 CFR
Part 81, effective January 6, 1992 (56 FR 56694, November 6,
1991). All those areas of the country not designated
nonattainment for PM-10 at enactment were designated
unclassifiable [see section 107(d)(4)(B)(iii) of the amended
Act].
1.2.2 Classifications
Once an area is designated nonattainment, section 188
outlines the process for classification of the area. In
accordance with section 188(a), at the time of designation,
all PM-10 nonattainment areas are initially classified as
moderate by operation of law. A moderate area can
subsequently be reclassified as a serious nonattainment area
under two general conditions. First, EPA has general
discretion under section 188(b)(l) to reclassify a moderate
area as a serious area at any time the Administrator of EPA
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determines the area cannot practicably attain the NAAQS by
the statutory attainment date for moderate areas. Second,
under section 188(b)(2) a moderate area is reclassified as
serious by operation of law after the statutory attainment
«
date has passed if the Administrator finds that the area has
not attained the NAAQS. The EPA must publish a Federal
Register notice identifying the areas that have failed to
attain and were reclassified, within 6 months following the
attainment date [see section 188(b)(2)(B)].
Section 188(b)(l)(A) mandates an accelerated schedule
by which EPA is to reclassify appropriate initial PM-10
nonattainment areas. The EPA proposed on November 21, 1991
(56 FR 58656) to reclassify 14 of tjhe 70 initial moderate
areas as serious. The final decision to reclassify the
areas proposed will be based on the criteria utilized in the
proposal, comments received in response to the proposal and
on information in the moderate area SIP's that were due on
November 15, 1991 for each of the areas.
In the future, EPA anticipates that, generally, any
proposal to reclassify an initial PM-10 nonattainment area
before the attainment date will be based on the State's
demonstration that the NAAQS cannot practicably be attained
in the area by December 31, 1994 [the statutory attainment
date specified in section 188(c)(l) for initial PM-10
nonattainment areas].
In addition to EPA's general authority under section
188(b)(l) to reclassify as serious any area the
Administrator determines cannot practicably attain the PM-10
NAAQS by the applicable date, for areas designated
nonattainment for PM-10 subsequent to enactment of the 1990
Amendments, subparagraph (B) of section 188(b)(l) mandates
that appropriate areas are to be reclassified as serious
within 18 months after the required date for the State's
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submission of a moderate area SIP.** Taken together with
the statutory requirement that PM-10 SIP's are due within 18
months after an area is designated nonattainment [see
section 189(a)(2)(B)], the statute thus requires that EPA
reclassify appropriate moderate areas as serious within 3
years of the nonattainment designation.
Any decision by EPA to reclassify such a future
nonattainment area as serious will be based on facts
specific to the nonattainment area at issue and will only be
made after providing notice in the Federal Register and an
opportunity for public comment on the basis for EPA's
proposed decision.
>* ;
1.2.3 Serious Area Attainment Dates
The amended Act specifies that the initial moderate
nonattainment areas (those designated nonattainment upon
enactment of the 1990 Amendments) reclassified to serious
are to attain the PM-10 NAAQS as expeditiously as
practicable but no later than December 31, 2001. Areas
designated nonattainment subsequent to enactment that are
reclassified as serious must attain the PM-10 NAAQS as
expeditiously as -practicable but not later than the end of
the tenth calendar year after the area's designation as
nonattainment [see section 188(c)(2)].
1.2.4 Key Serious Area SIP Requirements
As discussed above, States must develop and submit
SIP's providing for the attainment of the PM-10 NAAQS for
every area designated nonattainment and classified as
moderate or serious for PM-10 under the amended Act. New
revisions must be made to the PM-10 SIP in accordance with
"This directive does not restrict EPA's general
authority but simply specifies that it must be exercised, as
appropriate, in accordance with certain dates.
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section 189(b) of the amended Act *f or areas that are
reclassified as serious nonattainment areas. First,
provisions must be adopted to assure that BACM (including
BACT) will be implemented in the area [see section
189(b)(1)(B)]. Second, a demonstration (including air
quality modeling) must be submitted showing that the plan
will attain the NAAQS either by the applicable attainment
date or, if an extension is granted under section 188(e), by
the most expeditious alternative date practicable [see
section 189(b)(1)(A)].
The SIP revisions to require the use of BACM must be
submitted to EPA within 18 months after an area is
reclassified as serious [see sectiqn 189(b)(2)]. The BACM
are to be implemented no later than 4 years after an area is
reclassified [see section 189(b)(1)(B)].
The serious area attainment demonstration required
under section 189(b)(l)(A) must be submitted to EPA within
4 years after an area is reclassified based on a
determination by EPA that the area cannot practicably attain
by the statutory deadline for moderate areas. It is due
within 18 months after an area is reclassified for actually
having failed to attain by the moderate area attainment date
[see section 189(b)(2)].
1.2.5 RACM and BACM Issuance
Section 190 of the amended Act requires EPA to issue
technical guidance for RACM and BACM no later than 18 months
from enactment of the 1990 Amendments to the Act for three
PM-10 source categories: urban fugitive dust, residential
wood combustion, and prescribed silvicultural and
agricultural burning. In conjunction with publication of
the "General Preamble for Title I of the Clean Air Act
Amendments of 1990," EPA discharged the section 190
requirement to issue RACM technical guidance for each of
these three source categories [57 FR 13541, April 16, 1992;
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57 FR 18070, April 28, 1992]. The General Preamble provides
a policy for how to utilize the available RACM technical
guidance to develop area-specific RACM strategies.
The issuance of this prescribed burning BACM technical
guidance document (and its residential wood combustion and
fugitive dust companion documents), together with EPA's
previous issuance of RACM technical guidance, wholly
fulfills EPA's statutory obligation to issue RACM and BACM
technical guidance for urban fugitive dust, residential wood
combustion, and prescribed silvicultural and agricultural
burning under section 190 of the amended Act. Similar to
the manner in which EPA provided guidance on Act
requirements applicable to moderate PM-10 nonattainment
areas in the General Preamble, including a policy or how to
utilize the RACM technical guidance documents, the EPA is
planning to provide guidance on Act requirements and
provisions applicable to serious PM-10 nonattainment areas,
including BACM, in an addendum to the General Preamble.
[EPA made a draft of the addendum available for public
comment on July 16, 1992 (57 FR 31477).] The portion of the
addendum that addresses BACM provides a policy for how to
utilize today's prescribed burning BACM technical guidance
(and companion technical guidance for residential wood
combustion and fugitive dust) to develop area-specific BACM
strategies.
The information contained in this document was
assembled, in large part, through the coordinated efforts of
a task force. The task force consisted of individuals from
i
Federal and State agencies and other groups involved with
prescribed burning. Federal agencies represented on the
task force included the Bureau of Indian Affairs, the Bureau
of Land Management, EPA, the Fish and Wildlife Service, the
Forest Service, the National Park Service, and the Soil
Conservation Service. States represented on the task force
included Arizona, California, Florida, Montana, North
1-6 September 1992
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Carolina, and Oregon. Other groups represented were the
National Association of State Foresters, the National
;. .; .it.
Wildfire Coordinating Group's Prescribed Fire and Fire
Effects Working Team, and the Western States Air Resources
Council.
1.3 DOCUMENT ORGANIZATION
The information in this document is organized according
to the major components of a smoke management program.
Chapter 2 presents information on the various types of
prescribed burning that occur in the United States,
including estimates of PM-10 emissions. Chapter 3 presents
various State and Federal smoke management programs. The
focus of Chapter 3 is to describe the processes used by
State and Federal agencies with smoke management plans to
determine burn/no burn days, the location of burns, what may
be burned, and how much may be burned. Chapter 4 focuses on
the administrative programs used by State and Federal
agencies for receiving, processing, and granting burn
requests. Chapter 5 discusses qualifications for burners.
Chapter 6 discusses programs used by State and Federal
agencies to disseminate information on smoke management to
the public. Chapter 7 describes various methods used to
determine whether burners are complying with smoke
management programs, as well as tools to enforce compliance.
Chapter 8 describes available emission inventory programs
that are being used to track prescribed burning. Chapter 9
presents methods that can be used to reduce emissions from
prescribed burning, including alternatives to burning.
Chapter 10 provides descriptions of how States with active
smoke management programs coordinate their programs with the
State air quality agency and other State agencies. Finally,
Chapter 11 presents a methodology for estimating the costs
of each program component.
1-7 September 1992
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2.0 PRESCRIBED BURNING
2.1 INTRODUCTION
Prescribed burning has been applied to many different
types of lands, especially forests, agricultural fields, and
rangelands.* Prescribed burning of forest lands has been
defined as:
"The controlled application of fire to wildland
fuels in either a natural or modified state, under
specific environmental conditions which allow the
fire to be confined to a predetermined area and at
the same time produce the intensity required to
attain planned resource management objectives."1
Most prescribed burns are thought of as those that
occur from planned management ignitions to achieve a
particular objective. The term, prescribed burn, however,
is also applied to burns that occur as a result of natural
ignitions (e.g., from a lightning strike) where the
resulting fire is allowed to burn under pre-identified
conditions and approved burn plan to maintain the natural
role of fire in the environment.
Prescribed burns may be applied to native or planted
domesticated vegetation or to activity created fuels.
Vegetation may be burned to eliminate existing dominant
species (stand replacement), control invaded weeds and brush
species, maintain the current stand (underburning), or
reduce the natural build-up of hazardous fuels. Activity
"In this document, the term "wildlands" is used
frequently. The term is intended to be inclusive of all
open burning on forest lands, rangelands, and wetlands. The
term covers both public and private ownership (including
privately-owned "timber farms"). Where a specific reference
(e.g., a State regulation) uses the term "forest" in
relationship to prescribed burning, it is usually retained
because the reference does not necessarily apply to the
broader coverage of the term "wildlands."
2-1 September 1992
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created fuel is that debris or residue left after some
management activity has taken place, such as timber or crop
harvest, or land clearing (see section 9.2.2 for description
of fuel components).
2.2 OBJECTIVES OF PRESCRIBED BURNS
Prescribed fire is used to achieve a number of
objectives. Among the most cited for wildlands are:
- hazard reduction
- site preparation
- wildlife habitat improvement
- range improvement
- disease and insect control
- ecosystem maintenance
>»
Other objectives cited include management of endangered
species, management of competing vegetation, aesthetics
improvement, access improvement, and recycle of nutrients.
For agricultural lands, prescribed fire is used to
achieve waste disposal and agronomic objectives. Waste
disposal is a common objective to all agricultural burning.
Agronomic objectives may include disease, weed, and insect
control; nutrient recycling; site preparation; and improved
or sustained crop productivity. Not all agricultural burns
(e.g., orchard prunings) are conducted for agronomic
objectives.
The following paragraphs discuss several of the major
objectives of prescribed burning.
2.2.1 Hazard Reduction
In wildlands, fuels can accumulate in amounts
sufficient to pose a serious wildfire threat if they are not
removed. Fuels may accumulate naturally or be the result of
man-made activities, such as timber harvesting. Prescribed
fire is one method for removing the accumulation of the
fuel. By removing total available fuels, prescribed fire
can reduce the damage to an area in which a wildfire occurs.
2-2 September 1992
-------
In addition, by creating "breaks" in fuel continuity,
prescribed fire allows for easier control of a wildfire.2
2.2.2 Site Preparation
On most wildlands, the site needs to be prepared for
regeneration after harvest. Regeneration may occur through
seeding, planting, or natural regeneration. For each
method, fire can be used to make regeneration easier (e.g.,
clearing away vegetation that may interfere with planting)
and more successful (e.g., control competing vegetation
until seedlings become established).3
On agricultural lands, fire can be used to make crop
establishment easier by destroying ^weed seeds and residue on
the soil. For example, with burning, annual ryegrass can be
planted with little or no tillage.4
2.2.3 Wildlife Habitat Improvement
Prescribed fire is used to reduce undesirable plant
species, encourage desirable habitat by changing plant
composition, reduce vegetation growth, and manage critical
habitats. Prescribed fire is used to develop areas for
wildlife species to browse, nest, forage, etc.5 On
rangelands, firing techniques are used to promote a mosaic
pattern on the landscape encouraging different stages of
growth from range species, thus promoting species
diversity.6
2.2.4 Range CForage1 Improvement
In wildlands and agricultural lands used for forage
crops, prescribed burns can increase the availability,
palatability, quality, and quantity of grasses and forage
material for livestock as well as for wildlife species.7'8
2.2.5 Disease and Insect Control
Under very controlled conditions in wildlands,
prescribed burning can be used to control various diseases
and insects without destroying the seedlings or stand.9 On
2-3 September 1992
-------
agricultural lands, one of the major benefits of prescribed
fire is the sanitization of the soil after the residues are
burned away.
2.2.6 Ecosystem Maintenance
In many of North America's ecosystems, "natural" fire
is a significant ecological process. Many plants have
structural adaptations, specialized tissue, or reproductive
features that favor them over other species in a fire-
dominated environment. The removal or alteration of
"natural" fire patterns (e.g., from the attempt to exclude
fire) in these ecosystems can significantly change the make-
up of the ecosystem.10 Prescribed burning is used in some
areas to maintain those fire-tolerant or fire-dependent
species.11
2.3 GEOGRAPHIC DISTRIBUTION OF PRESCRIBED BURNING
Prescribed burning is used throughout the United States
(U.S.). Its distribution, however, is quite varied. The
distribution of prescribed burning is examined by presenting
estimates of the acreage of forest and rangelands, and
agricultural lands to which prescribed burning has been
applied for each State.
2.3.1 Prescribed Forest and Rangeland Burning
In 1989, prescribed burning was estimated to occur on
over 5 million acres of forest and rangeland. Table 2-1
identifies the estimated acres of prescribed wildland and
rangeland burns by each State, grouped by EPA Region.
Figure 2-1 provides a graphical presentation of these
estimates.
As seen in Table 2-1 and Figure 2-1, the eight States
that make up EPA Region IV burned substantially more
wildland and rangeland than the remaining 44 States
combined. Over 3.6 million of the 5 million acres were
estimated to be burned in these eight States. The least
amount of prescribed forest and rangeland burning occurs in
2-4 September 1992
-------
the northeastern States of EPA Regions I and II (17,000
acres) and the north central States of EPA Regions V and VII
(41,000 acres).
Table 2-2 shows the relative acreages burned in each
EPA Region for three major objectives of prescribed forest
burnings wildfire hazard reduction, silvicultural
objectives, and wildlife improvement (including ecosystem
maintenance). As seen in Table 2-2, most burning appears to
be conducted for wildfire hazard reduction across the U.S.
The notable exception is in U.S. EPA Region V, where over 80
percent of the acres burned were attributed to ecosystem/
wildlife objectives. In using this table, it is important
to note that there exists certain incentives in some States
to bias the reason(s) indicated by the burner as to the
objective of the burn. For example, a State may only issue
a burning permit if the objective is fuel reduction. This
will likely create a strong bias for all burns to be
reported as being conducted for "hazard reduction." There-
fore, these relative percentages should be used with
caution.
Finally, Figure 2-2 shows the relative distribution of
acres burned by season. Because of the significant amount
of acres burned in EPA Region IV, the U.S. distribution is
very similar to that of Region IV. With the exception of
EPA Region I,. winter burning decreases rather steadily the
further west one goes, while fall burning tends to steadily
increase.
2.3.2 Prescribed Agricultural Burning
Data on agricultural prescribed burning are much less
readily available than that for prescribed wildland and
rangeland burning. The last comprehensive survey of
agricultural open burning was conducted in 1977. A 1983
survey report14 compared several estimates of agricultural
burning, including the 1977 study. In 1988, the Oregon
Department of Agriculture assembled data on agricultural
2-5 September 1992
-------
TABLE 2-1. NUMBER OF FOREST AND RANGELAND
ACRES BURNED, BY STATE
STATE
Connecticut
Maine
Massachusetts
New Hampshire
Rhode bland
Vermont
REGION I
New Jersey
New York
REGION II
Delaware
Maryland
Pennsylvania
Virginia
West Virginia
REGION HI
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
REGION IV
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
REGION V
NUMBER OF ACRES BURNED
0
12
350
0
74
800
1,240
15,300
30
15,400
740
21,000
130
31^00
130
53,800
990,000
849,000
977,000
8,700
385,000
65,000
303,000
29,000
3,610,000
2,150
5340
1320
11,600
1,800
10,400
33,200
STATE
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
REGION VI
Iowa
Kansas
Missouri
Nebraska
REGION yjl
Colorado
Montana
North Dakota
South Dakota,
Utah
Wyoming
REGION VIH
Arizona
California
Hawaii
Nevada
REGION DC
Alaska
Idaho
Oregon
Washington
REGION X
NUMBER OF ACRES BURNED
73,700
66,400
9,800
0
160,000
310,000
12
920
6,240
720
7,900
22,000
108,000
22,700
7,120
24300
22,700
207,000
236,000
168,000
17
1,770
405,000
4,200
160,000
223,000
56,000
443,000
UNITED STATES 5,085,000
NOTE: TOTALS MAY NOT SUM DUE TO ROUNDING
SOURCE:
Reference 12.
2-6
September 1992
-------
O
3
w
rt
$
Connecticut
Maine
_ Massachusetts
New Hampshire
Rhode Island
Vermont
>-c New Jersey
~ New York
Delaware
_ Maryland
a Pennsylvania
Virginia
West Virginia
Alabama
Florida
Georgia
> Kentucky
ii Mississippi
North Carolina
South Carolina
Tennessee
Illinois
Indiana
j> Michigan
Minnesota
Ohio
Wisconsin
Arkansas
Louisiana
5 New Mexico
. Oklahoma
Texas
Iowa
K Kansas
£* Missouri
Nebraska
Colorado
, t Montana
S North Dakota
> South Dakota
Utah
Wyoming
Arizona
X California
*' Hawaii
Nevada
Alaska
X Idaho
Oregon
Washington
200
400 600
ACRES (x 1,000)
800
1,000
Figure 2r-i. Estimated Acres of Prescribed Forest
and Rangeland Burns, by State
September 1992
2-7
-------
TABIoE 2-2. DISTRIBUTION OF FOREST AND RANGELAND ACRES
BURNED BY RESOURCE MANAGEMENT OBJECTIVE
EPA
REGION
I
n
m
TV
V
VI
vn
vm
IX
X
OBJECTIVE
Wildfire Hazard
Reduction
57%
99.8
35-
63
15
38
65
63
81
58
62
Silviculture
5%
~
57
21
1
32
1
0.4
30
20
Ecosystems/Wildlife
39%
0.2
8
16
84
30
35
36
18
12
18
TOTAL
ACRES
BURNED
1,240
15,400
53,800
3,610,000
- 33,200
310,000
7,900
207,000
405,000
443,000
5,085,000 .
SOURCE: Reference 12.
NOTE: Certain State requirements for obtaining bum permits may bias the reporting of the objectives of the
burns. For example, some States will only issue bum permits for hazard reduction. Therefore, these
distributions contain some unquantifiable bias.
September 1992
2-8
-------
burning in ten States.xs A recent study on smoke management
practices contains some data on agricultural burning.16
Using the data in the above referenced reports,
approximately 7.5 million acres are estimated to be burned
on an annual basis. (Because of the varying years from
which the data were obtained, these "annual" estimates are
subject to much uncertainty.) Table 2-3 presents the State-
by-State estimates. Of the estimated 7.5 million acres, EPA
Region IV accounts for approximately one-half of the total
acreage. The least amount of agricultural burning occurs in
the northeastern and mid-Atlantic States of EPA Regions I,
II, and III. Figure 2-3 illustrates the distribution of
agricultural prescribed burning by ^showing the counties in
which more than 10,000 acres were burned.
The types of agricultural residues burned vary from
region to region. In the northeast, where burning is
virtually nonexistent, most of the burning that occurs
appears to be the burning of orchard prunings. In the north
central States, open field burning, especially for wheat
straw, appears to be common only in three States: Kansas,
Nebraska, and Missouri. In the southern States,
agricultural burning is an accepted practice. Major crops
burned are rice, wheat, and sugar cane. In the western
States, most of the agricultural burning occurs in three
States: California, Hawaii, and Oregon. In California,
agricultural burning involves a large number of crops,
including rice, wheat, and almond trash. In Hawaii, sugar
cane is the predominant crop burned, with some pineapple
burning taking place. In Oregon, the major area of
agricultural burning is the Willamette Valley where seed
grasses are burned. Other specific areas in the western
States where agricultural burning occurs include Spokane
County, Washington (approximately 26,000 acres of
bluegrass), eastern Idaho (approximately 10,000 acres of
bluegrass), and, in Montana, the Gallatin Valley (hay crop)
and the Flathead area (grass-seed)."
2-9 September 1992
-------
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TABLE 2-3
ESTIMATED AGRICULTURAL ACRES BURNED AND
PRINCIPLE CROPS, BY STATE
STATE
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
REGION I
New Jersey
New York
Puerto Rico
REGION II
Delaware
Maryland
Pennsylvania
Virginia
West Virginia
REGION HI
Alabama
Florida
Georgia
Kentucky .
Mississippi
North Carolina
South Carolina
Tennessee
REGION IV
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
REGION V
NUMBER OF ACRES BURNED
0
31,"000 to 36,000
1,500
0
0
85 to 100
33,000 to 38,000
0
0
78,800
78,800
180 to 210
'1,300 to 1,500
38,000
24,000
0
63,000 to 64,000
76,000 to 89,000
1,900,000102,400,000
837,000 to 1,000,000
32,000
274,000 to 350,000
293,000 to 350,000
21,000
34,000
3,670,000 to 3,980,000
negligible
negligible
51,000
151,000
79,000
80,000
361,000
PRINCIPLE TYPES OF CROPS
Blueberry, potato tops, hay
Blueberry, raspberry stalks
Orchard primings
Sugar cane
Sugar cane, orchard prunings,
pasture
Pasture, peanut, soybean, wheat
Wheat, soybean, rice
Wheat, tobacco
Bluegrass
REFERENCES)
14,16
14,16
14,16
14,16
14
14
14
14
14
14
14
14
14
14
14
15, 17, 18
14, 15
14
14,15
14,15
14
14
14
14
14
14
14
14
September 1992
2-11
-------
TABLE 2-3.
ESTIMATED AGRICULTURAL ACRES BURNED AND
PRINCIPLE CROPS, BY STATE
(concluded)
STATE
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
REGION VI
Iowa
Kansas
Missouri
Nebraska
REGION VII
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
REGION VIII
Arizona
California
Hawaii
Nevada
REGION DC
Alaska
Idaho
Oregon
Washington
REGION X
UNITED STATES
NUMBER OF ACRES BURNED
64,000
287,000 to 350,000
1,000
89,000
37,000
478,000 to 541,000
negligible
600,000
100,000
167,000
867,000-'
79,000
84,000
242,000 to 250,000
146,000
negligible
18,000
569,000 to 577,000
11,000 to 19,500
655,000 to 763,000
93,000 to 200,000
1,700 to 2,000
760,000 to 984,000
0
10,000 to 12,000
237,000 to 264,000
121,000 to 141,000
368,000 to 417,000
, 7,200,000 to 7,900,000
PRINCIPLE TYPES OF CROPS
Rice, wheat
Rice, sugar cane
Sugar cane, wheat
Wheat
Wheat Xi
Wheat
Hay, grass
Cereal, hay
Grasses, wheat, barley, asparagus
Rice, barley, orchard prunings
Sugar cane, pineapple
Grasses
Grasses, cereal
Grasses
REFERENCE(S)
14
14,15
14
14
14
14
14, 15
14
14
14
14
14, 15
14
14
14
14,16
14,15
14,15
14
14
14
14, 15
14
NOTE: TOTALS MAY NOT SUM DUE TO ROUNDING
September 1992
2-12'.
-------
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2-13
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2.4 EMISSIONS FROM PRESCRIBED BURNING
Prescribed burning releases many types of pollutants
into the atmosphere. These include particulates, partially
consumed fuel, liquid droplets, carbon monoxide,
hydrocarbons, and nitrogen oxides. Of particular concern in
this document are the emissions of particulates. Most
particulate emissions from prescribed burning (over 90
percent) are less than 10 microns (/z) in diameter (PM-10).
This size particulate is considered to pose particular
health concerns because PM-10 is small enough to enter the
human respiratory system.
Analyses of particulate matter from the burning of wood
have identified several hundred organic compounds in the
particulate matter, which are expected to be part of smoke
from a prescribed fire. These compounds have been
categorized into the general classes of: organic acids,
alcohols, aldehydes, furans, ketones, and aromatic compounds
(esters, phenols, and polycyclic organic matter).20 Some of
the compounds identified in smoke from prescribed fire are
considered by the U.S. EPA to be toxic. These compounds
include acetaldehyde, acrolein, formaldehyde, and toluene.21
2.4.1 Emission Estimates
Table 2-4 presents estimates of PM-10 emissions from
prescribed forest and rangeland burns. Figure 2-4 presents
this information in graphical form. PM-10 emissions from
these prescribed burns in 1989 were estimated to be over
600,000 tons. Over one-half of these emissions (380,000
tons) were attributed to the eight States in EPA Region IV.
Five of these eight States were estimated to emit over
10,000 tons of PM-10. Out of the remaining 42 States, only
seven other States were estimated to emit over 10,000 tons
of PM-10 from prescribed forest and rangeland burning,
totalling approximately 220,000 tons. These seven States
are Arizona, California, Idaho, Montana, Oregon, Texas, and
Washington.
2-15 September 1992
-------
Nationwide estimates of particulate emissions from
agricultural burning were made covering the years 1940,
1950, i960, and 1970, ranging from 1.6 million tons in 1940
to 2.4 million tons in 1970. 22 In the 1983 survey report,
an estimate of particulate emissions of approximately 68,000
tons from agricultural open burning in 17 States was made.*
There are many limitations associated with the derivation of
this estimate. This estimate, therefore, should be
considered an order of magnitude estimate.
In general, particulate and PM-10 emissions from
agricultural burning tend to be relatively small portions of
a State's total particulate (PM-10) emission inventory. The
1983 survey report on agricultural burning showed
particulate emissions contributing less than 0.1 percent for
5 of the 17 States, less than 1 percent of total
particulates for 9 of the 17 States, between l and 2 percent
for 2 States (Florida and Louisiana), and over 14 percent
for 1 State (Hawaii).23
The PM-10 emissions from prescribed forest and
rangeland burning may be a much more significant portion of
a State's total particulate emissions. For example, the
211,000 tons of PM-10 emissions in Georgia in 1989 is
approximately 30 percent of the 1970 estimated State total
for particulates from all sources.24 A similarly high
percentage is found for PM-10 emissions from prescribed
forestry burning in Alabama, with a few exceptions,
however, the relative contribution of PM-10 emissions from
prescribed burning appears to be less than 10 percent to the
total particulate emissions - and, for most States, the
contribution is likely to be less than l percent.
Emissions from prescribed burning are not uniformly
spread out through the year. Figure 2-5 shows the
distribution of PM-10 emissions from prescribed forest and
T?io,-n 1? .States w.e.re: Alabama, California, Delaware,
Florxda, Georgia, Hawaii, Idaho, Kansas, Louisiana
Massachusetts, Maryland, Michigan, Nebraska, North Carolina,
Oregon, Vermont, and Washington. (Reference 14, p. 33)
2-1 6 September 1992
-------
TABLE 2-4. ESTIMATED PM1Q EMISSIONS FROM PRESCRIBED
FOREST AND RANGELAND BURNS, BY STATE
STATE
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
REGION I
New Jersey
New York
REGION II
Delaware
Maryland
Pennsylvania
Virginia
West Virginia
REGION HI
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
REGION IV
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
REGION V
PM10 EMISSIONS (tons)
0
0.1
21-
0
5
56
82
1,240 '
O.S
1,240
26
760
11
4400
13
5320
87300
85300
129,000
530
40,600
6,900
28,700
2,700
381^00
120
280
110
1,240
52
490
2300
STATE
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
REGION VI
Iowa
Kansas
Missouri
Nebraska
REGION VII
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
REGION VIII
Arizona
California
Hawaii
Nevada
REGION DC
Alaska
Idaho
Oregon
Washington
REGION X
PM10 EMISSIONS (tons)
9,540
6,100
980
0
23,000
39,600
03
30
430
28
490
2,160
15300
260
690
1,180
1300
20,900
38300
29,000
2
87
67,400
66
36,700
60300
20^00
118,000
UNITED STATES 637,000
NOTE TOTALS MAY NOT SUM DUE TO ROUNDING
SOURCE:
Reference 12.
September 1992
2-17
-------
o
w
Connecticut
Maine
M Massachusetts
New Hampshire
Rhode Island
Vermont
_< NewJersy
*' New York
Deleware
_ Maryland
£3 Pennsylvania
Virginia
West Virginia
Alabama
Florida
Georgia
> Kentucky
""" Mississippi
North Carolina
South Carolina
Tennessee
Illinois
Indiana
> Michigan
Minnesota
Ohio
Wisconsin
Arkansas
[_, Louisiana
** New Mexico
Oklahoma
Texas
« Iowa
^. Kansas
Missouri
Nebraska
Colorado
S Montana
^ North Dakota
South Dakota
Utah
Wyoming
X!
Arizona
California
Hawaii
Nevada
Alaska
Idaho
Oregon
Washington
I
I
20 40 60 80 100
PM10 EMISSIONS (1,000 tons)
120
140
Figure 2-4. Estimated PM10 Emissions from Prescribed
Forest and Rangeland Burns, by State
September 1992
2-18
-------
rangeland burns for the four seasons in each of the EPA
Regions. In general, the distribution of emissions follows
the distribution of acres burned (see Figure 2-2).
Emissions from prescribed forest and rangeland burns tend to
be the greatest during the fall in the western States,during
the spring in the States located in the middle of the
country, and during the summer or winter in the southern and
eastern States.
2.4.2 Relationship to PM-10 Nonattainment Areas
No information is available on a national basis to
identify the contribution of prescribed burning to PM-10
concentrations in PM-10 nonattainment areas. Table 2-5
shows total prescribed forest, rangeland, and agricultural
acres burned and PM-10 emissions from prescribed forest and
rangeland burning (with particulate emission estimates from
agricultural burning for 17 States) in comparison to
moderate nonattainment areas. From Table 2-5, it is clear
that there is no relationship between total acres burned or
particulate (PM-10) emissions in a State from prescribed
burning and the presence of a nonattainment area in that
State.
Further, there is little information on the relative
contribution of prescribed burning to specific PM-10
nonattainment areas. There is even less information on the
relative contribution of PM-10 emissions of prescribed
burning during periods of nonattainment. Some information,
as discussed below, is available on various areas in
California, Montana, and Oregon.
2.4.2.1 California.25 On an average day in the
Sacramento Valley (where 96 percent of the rice in
California is grown and harvested), agricultural burning has
been estimated to contribute approximately 2 percent of the
total PM-10 concentration. Other PM-10 sources included
motor vehicles, fuel combustion, solvent uses, petroleum
processes, industrial processes, and miscellaneous
2-19 September 1992
-------
-f
a
w
-------
TABLE 2-5. PRESCRIBED BURNING ACRES AND
EMISSIONS VS. NONATTAINMENT AREAS
STATE
FLORIDA
GEORGIA
ALABAMA
CALIFORNIA
MISSISSIPPI
KANSAS
OREGON
LOUISIANA
NORTH CAROLINA
SOUTH CAROLINA
NORTH DAKOTA
ARIZONA
MONTANA
WASHINGTON
IDAHO
NEBRASKA
MINNESOTA
TEXAS
SOUTH DAKOTA
ARKANSAS
MISSOURI
COLORADO
HAWAII
WISCONSIN
OKLAHOMA
OHIO
TENNESSEE
VIRGINIA
MICHIGAN
WYOMING
KENTUCKY
PENNSYLVANIA
NUMBER OF ACRES BURNED1
(x 1,000)
3,000
1,900
1,070
877
692
601
474
385
382
324
265
246
192
187
170
168
163
160
153
138
106
101
100
90
89
81
63
56
53
41
41
38
PM-10
EMISSIONS
(TONS X l.OOO)2
1184
2184
1564
49'
61'
3.5'
63*
264
154
51
0.3
49
19
22'
464
0.03
1.4
31
0.8
14
0.9
2.9
7.64
0.4
0
0.06
3.4
5.8
0.1
1.3
1.1
0.03
CONTAINS INITIAL
MODERATE PM-10 NON-
ATTAINMENT AREAS'3
NO
NO
NO
YES
NO
NO
YES
NO
NO
NO
NO
YES
YES
YES
YES
NO
YES
YES
NO
NO
YES
YES ' '
NO
NO
NO
YES
NO
NO
YES
YES
YES
2-21
September 1992
-------
TABLE 2-5. PRESCRIBED BURNING ACRES AND
EMISSIONS VS. NONATTAINMENT AREAS
(concluded)
STATE
MAINE
UTAH
MARYLAND
NEW JERSEY
NEW MEXICO
INDIANA
ALASKA
NEVADA
ILLINOIS
MASSACHUSETTS
VERMONT
DELAWARE
WEST VIRGINIA
RHODE ISLAND
NEW YORK
IOWA
NEW HAMPSHIRE
CONNECTICUT
NUMBER OF ACRES BURNED1
(x 1,000)
34
24
22
15
11
5
4
4
2
2
1
1
0.1
0.07
0.03
0.01
0
0
PM-10
EMISSIONS
(TONS X 1,000)*
0.2*
1.4
l.O4
1.6
0.1
0.3
oa4
0.2
0.05
O.I4
0.054
0.02
0.007
0.001
0
0
0
CONTAINS INITIAL
MODERATE PM-10 NON-
ATTAINMENT AREAS?3
YES
YES
NO
NO
YES
YES
YES
YES
YES
NO
NO
NO
YES
NO
NO
NO
NO
YES
From Tables 2-1 and 2-2. Where a range in Table 2-2 was given,
numbers was used.
the average of the two
Prescribed forestry and rangeland burns only, unless otherwise indicated. Reference 12.
1 Federal Register. November 6, 1991, pages 56694-56858.
Includes estimates of agricultural burning emissions from 1983 agricultural report.
2-22
September 1992
-------
processes. According to one report, peak PM-10 emissions in
the Sacramento Valley occur outside the periods when rice
straw is burned.
2,4.2.2 Montana.26 Montana has several areas
identified as moderate PM-10 nonattainment areas. These
areas are: portions of Flathead County, Ronan, Poison,
Libby, Lame Deer, Columbia Falls, Butte, and portions of
Missoula. Most of the prescribed wildland burning in
Montana is conducted in these areas. The Montana Air
Quality Bureau is currently working on source
apportionment studies in some of these areas to more
precisely determine the contribution of prescribed burning
and other sources to the PM-10 concentrations in these
areas.
2.4.2.3 Oregon. The Oregon Department of
Environmental Quality's (DEQ) air quality data for the three
cities in Oregon currently violating annual particulate air
quality standards show that prescribed burning's
contribution to all three areas are less than 10 percent.27
Specific information on the areas currently in violation of
either the 24-hour and/or annual particulate standards
are:2S
In Klamath Falls, the 24-hour standard was exceeded on
an average of 32 days per year during the winter months
during the 1987 to 1989 period. The DEQ stated that slash
burning was a small contributor to the problem. Woodstoves
were estimated to contribute 80 percent of the problem and
dust, transportation, and other sources (excluding slash
burning) 18 percent of the total particulate.
In the Medford airshed, where the 24-hour standard was
violated on an average of 4 days per year from 1987 through
1989 and the annual standard is also exceeded, prescribed
burning is estimated to contribute 4 percent of the
particulates. Woodstoves were estimated to contribute 63
percent, and dust and industry another 18 percent.
2-23 September 1992
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In Grants Pass, the 24-hour standard is exceeded about
1 day per year during winter months. The DEQ has said that
slash burning is a "small" contributor. Woodstoves, dust,
and industrial sources are the primary causes of the
violations.
In LaGrande, the 24-hour standard is exceeded about 3
days per year, primarily during the winter months. There
have been non-winter exceedances attributed to road building
and wildfires. The annual standard is also exceeded, with
woodstoves and dust comprising 97 percent of the
particulates.
In Oakridge, the 24-hour standard is exceeded about 3
days per year during the winter months. Woodstoves and
industry are the primary contributors to the violations.
In Eugene-^Springfield, the 24-hour standard is exceeded
about 1 day per year during the winter months. The major
source of violations is woodstoves, contributing 78 percent
of the particulates.
The general conclusion is that slash burning is not a
significant contributor in any of the nonattainment areas in
Oregon. The burning impacts have been grouped with other
minor impact sources, which represent from 1 to 7 percent of
the particulate impact in the nonattainment area. It should
be pointed out that the smoke management program already in
place in Oregon for prescribed burning, may be partly
responsible for the relatively small impact of slash burning
on nonattainment. The other major factor is that little
slash burning occurs in the winter months.
2.5 REGULATION OF PRESCRIBED BURNING
Prescribed burning is regulated in many States through
smoke management programs. The objective of smoke
management programs is usually to reduce the emissions from
prescribed burning or minimize the impact of the smoke on
populations or both. The State of Oregon defines smoke
management for agricultural burning as the daily (hourly)
2-24 September 1992
-------
control of field burning according to prevailing
meteorological dispersion conditions.
The level of regulation of smoke management programs
varies considerably, from State to State, and sometimes
within a State for agricultural versus wildland and
rangeland burning. The more detailed smoke management
programs are those designed to provide direct control over
when, where, and how much burning takes place.
The specific steps employed by a State to achieve these
objectives constitute the State's "smoke management plan."
The following are characteristic elements of a more
developed smoke management plan:
1. Registration of acres to be turned in the coming
year. .
2. Designation of burn/no burn days based on a number of
specific meteorological factors.
3. Allocation procedures to determine how many and which
acres -will be burned on a given day.
4. The specific emission reduction technigues to be
used. -
Smoke management plans in some States, such as Oregon
and Washington, incorporate emission reduction goals in
addition to the more traditional goals of minimizing smoke
intrusions and public complaints from reduced visibility.
In western Oregon, for example, emissions from prescribed
slash burning have declined by about 45 percent in the past
12 years. Reasons cited for this decline include increased
utilization of forest fiber, a decline in the number of
acres burned, and more spring burning. Alternatives to
slash burning, such as mechanical, herbicide, and manual
treatment, are widely practiced in western Oregon.
The following chapters focus on the elements of a
smoke management plan and methods that can be employed to
reduce emissions from prescribed burning.s
2-25 September 1992
-------
-------
2.6 REFERENCES
1. U. S. Department of Agriculture, Forest Service
Southern Region. A Guide for Prescribed Fire in
Southern Forests. Technical Publication R8-TP 11.
February 1989.
2. Reference 1, p. 3.
3. Reference 1, P. 4.
4. Oregon State University Extension Service. Burning
Grass Seed Fields in Oregon's Willamette Valley; The
Search for Solutions. Extension Miscellaneous 8397.
Reprinted February 1989. p. 12.
5. Personal communication. Roger Eubanks, U.S. Forest
Service, to Ken Meardon, Pacific Environmental Service,
Inc., June 1991.
6. Personal communication. Greg Hendricks, Soil
Conservation Service to Ken Meardon, Pacific
Environmental Service, Inc., June 26, 1991.
7. Reference 1, p. 6.
8. Reference 6.
9. Reference 1, p. 6.
10. Personal communication. Bill Leenhouts, U.S. Fish and
Wildlife Service, to Ken Meardon, Pacific Environmental
Service, Inc., June 6, 1991.
11. Reference 1, p. 7.
12. Personal communication. Janice Peterson, U.S. Forest
Service, to Ken Meardon, Pacific Environmental Service,
Inc., 1991.
13. C. T. Chi and D. L. Zanders. Source Assessment;
Agricultural Open Burning. State of the Art. EPA/600-
2-77-107a. 1977.
14. M. T. McAdams, K. R. Meardon, and D. P. Kent, Pacific
Environmental Services, Inc. Assessment for Future
Environmental Problems - Agricultural Residues.
Prepared for: U. S. Environmental Protection Agency.
1983.
15. Chuck Craig, Oregon Department of Agriculture, to Bruce
Andrews. Agricultural Burning Around the Nation.
Interoffice Memo. December 2, 1988.
2-26 September 1992
-------
16. Peter Lahm. Smoke Management Practices Report. Smoke
Management Programs Within the United States. Prepared
for: Arizona Department of Environmental Quality.
1990.
17. Personal communication. Florida Department of
Environmental Resources, with Ken Meardon, Pacific
Environmental Service, Inc. July 29, 1991.
18.- Personal communication. Jim Brenner, Florida Division
of Forestry, with Ken Meardon, Pacific Environmental
Service, Inc. July 29, 1991.
19. Reference 14, pp. 21 through 30.
20. Southeastern Forest Experiment Station. Southern
Forestry Smoke Management Guidebook. USDA Forest
Service General Technical Report SE-10. December 1976.
p. 16.
fr >.,.
21. Reference 20, pp. 13, 14.
22. J.H. Cavender, D.S. Kircher, and A.J. Hoffman.
Nationwide Air Pollutant Emission Trendsr 19401970.
U.S. Environmental Protection Agency, Research Triangle
Park, NC, 1973.
23. Reference 14, p. 33.
24. Reference 14, p. 33.
25. William G. Miller, Natural Resource Strategic Services.
Air Quality Briefing Document. Prepared for:
California Rice Promotion Board.
26. Montana Airshed Group. Annual Report - Fall Season
1990. January 1991.
27. Oregon Department of Forestry. A Report on Prescribed
Burning in Oregon. 1990. p. 2.
28. Reference 27, p. 44.
2-27 September 1992
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3.0 SMOKE DISPERSION EVALUATION
3.1 INTRODUCTION
Smoke dispersion evaluation is used to identify how
much burning can be allowed on a given day without
exceeding, for example, visibility criteria or ambient air
quality standards. Smoke dispersion evaluation is conducted
to assist smoke management coordinators in determining when,
where, how, and to what extent prescribed burns can be
conducted on a particular day. .
This chapter presents an overview of two types of
models used to perform smoke dispersion evaluations:
weather categorization models and smoke dispersion computer
models. The smoke dispersion evaluation methods and
procedures used by several States with smoke management
programs are then described. A discussion of a suggested
implementation strategy for the smoke dispersion evaluation
element available for the development of area-specific BACM
smoke management programs concludes this chapter.
3.2 SMOKE DISPERSION EVALUATION METHODS
3.2.1 Weather Categorization Models
Weather categorization models are based on an
assessment of the dispersion capabilities of the atmosphere.
Poor dispersion capabilities limit the amount of burning
because under such conditions smoke can accumulate in
quantities sufficient to violate ambient air quality
standards or other criteria. Sufficiently poor dispersion
capabilities can result in the declaration of "no burn" '
9
days. Good or favorable dispersion capabilities allow
prescribed burning to occur without endangering ambient air
3-1 September 1992
-------
quality standards, provided the amount of prescribed burning
does not "overload" the ability of the atmosphere to
disperse the emissions. Thus, even under favorable
dispersion conditions, assessment of the quantity of burning
and its location needs to be made.
The capability of the atmosphere to disperse smoke from
prescribed fires tends to be related to three primary
factors: atmospheric stability, mixing height, and
transport wind speed.1 Most weather categorization models
incorporate a combination of these factors. The two most
commonly used are mixing height and transport wind speed.
3.2.1.1 Atmospheric stability. Atmospheric stability
is a measure of the tendency for vertical mixing to take
place in the atmosphere. Atmospheric stability affects the
mixing of the smoke during both the convective (where most
of the emissions are entrained into a definitive convective
column) and nonconvective (where most of the emissions are
not entrained into a definitive convective column) phases of
a burn. A stable atmosphere is a poor time to conduct a
burn because the smoke will most likely start to settle to
the lowest levels of the atmosphere, and high concentrations
of smoke will result.2
An unstable atmosphere tends to aid good mixing of
smoke plumes with little, if any, long-term high volumes of
smoke. For most prescribed burning, a slightly unstable
atmosphere tends to produce an optimum dispersion pattern,
particularly where surface wind speeds are moderate.3
Strongly unstable conditions may result in fire hazards
concerns. Thus, while dispersion conditions are more
favorable, greater care must be exercised in conducting
prescribed burns under strongly unstable conditions.
A neutral atmosphere is one in which vertical mixing
and plume-rise are neither enhanced nor suppressed. The
level at which a parcel of smoke reaches equilibrium with
the surrounding air is the level at which it remains.
3-2 September 1992
-------
Burning activity can generally be planned under neutral
stability conditions as long as the wind is away from a
sensitive area.4
Atmospheric stability is determined by the rate of
temperature change with respect to height in the atmosphere.
A dry atmosphere that cools at a rate in excess of 5.5 ° F
per 1,000 feet is unstable? one that cools at a lesser rate
or which becomes warmer with height is stable. Direct
measurements of temperature with height are not routinely
available except at widely separated upper-air observing
stations on a twice daily basis.3
Because of the difficulties in obtaining and, in some
cases, interpreting temperature profiles, the atmospheric
dispersion rate near the ground has often been indirectly
estimated by use of readily observed weather variables such
as surface wind speed, cloud cover, ceiling height, and
insolation.* The most common scheme** to indirectly
estimate stability assigns a dispersion rate to the lower
atmosphere according "to one of seven stability classes,
ranging from extremely unstable through neutral to extremely
stable. The stability class is determined from solar
elevation angle, wind speed, opaque cloud cover, and cloud
coyer height.12
Indicators of a stable atmosphere include cloudless
nights with light winds; hazy conditions and reduced
visibility; clouds with flattened or layered appearance; and
light winds. Unstable air masses tend to have cumulus
clouds with good vertical extent; good visibility; strong,
gusty winds, and hot, clear days (without any low-level
""Insolation" is the rate at which the total solar
energy (direct plus sky radiation) is received on a
horizontal surface. (Reference 6)
**The most common scheme is that of Pasquill
(References 7 and 8), modified by Gifford (Reference 9), and
reformulated for computerized applications by Turner
(References 10 and 11) .
3-3 September 1992
-------
subsidence inversions).13 Neutral conditions are most
likely during cloudy or windy regimes.3-* Visible indicators
of a stable atmosphere and an unstable atmosphere are
illustrated in Figures 3-1 and 3-2, respectively.
3.2.1.2 Mixing height. Mixing height is that height
through which the mixing process is relatively complete.15
A mixing height only exists when the lower atmosphere is
unstable or neutral. Above the mixing height is a layer of
stable air that acts to suppress vertical mixing. The
higher the mixing height, the better the conditions for
smoke management because a reasonably deep layer of vigorous
mixing is needed to maintain low background concentrations
in 'the lower atmosphere.16
Mixing height changes markedly during the course of the
day. On a clear night with light winds, the dispersion rate
near the ground, particularly in rural areas, may be about
as slow as that at great heights. In such conditions, the
mixing height is effectively zero, and pollutants spread
very slowly above the ground. After sunrise, the ground
heats up and the lower atmosphere is warmed from below,
creating a mixing layer that typically increases in depth
(increasing mixing height) until early afternoon. The
mixing height generally reaches a steady state through the
afternoon hours until about sunset. By dark, cooling
temperatures at ground level create a stable layer of air
that traps ground pollutants, and the mixing height
effectively returns to zero. During cloudy or very windy
days, the above trends generally do not hold; the mixing
height may be determined by frontal zones or other factors
that may be rapidly changing as a storm system moves across
an area.17
During fair weather regimes, when most prescribed fires
are conducted, mixing height can be determined fairly
accurately by comparing the current surface air temperatures
with the upper-air temperature profile measured during early
3-4 September 1992
-------
RELATIVELY WARM
CLOUDS IN LAYERS,
NO VERTICAL MOTION
STRATUS TYPE CLOUDS
SMOKE COLUMN DRIFTS APART AFTER
LIMITED RISE
POOR VISIBILITY IN LOWER LEVELS
DUE TO ACCUMULATION OF HAZE
AND SMOKE
FOG LAYERS
STEADY WINDS
Figure 3-1. Visible Indicators of a Stable Atmosphere.
RELATIVELY COLD
CLOUDS GROW VERTICALLY AND
SMOKE RISES TO GREAT HEIGHTS
CUMULUS TYPE CLOUDS
UPWARD AND DOWNWARD CURRENTS
GUSTY WINDS
GOOD VISIBILITY
DUST WHIRLS
Figure 3-2. Visible Indicators of an Unstable Atmosphere.
SOURCE: Reference 1, p 17.
September 1992
3-5
-------
morning hours (7:00 a.m.)- During the day, the surface
temperature will typically be higher than that given as
surface temperature within the early morning upper-air
profile. By comparing the temperatures and pressures of the
surface and upper-air observations and assuming dry
adiabatic process of atmospheric mixing, the mixing height
associated with the current surface temperature can be
ascertained.18
During stable atmospheric conditions, there is no
mixing height; that is, there is no height below which
dispersion processes are rapid. Because high smoke
concentrations are maintained for extended distances in such
conditions, no burning should occur and smoldering fires
x-
should be extinguished.19
Depending on the characteristics of the prescribed burn
(e.g., fire intensity) and the degree of stability of the
stable air, the plume may be able to penetrate the stable
air over the mixing height. This creates an "effective
plume rise," which can be used in place of mixing height in
evaluating smoke dispersion capabilities. In the Willamette
Valley, test fires, aerial and ground monitoring, and
predictive equations are used to determine and track
effective plume rise.20
3.2.1.3 Transport wind speed. Transport wind speed is
the average diluting wind speed within the smoke-laden
layers of the atmosphere.21 Pollutants within the mixing
layer are directly diluted by the transport wind speed.
Transport wind speed is generally considered to have the
most profound effect on pollutant concentrations.22
Frequently, the mixing height is multiplied by the
transport wind speed to yield a "ventilation factor or
index." A number of States have used ventilation indices
alone or in conjunction with consideration of atmospheric
stability in their smoke dispersion evaluation procedures. *m±
9
3-6 September 1992
-------
Weather categorization models used by several States are
discussed in the next section of this chapter.
It is important to note that no two weather
categorization models are the same. Other considerations,
such as topography of the area, types of burns conducted,
and elevation at which the burns are to occur, are important
in designing a weather categorization model for a particular
area or State.
3.2.2 Smoke Dispersion Computer Models
Until recently, there were no smoke dispersion computer
models that were specifically designed to model emissions
from prescribed burns. Development of a simple screening
level model was undertaken by the Bureau of Land Management
(BLM) as a result of a request in 1985 by the Wyoming
Department of Environmental Quality, Air Quality Division
(DEQ/AQD) that BLM present evidence that prescribed burning
would not violate ambient air quality standards for
particulates.
The Wyoming DEQ/AQD reached the decision that the best
way to fulfill this requirement was a simple screening level
computer model because: (1) computer modeling would provide
a reproducible analysis, technique suitable for agency
review; (2) the Clean Air Act Amendments of 1977 mandated
the use of modeling for prevention of significant
deterioration; and (3) modeling had been used routinely in
all areas of air quality permitting since the 1977
Amendments.
The BLM became the agency to undertake the development
of a simple screening level computer model because it was
the first to desire to conduct prescribed burns in Wyoming
after the DEQ/AQD required evidence that prescribed burning
would not violate ambient air quality standards for
particulates. The result of the BLM model development
effort, which was conducted in conjunction with the U. S.
3-7 September 1992
-------
Forest Service and the Wyoming AQD, was the Simple Approach
Smoke Estimation Model (SASEM).23
In addition to SASEM, at least two other computer ,
models are available for modeling emissions from prescribed
burning. One is the Topographic Air Pollution Analysis
System (TAPAS), which was developed by the U.S. Forest
Service. The other is a smoke plume trajectory and
dispersion model (PUFF) recently developed under contract
for the Pacific Northwest Region of the U.S. Forest Service.
The following paragraphs discuss briefly these three
computer models. Additional details can be obtained from
the various agencies involved with their development.
Xv
3.2.2.1 SASEM. This model was designed to be a
screening tool for analyzing air quality impacts of
controlled range and grassland burns on Federal lands. It
has minimal data requirements and limited computer resource
requirements. SASEM can be easily applied by fire
management field personnel.24
As a simple screening tool, SASEM was designed to
assist the State agency in determining whether a new
prescribed burn should be given a permit. To achieve this
end, the model was designed to give technically correct,
answers concerning whether the permit should be granted
using simplifying assumptions that produce conservative
results (i.e., SASEM more likely overpredicts, rather than
underpredicts, downwind particulate concentrations of the
burn).25 SASEM is designed to model the impacts of a single
fire.
SASEM includes a simple estimation of particulate
emissions from burning of range fuels and screening level
estimation of dispersion of these emissions. The model
calculates emissions from fire line intensity, average fuel
loading, and the type of fuel that is burned. Plume rise is
calculated from the fuel type burned, wind speed, and
stability. Particulate concentrations are obtained from the
3-8 September 1992
-------
emission rate, plume rise, wind speed, and stability using
Gaussian dispersion formula for a line source or a point
--&
source depending on whether the fire will be a range burn or
a pile burn. The model determines maximum concentration and
the distance over which applicable standards will be
violated. Plume rise is determined from a modification of
the EPA standard formula. The modifications are intended to
take into account that the fire is generally an irregular
line source and not a point source for which the equations
were derived.26
Since SASEM was designed based on a single fire line,
strictly it is not applicable to field burning that is
conducted with perimeter ignition. For example, backing
>.-
fire followed by encircling fire (as is done in the
Willamette Valley) results in much higher fire intensities
than does a single fire line. Therefore, a different plume
rise model is needed in SASEM.27
SASEM was originally developed to meet prescribed
burning smoke management requirements imposed by ambient air
quality standards. Thus, the .results are expressed in terms
of 24-hour averaged ground-level concentrations. SASEM also
reports calculated minimum visual ranges from up to ten
preselected receptors to assess public nuisance impacts.28 .
SASEM is frequently packaged with the Emission
Production Model (EPM) as the Tiered Smoke Air Resource
System (TSARS). The EPM is designed to estimate total
emissions for tracking emission reductions and to become the
front end to a dispersion model. The EPM first calculates
fuel consumption for each fuel-bed component. The
proportion burned in the two combustion stages is then
computed for each fuel-bed component and multiplied by
predicted fuel consumption. The mass of fuel burned in all
components is summed to estimate total fuel consumption,
flaming stage consumption, and smoldering stage consumption.
Those values are multiplied by fire size, and the
appropriate emission factor, to compute emission yield from
3-9 September 1992
-------
each stage of the burn. The proportion of fuel consumed per
minute is derived for each stage. The average rate
proportion for each 10 minutes is multiplied by emission
yield to predict flaming and smoldering emissions. The
emission strengths are then summed to estimate total
emissions.29
The EPM uses up to 22 variables (e.g., ignition period,
fuel moisture, preburn fuel loading) to predict fuel
consumption, select emission factors, or solve rate
equations. Default values can be substituted for any of the
inputs.30
3.2.2.2 TAPAS. This computer^ system was developed by
the U.S. Forest Service. TAPAS contains terrain modules,
dispersion models, and graphic display procedures, and is
applicable to complex terrain. At the present time, TAPAS
does not have a front end emissions production model for
predicting smoke production and heat release rates from
prescribed burns.31 Therefore, in order to use TAPAS, the
manager will require some knowledge of relationships between
fire and emissions.32 TAPAS has been described as being too
large and difficult to use for implementation at the local
level because it is a large system requiring the use of
mini-mainframe computer capacities to house and run. The
system requires large amounts of data, much of which most
smoke managers do not have available to them.33
Documentation and more information on TAPAS is available
from the Rocky Mountain Experiment Station, Fort Collins,
Colorado.
3.2.2.3 PUFF. This model, which runs on an IBM
compatible PC-based microcomputer, is designed to predict
the smoke plume path and calculate the concentration of
particles in the plume path. The model, like SASEM, uses
fire parameter input from EPM. Meteorological data input
are composed of forecast pressure obtained from the National
3-10 September 1992
-------
Weather Service (NWS) Nested Grid Model (NGM). Output from
the NGM has a new forecast wind field every 6 hours out to
48 hours. Options will eventually be available to use other
meteorological inputs to initialize the wind field, such as
climatological winds or the actual wind field for post-burn
analysis. The model performance is particularly sensitive
to the smoldering phase of a fire when the heat production
is low and the smoke tends to remain close to the surface,
which is when the threat of an intrusion close to the burn
site is high.34
This model can handle up to 20 fires simultaneously.
Additionally, particle concentrations from multiple plumes
can be summed over time and space. ^This information, along
with weather forecasts, can be evaluated to determine if the
level of risk is low enough to make a "go" decision on an
individual burn or a combination of burns.35
The performance of this model was scheduled to be
validated during the spring 1991 burning season.36
3.3 STATE PROGRAMS
State's with smoke management programs conduct smoke
dispersion evaluations using many of the same meteorological
elements in the development of weather categorization
models. Only Wyoming requires the use of a smoke dispersion
computer model (i.e., SASEM) in the burn/no burn decision.
There are two distinct ways in which the States apply
smoke dispersion evaluations. Some States use smoke
dispersion evaluation to determine beforehand burn/no burn
days without regard to actual number or type of burns being
requested to be conducted that day. Other States use smoke
dispersion evaluation to determine whether or not a
requested burn should be permitted to occur on a particular
day or the one following.
Most States conduct little, if any, smoke dispersion
evaluation during the course of a day once the burns have
begun. A number of the States require burners to observe
3-11 September 1992
-------
changing weather patterns, smoke drift, and/or smoke buildup
during the course of the day to determine whether the burn
should be extinguished. Of the States surveyed, Oregon's
smoke management program for open field burning in the
Willamette Valley conducts the most aggressive real-time
smoke dispersion evaluation program once burns have begun.
The ability to conduct this type of aggressive program is
due, in large part, to features of open field burning that
are not typical of wildland burns. For example, the terrain
of field burning is much flatter than the terrain associated
with many wildland burns. This allows for easy application
of techniques for extinguishing existing burns.
The following is a discussion ^of the elements of
selected examples of State programs that deal with smoke
dispersion evaluation.
3.3.1 Arizona
The State makes no formal declaration of a burn/no burn
day for prescribed forestry burns. Instead, the Arizona
Department of Environmental Quality (ADEQ) makes individual
burn approval determinations for each prescribed burn.
These determinations are based on information concerning
weather conditions, dispersion forecasts, and the status of
previous fires in the area. No computer models are used by
ADEQ in determining whether a burn can be conducted or how
much burning can occur.
In Arizona, the normal procedure is for an agency or
individual to call the ADEQ and give notice of its intent to
burn, either on the day before the burn is to take place or
on the morning of the proposed burn. During this
conversation, the ADEQ tries to obtain information about
local weather conditions and trends, how well smoke in the
area could or is dissipating, and the status of the caller's
previous burns (if any) in the area.37
3-12 September 1992
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In addition to the information obtained through the
phone call, the ADEQ also considers" the following
information: .
' - _ i
weather and dispersion forecasts as supplied by the
NWS (discussed below);
local weather conditions and limitations;
size of the prescribed fire;
location of the prescribed fire;
fuels to be burned;
potential smoke impacts of both the plume and
residual smoldering; and
other active local burns.38^
Other factors in approving a proposed prescribed burn
may be considered as well. A decision is usually rendered
by 9:00 a.m. of the morning of the proposed burn.39 The
decision is conveyed over the telephone to the burner, who
is usually asked to call the DEQ for the decision.40
The NWS provides upper air data in the daily
ventilation forecast for three sites within the State. The
smoke management and ventilation forecast is based on mixing
height and mixing layer transport winds, which results in a
category description of ventilation ranging from excellent
to poor. A prediction of the following day's ventilation is
included in the smoke management forecast. The ventilation
forecasts are made from August through early November, which
are the times of highest prescribed fire activity, and are
provided to ADEQ and all land management agencies that have
Data General computers or the AFFIRMS linkage.41
The BLM, the U.S. Forest Service, and the Bureau of
Indian Affairs (BIA) maintain meteorological measurement
sites (for forest meteorology) with access to data on
temperature, wind speed, wind direction, relative humidity,
fuel moisture, dew point, barometric pressure, solar
radiation and precipitation levels. All these data are
available through the AFFIRMS or Weather Check systems.42
3-13 September 1992
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Agricultural burning in Arizona is not regulated under
these requirements, although a permit is still required.
Agricultural burning tends to take place without regard to
t
severe fire weather conditions and with little regard for
poor smoke dispersion conditions.43
3.3.2 California
The California Air Resources Board (GARB) identifies
burn/no burn days based on the State's own telemetry system.
This system provides information on air quality and
weather/dispersion parameters.44 In California, the term
"permissive-burn" day is used for a "burn day" and means any
day on which agricultural burning is not prohibited by GARB.
A "no burn" day is any day on which agricultural burning is
prohibited by GARB or by a district.45 California law
identifies certain situations in which agricultural burning
is exempt from the guidelines.46
The GARB makes the burn/no burn decision for each of
the air basins in the State. The criteria used in
determining a permissive burn day or a no burn day vary from
air basin to air basin. Generally, the criteria include one
or more of the following:
height above sea level at which the burn will take
place;
atmospheric pressure;
temperature difference at 3,000 feet above the.
surface;
wind speed at 3,000 feet above the surface;
mixing layer wind direction, height, and maximum
depth;
on-shore air flow; and
height of inversion.
Table 3-1 presents the criteria for determining
permissive burn days for two of the air basins in
California. Notwithstanding the criteria used to determine
3-14 September 1992
-------
burn/no burn days, GARB may announce a burn/no burn day
based on expected meteorological conditions and on the
estimated effect on air quality from agricultural burning.47
Forestry, rangeland, and.wildland vegetation burning
are also regulated under the agricultural burning
guidelines. For these burns, the State will issue a notice
up to 48 hours prior to the date of the scheduled burn as to
whether the burn can be conducted (a permissive burn notice)
or not (a no burn notice).48 In issuing these notices, the
State may consider (1) the specific site and its location
relative to populous areas, (2) the stated amount of
material to be burned, and (3) the expected impact that the
burn will have on air quality in modifying the
meteorological criteria used to determine permissive burn
days for agricultural burning in the particular air basin.49
3.3.3 Montana
The daily operation and management of the Montana
Cooperative Smoke Management Plan is conducted by a two-
person unit referred to as the Monitoring Unit. The *
Monitoring Unit is composed of a certified consulting
meteorologist from the Air Quality Bureau of the Montana
Department of Health and Environmental Sciences and a
forester specializing in fuels management from the Division
of Forestry of the Montana Department of State Lands.50
The Monitoring Unit is responsible for regulating
prescribed forestry burning between September and November
by participating members of the smoke management program.
During that period, the Monitoring Unit makes a decision
each day as to whether or not any restrictions on burning
are necessary for the following day. Information used to
decide what restrictions, if any, are to be imposed include:
the amount of burning planned;
forecasted weather conditions; and
an evaluation of existing air quality.51
3-15 September 1992
-------
TABLE 3-1
METEOROLOGICAL CRITERIA FOR DETERMINING
PERMISSIVE BURN DAYS FOR AGRICULTURAL BURNING,
SELECTED AIR BASINS IN CALIFORNIA
North Coast Air Basin1
above 3,000 feet
Near 4:00 a.m., the mean
500 mb (millibar) height
over the basin is less
than the limiting mean
height as calculated from
tables.
The expected 4:00 p.m.
mean 500 mb height over
the basin is less than
the limiting mean height
given in the tables.
-
below 3,000 feet
(*must meet at least
3 criteria)
Near the time of day
when the surface
temperature is at a
minimum, the
temperature at 3,000
feet above the
surface is not
warmer than the
surface temperature
by more than 10
degrees F, except
that during July
through November it
is not warmer by
more than 18 degrees
F.
The expected daytime
temperature at 3,000
feet above the
surface is colder
than the expected
surface temperature
by at least 11
degrees F for 4
hours.
The expected daytime
wind speed at 3,000
feet above the
surface is at least
5 miles per hour.
The expected daytime
wind direction in
the mixing layer .has
a component from the
cast at a speed of
12 miles per hour or
less.
San Francisco Bay Air Basin2
North Section
Near the time of day
when the surface
temperature is at a
minimum, the
temperature at 2,500
feet above the
surface is not
warmer than the
surface temperature
by more than 13
degrees F except
that during May
through September it
is not warmer than
18 degrees F.
The expected daytime
temperature at 2,500
feet above the
surface is colder
than the expected
temperature by at
least 10 degrees F
for 4 hours.
South Section
Near the time of day
when the surface
temperature is at a
minimum, the
temperature at 2,500
feet above the surface
is not warmer than the
surface temperature by
more than 11 degrees F
except that during May
through September it
is not warmer by more
than 16 degrees F.
The expected daytime
temperature at 2,500
feet above the surface
is colder than the
expected surface
temperature by at
least 10 degrees F for
4 hours.
1 Reference 45, Section 80180. North Coast Air Basin.
* Reference 45, Section 80190. San Francisco Bay Air Basin.
3-16
September 1992
-------
The amount of burning planned is determined by
requiring each prospective burner to submit a daily report
of planned burning for the next day to the local airshed
coordinator by 10:00 a.m. This information is then relayed
to the Monitoring Unit by 11:00 a.m.62
Weather and local air quality data are compiled in the
following ways.
1. Each morning (Monday-Friday) a weather balloon
(pilot balloon or PIBAL with temperaturesonde) is
used to get an upper air sounding at selected cities
in Western Montana. The resulting temperature and
wind information is then plotted by the Monitoring
Unit and relayed to the NWS office at Missoula.53
2. The NWS compiles all available weather data and
issues an updated management forecast each day at
approximately 9:00 a.m., and a forecast for the
following day at approximately 3:30 p.m. These
dispersal forecasts are referenced to existing fire
weather zones and sent out over the data general
computer network. Individual burners may also work
directly with NWS fire weather forecasters to obtain
spot weather forecasts for specific burns.s*
The Monitoring Unit also considers existing air quality
conditions and other local data in each airshed in
determining the need for burning restrictions.
Specifically, the amount of residual smoke from the previous
day's burning is evaluated. The local airshed coordinators
are the primary source of this information.ss
After an analysis of all the available information, the
Monitoring Unit decides whether any restrictions to burning
should be imposed for the following day. These restrictions
can be:
a. statewide;
b. by individual airshed(s);
c. by elevation within an airshed(s);
d. by impact zone(s); and
e. by time periods.56
3-17 September 1992
-------
The Monitoring Unit notifies the appropriate local
airshed coordinator(s) by 4:00 p.m. if restrictions are to
, be in effect for the following day. If no restrictions are
to be in effect for the following day, a "no restrictions"
message is broadcast by 4:00 p.m. The local airshed
coordinators, in turn, notify cooperating agencies and
companies of any restrictions or other messages concerning
burning by 5:00 p.m. the same day. Individual agencies and
companies are entirely responsible to ensure that all
burning crews are aware of restrictions. It is the duty of
the Monitoring Unit to send all information regarding
burning restrictions over the computer network and by
telephone to any local airshed coordinator not on the
v>
network.S7
All imposed restrictions are in effect for the time
period indicated on the daily message, usually 24 hours.
Restrictions for weekends (issued on Fridays) indicate the
effective time period on the message. If it is necessary to
extend restrictions for a second or subsequent day, the
Monitoring Unit reissues them using the same procedures as
described above. If a permitted burner is not notified of a
restriction by 5:00 p.m., it is the burner's responsibility
to call the local airshed coordinator to determine if
burning is authorized for the following day.58
The final responsibility for ignition rests with the
cooperating agency or company. Burners are expected to
curtail burning if, in their opinion, they are not getting
adequate smoke dispersion, or if local weather factors are
such that smoke problems could result. Conversely, if local
weather conditions appear to be more favorable for burning
than what was forecast., burners may contact the appropriate
local airshed coordinator for an exception to the
restriction. The local airshed coordinator consults with
the Monitoring Unit and, if deemed appropriate, the
monitoring unit may then grant an exception to the
3-18 September 1992
-------
National Weather Service
Fire Weather Forecasters
Missoula/Bill ings
Smoke \
Dispersal ]
Forecast
Monitoring Unit
MVssouTa "
Spot
Weather
Forecasts
Burning Restriction
- 8y Airshed
- 8y Elevation
- By Designated Area
Upper Air Sounding
^
t
- Temperature
Profile
- Winds
- Planned Burning
- Existing Air Quality
Local Airshed Coordinator
Planned Burning !
Completed Burning j
Member Field Offices
Figure 3-3. Operational Flow Chart, Montana
SOURCE:. Reference 62.
3-19
September 1992
-------
restriction.59 The total informational flow is shown in
Figure 3-3. fln
3.3.4 North Carolina
Forestry burning operations are managed through
voluntary smoke management guidelines.60 Under these
guidelines,' restrictions are placed on burning considering .
the burn category/forecast, location of the burn, and fuel
loading. The burn category/forecast is a prediction made by
the NWS as to the status of the atmosphere's ability to
disperse smoke from prescribed burns during the day and
during the night for the following day. These predictions
are based on broad-scale weather patterns and, thus, are
generalized for large geographical areas. Predictions are
made for three areas in the State:, coast, mountains, and
central (Piedmont and Coastal Plain).61
The burn category/forecast is determined based on the
combined effects (i.e., the product) of mixing height and
transport wind. The category day/forecast and transport
wind are predicted by the NWS at the Raleigh-Durham airport
and are relayed to each district daily, December 1 through
the last day of May.63 The burn categories/forecasts for
each day are issued at 8:30 a.m. (for daytime forecasts) and
2:30 p.m. (for nighttime forecasts).64 Table 3-2 presents
the various burn categories/forecasts for daytime and
nighttime burns.
The category/forecast day in combination with smoke
drift (wind direction) and distance from smoke-sensitive
areas is used to identify the total tons of fuel that may be
consumed per 16,000 acres (25 square miles). Table 3-3
summarizes these allowable tonnages.
3.3.5 Oregon
3.3.5.1 Field Burning in the Willamette Valley. The
Oregon Department of Environmental Quality (DEQ) has
3-20 September 1992
-------
TABLE 3-2
DAYTIME BURN CATEGORY FORECASTS, NORTH CAROLINA
CATEGORY/FORECAST
WEATHER EVENT
RECOMMENDATION
DAYTIME CATEGORY DAYS
Low level temperature inversion
and stagnant air the en-tire day.
Ho burning.
Inversion until early afternoon
and very light transport wind.
Hid afternoon burning only.
Inversion burnoff
temperature will be given.
Inversion until late morning.
Light transport wind.
Daytime burning only, but
not until given burnoff
temperature is reached.
Little or no inversion. Hoderate
transport wind.
Burning anytime.
Ho inversions. strong gusty
transport wind.
Burning with caution. Good
smoke dispersion, but
adverse fire behavior.
HIGHTTIHE FORECASTS
Stagnant
Low level temperature inversion
and stagnant air all night.
Ho burning.
Very Poor
Sapid inversion set up at sunset
and very light wind or calm.
Terminate burning in late
after noon to allow smoke
dispersal before sunset.
Gradual inversion setup
overnight. Light wind.
Terminate burning around
dusk or shortly after
sunset.
Fair
Weak or no inversion setup over-
night. Light to moderate wind.
Burning anytime.
Ho inversion. Hoderate to strong
and gusty wind.
Burn with caution.
Possible adverse fire
behavior .
SOURCE: Reference 61, pp. 8, 9.
3-21
September 1992
-------
TABLE 3-3
TOTAL AVAILABLE TONS OF FUEL ALLOWABLE PER 16,000 ACRES
FOR FORESTRY BURNS IN NORTH CAROLINA
BURNING CATEGORY DAY
DISTANCE
TO SSA
(miles)
0 - 1/2
1/2 - 5
5-10
10 - 20
20 - 30
30+
1 2
0 0
0 360
(720)
0 720
(1440)
"
0 1080
(2160)
0 1200
(2400)
0° 1440
(2880)
Daytime Burning
3 4
0
450
(900)
900 .
(1800)
1350
(2700)
1600
(3200)
1800
(3600)
Only
(1030)+
720*
1440+
(1440)*
(2160)+
1400*
2880+
(2880)*
(2160)+
2160*
4320+
(4320)*
(6480)+
2500*
5000+
(5000)*
(7500)+
2880*
5760+
(5760)*
(8640) +
5
(1350)+
900*
1800+
(1800) *
(2700)+
1800*
3600+
(3600)*
(5400) +
2700*
5400+
(5400)*
(8100) +
3000*
6000+
(6000)*
(9000)+
3600*
7200+
(7200)*
(10800)+
Day & Nighttime
Burning
Allowed
* Nighttime dispersion poor to very poor
+ Nightime dispersion fair or good
( ) For Understory burns only
SOURCE: Reference 67.
September 1992
3-22
-------
delegated the management and administrative responsibilities
for the smoke management program controlling agricultural
burning in the Willamette Valley to the Department of
Agriculture. The DEQ retains the responsibilities of air
quality monitoring and enforcement.65
This smoke management program provides for daily and
hourly control of field burning according to prevailing
weather conditions. The time, places, and amounts of
burning allowed is designated on a continuous basis each day
so as to provide for a maximum amount of burning (as
required by statute) under optimal dispersion conditions
with minimal impact on the public.66
Limits on field burning in the.. Willamette Valley are
based on consideration of a number of factors: maximum arid
minimum mixing height, average wind speed, relative
humidity, wind direction, temperature, and rainfall. Table
3-4 presents how these factors are considered for
identifying whether there is to be general burning, limited
burning, or no burning.
When the ventilation index [(maximum mixing height x
average wind speed)/I,000] is greater than 15 (e.g.,
atmospheric mixing height is 2,700 feet and average
dispersal winds less than 6 knots), general burning is
allowed, provided it is consistent with minimal potential
impact in populated areas. A "performance standard" exists '
for the Eugene/Springfield area such that minimum
ventilation criteria become more stringent if and when the
cumulative hours of smoke impact in the metropolitan area
increase above an allowable level of 14 hours.68
Burning is limited in any area when the relative
humidity exceeds 65 percent under southerly winds or 50
percent under northerly winds or the ventilation index is
between 10 and 15, except for test fires. Test fires are
used by smoke managers to assess atmospheric dispersion
capacity (by observing smoke plume rise and verifying upper-
level air movement and stability characteristics) and
3-23 September 1992
-------
thereby determine what level of burning, if any, may be
accomplished during existing weather conditions.69
Burning is not allowed when the ventilation index is
less than ten. Burning is also prohibited in areas that
might aggravate downwind pollutant levels already projected
to exceed Federal standards. Other criteria that result in
no burning include: (1) rain (one drying day is required
for each 0.1 inch of rainfall); (2) burn is located upwind
of adjacent city, highway, or airport in a priority area;
and (3) times when two of the three fire hazard conditions
exist (temperature greater than 95°F; relative humidity less
than 30 percent; surface winds greater than 15 miles per
hour). Regardless of dispersal conditions, no further
burning is allowed in the entire Valley when the 250,000-
acre limit has been reached,*** in any district when that
district's allocation limit has been reached, and in the
South Valley on any day when 46,934 acres have already been
burned in the South Valley.
The DEQ uses a comprehensive real-time monitoring of "
wind flows and smoke concentrations at selected sites
throughout the Valley to determine restrictions and to
control burning once it has begun. The telemetered stations
continuously report surface wind speed and direction and
smoke concentrations. The surface wind data are used to
plot probable smoke trajectories and to gain advance '
indication of wind shifts in an effort to avoid direct
intrusions into populated areas. Temperature data are used
to supplement other information in gauging the onset of
nighttime cooling or marine air influence. Smoke
concentration measurements warn of smoke intrusions as they
begin to occur so that immediate corrective action can be
taken.70
***New legislation is being considered that will
significantly reduce the maximum allowable acreage.
(Reference)
3-24 September 1992
-------
TABLE 3-4
REGULATORY CRITERIA LIMITING FIELD BURNING
IN WILLAMETTE VALLEY, OREGON
<*
BURNING
PERMITTED
General Burning
Test Fires
Limited Burning
No Burning
LOCATION
Entire Valley
Entire Valley
Entire Valley
Eugene/Spr i ngf i el d
Entire Valley
South Valley
priority areas
South Valley
All priority areas
Any fire district
METEOROLOGICAL CONDITIONS
Ventilation index greater than 15, only when
appropriate with minimal potential for impact in
populated areas.
Ventilation index 10-15
Relative humidity restrictions
- northerly wind, relative humidity greater than
50%
- southwind, relative humidity greater than 65%
When dispersion conditions are 1 imited or to protect
special events x~
or sensitive receptors
Eugene/Springfield performance standard restrictions
(up to 1,000
acres otherwise allowed per day)
Impact Min. Mixing
Hours Heiqht
0-14 none
15-19 4,000
20-24 4,500
25+ 5,500
Ventilation index less than 10
Upwind of (or near) an area expected to exceed a
Federal or State
air pollution, standard
250,000 acres burned for summer
Rain. One drying day required for each 0.1"
rainf al 1 . May be
waived by ODA.
Occurrence of any two fire hazard conditions:
- temperature greater than 95"F
- RH less than 30 percent
- surface winds greater than 15 mph
Upwind of Eugene/ Springfield
46,934 acres burned South valley in a single day
Upwind of adjacent city, high-way, or airport
District's burning allocation limit reached
SOURCE: Reference 69, p. 15.
3-25
September 1992
-------
Additional local and regional meteorological data are
acquired from other sources. The NWS issues surface weather 9B
observations every hour from a number of stations. This
information, provides the basis for tracking large scale
weather changes and is used to project mesoscale pressure
gradients and temperature distributions affecting air flow
and atmospheric mixing in the Valley. The NWS also issues
periodic regional weather forecasts and prognoses, and
twice-daily .reports on upper-level temperature and wind
profiles at Salem. Satellite weather imagery is also
received in order to predict weather phenomena not readily
available from other data or visual observations.71
Measurements of upper-level wj,nds are taken by tracking
pilot (weather) balloons at three sites.. This information
supplements visual observations by ground and aerial-based
staff of upper-level smoke plume movement. Additional
measurements are made of rainfall, winds, temperatures, and
humidities at locations throughout the Valley.72
During the course of a typical day, smoke managers will
track the development of meteorological conditions
throughout the morning and by mid-day may schedule a limited
number of test fires. An increased level of burning
activity is then considered based on these test fire results
and existing and forecast conditions.73
3.3.5.2 Slash Burning in Western Oregon. The
Department of Forestry began administering a voluntary smoke
management program for forest land burning in western Oregon
in 1969. In 1972, the State Legislature made the program
mandatory and put it under control of the State forester.
The State forester and the Department of Environmental
Quality cooperate in the administration of the program.74
The normal procedure is fairly simple, but involves a high
degree of coordination and cooperation within and among
agencies and the private sector.
3-26 September 1992
-------
Forecasts and instructions are issued in the afternoon
from the State capital, describing, the following day's
expected conditions of smoke dispersal and transport wind
direction in western Oregon (the area of the State being
regulated by the smoke management program). The
meteorologists also issue burning instructions describing
favored areas where burning could be accomplished with
minimal impact on air quality. The instructions take into
account factors such as elevation, distance to smoke-
sensitive areas and sizes of units to be burned.75 Smoke
drift restrictions also play a large part in determining
restrictions. Table 3-5 presents the meteorological
conditions and their effect on slash burning.
3.3.6 Washington
In Washington, in conjunction with the Washington
Forest Protection Association, the U.S. Forest Service, and
the BIA, the Department of Natural Resources (DNR) has a
smoke management program for slash burning, which occurs in
the western part of the State. This smoke management
program has placed restrictions on the amount of slash
burning that may occur on a given day based on certain
meteorological criteria. Table 3-6 is a summary of how
these criteria restrict slash burning. As seen in Table 3-
6, the smoke dispersion evaluation criteria are essentially
identical to those used in Oregon for slash burning.
In determining the applicable restrictions for a given
day, each local administrator considers the acreage and
amount of forestry slash planned to be burned, the potential
smoke column vent height, the direction and speed of the
smoke plume, mixing characteristics of the atmosphere, and
distance from designated areas of each burning operation.78
The Washington smoke management plan limits the amount
of slash that can be burned in any one day to 75,000 tons of
slash per 500,000 acres. Fewer acres may be burned as
dispersion characteristics and the other factors
3-27 September 1992
-------
TABLE 3-5
METEOROLOGICAL CONDITIONS RESTRICTING
SLASH BURNING IN OREGON
METEOROLOGICAL CONDITIONS
Smoke drift 1s
away from a
principal
population
center.
Smoke drift is
toward a principal
population center
(designated area)
and the smoke plume
height is below a
ceiling specified
for that area
(included are fires
whose smoke vents
into layers of air
that give a
downs! ope
trajectory into a
designated area).
Smoke drift is
toward a designated
area and the smoke
plume will be mixed
through the deep
layer at the
designated area.
(The deep mixed
layer extends from
the surface to
1,000 feet or more
above the
designated area
ceiling).
Smoke drift is
toward a designated
area and the smoke
plume will be above
a stable layer over
the designated
area.
X*-
Smoke plume
vented into a
cloud system
yielding
precipitation.
LIMITS ON SLASH BURNING
No restrictions
No new fire will
be ignited if the
upwind distance
from designated
area is less than
10 miles.
Burning will be
limited to 1,500
tons per 150,000
acres on any one
day if the upwind
distance is 10-30
miles.
Burning will be
1 imited to 3,000
tons per 150,000
acres on any one-
day if the upwind
distances is 30-
60 miles.
No acreage
restriction will
be imposed if the
upwind distance
is more than 60
miles.
Burning will be
limited to 3,000
tons per 150,000
acres on any one
day if the upwind
distance to the
designated area
is less than 10
miles.
Burning will be
limited to 4,500
tons per 150,000
acres on any one
day if the upwind
distance is 10-30
miles.
Burning will be
limited to 9,000
tons per 150,000
acres on any one
day if the upwind
distance is 30-60
miles.
No acreage
restrictions will
be imposed if the
upwind distance
is more than 60
miles.
Burning will be
1 imited to 6,000
tons per 150,000
acres on any one
day if the upwind
distance to the
designated area
is less' than 10
miles.
Burning will be
1 imited to 9,000
tons per 150,000
acres on any one
day if the upwind
distance is 10-30
miles.
Burning will be
limited to 18,000
tons per 150,000
acres or any one
day if the upwind
distance is 30-60
miles.
No acreage
restrictions
apply if the
upwind distances
is more than 60
miles.
No restrictions
SOURCE: Reference 76.
3-28
September 1992
-------
TABLE 3-6
SUMMARY OF SLASH BURNING RESTRICTIONS
FOR SMOKE CONTROL, WASHINGTON
Dispersion condition over
Designated Areas (DA) and
direction of drift of smoke
plume
Tonnages of consumable slash that may be burned at any one
time on each 150,000 acre administrative area
Upwind distance of slash from Designated Area (DA) boundary
More than 60 mi. : 30-60 mi.
Within
10-30 mi. " Less than "Designated
: 10 mi. ; Area
Tons
1. Smoke into precip. cloud system Mo restriction
2. Smoke moving away from DA No restriction
3. Smoke moving toward DA
a. Plume will be above stable
layer and above DA ceiling No restriction
b. Plume mixed through deep
layer over DA. Mixing
level more than 1,000 feet
above DA area ceiling
No restriction No restriction No restriction
No restriction No restriction No restriction
c. Plume below DA ceiling
No restriction
No restriction
18,000
9,000
3,000
9,000
4.500
1,500
Hop up any
acreage in
excess
6,000
3,000
No new f i res
Mop up residual
fire
3000
3000
2000
None
None
NOTE: The Department of Natural Resources has authority to further restrict burning due to excessive residual
smoke or potential smoke accumulation in localized areas.
SOURCE: Reference 77.
September 1992
3-29
-------
deteriorate. The following summarizes how these factors
affect the amount of acreage that may be burnedi
When smoke can be vented to a height above the cloud
base from which precipitation is falling, the maximum daily
limit applies, except burning in a designated area, which is
limited to 3,000 tons of slash.79
Similarly, if the smoke drift is away from a designated
area, no specific slash limitation amount is placed on slash
burning. Burning within the designated area, however, is
limited to 3,000 tons* Within a designated area, "smoke
drift away from a designated area" is defined as smoke drift
away from the higher populated or traveled portions of the
designated area. Regardless, under- this condition, burns
are always to be conducted so as to best accomplish maximum
vent height and minimize nuisance effect on any segment of
the public.80
When the smoke drift is towards a designated area,
restrictions are placed that increase in stringency (fewer
tons are allowed to be burned) up to prohibition of any
burning within the designated area. The level of stringency
is affected by the atmospheric stability, the height of the
plume relative to the ceiling, and the distance of the burns
from the designated area.
The data on the amount and acreage of planned burns are
generated through daily reports of planned burns filed by
the cooperating agencies with the Department of Ecology.
The Department of Ecology provides air quality forecasts and
fire descriptors to the cooperating agencies to help in the
making of the burn/no burn decision. The air quality
forecasts include information on atmospheric stability to
7,000 feet above sea level and average windspeed and
direction at 3,000 and 5,000 feet above sea level. Four
descriptions of atmospheric stability are used: very
unstable, unstable, stable, and very stable.81
As seen in Table 3-6, smoke height is an important
component in determining acreage limitations. Smoke vent
3-30 September 1992
-------
height below the designated area ceiling includes smoke that
remains below the designated area ceiling. This may occur
for reasons of low fire intensity, lowelevation location,
or weather. In addition, upward mixing of smoke may be
retarded.82
Plume mixed through deep layer at designated area
includes smoke that is dispersed from the surface through a
deep layer when it reaches the designated area boundary.
The air is unstable through a deep layer in the designated
area.83
Plume above a stable layer over the designated area
includes a stable layer of air under the smoke plume that
keeps it from entering the designated area.84
3.4 EFFECTIVE IMPLEMENTATION STRATEGY
Each State should forecast daily the capacity of the
atmosphere to disperse smoke from prescribed burning so as
not to violate the NAAQS for PM-10. The daily forecast,
which should be given as early in the day as practicable,
should also include a long-range forecast to allow burners
time to prepare for burns. Smoke dispersion evaluation
should not be done on a burn-by-burn basis. The State
should conduct a two-level smoke dispersion evaluation
program. The purpose of the "first level" smoke dispersion
evaluation is to set overall criteria as to how much burning
will be allowed on any given day. The State smoke
management coordinator would be responsible for determining
the amount of emissions acceptable each day.
The first level smoke dispersion evaluation should
also include modeling, which may or may not require the use
of a computer model. The purpose of this modeling is to
evaluate quantitatively total PM-10 loading from prescribed
burning and other PM-10 sources to ensure that the
cumulative emissions from all burns and other sources in the
nonattainment area and its extended area will not cause or
contribute to exceedances of the PM-10 NAAQS. The burns
3-31 September 1992
-------
that would be released are entered into the model. If the
results of the modeling indicate "no violation," then those MB
burns can be allowed. If the results indicate "violation,"
then the State would allow only the amount of burning that
indicates "no violation" via the modeling.
There are two approaches for obtaining acceptance of a
model in the "Guideline on Air Quality Modeling" (EPA-450/2-
78-027). The formal approach is outlined in a Federal
Register notice Vol. 45, No. 61, Thursday, March 27, 1980,
entitled "Guidelines on Air Quality Models." To obtain
acceptance informally, the State should send a cover memo
and a copy of the model to the Source Receptor Analysis
Branch at EPA's Office of Air Quality Planning and
Standards. The acceptance process still requires time;
however, models can be conditionally approved on a case-by-
case basis.
The meteorological factors to be considered in the
first-level smoke dispersion evaluation include, at a
minimum, atmospheric stability, mixing height or effective
plume rise, and transport wind speed and direction. Local
data should be used for this information. Data from the NWS
concerning larger scale meteorological phenomena that would
affect the dispersion capacity of the atmosphere should also
be reviewed in the forecasts. Nonmeteorological factors,
such as elevation, may also be considered in developing a
smoke dispersion evaluation method.
Meteorological data for the first-level evaluation
should be collected during morning hours. Mixing height
should be determined from temperature soundings, which may
be obtained from aircraft. Pilot balloons or equivalent
should be used to obtain transport wind speed and direction
data. Test fires should be conducted to verify conditions.
Instead of mixing height, effective plume rise may be used.
Determination of effective plume rise should be made using
test fires, aerial and ground observers, and appropriate
predictive equations.
3-32 September 1992
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Each State should evaluate !its own needs and select the
smoke dispersion model best suited to its situation. For
example, if a few large burns dominate, then perhaps a
simple model, such as SASEM, may be appropriate. Where
multiple burns in complex terrain are involved, then more
detailed models, such as PUFF or TAPAS, may be appropriate.
Whichever model (computer or otherwise) is selected by the
State, it should produce quantitative, comprehensive, and
reproducible results that allow jindependent confirmation of
the decisions reached. I
j
The BACM smoke dispersion evaluation should also be
done during the course of a day ;when any burning is being
conducted. The goal of this "second-level" smoke dispersion
evaluation is to ensure that burns do not overload the
atmosphere causing violations of the PM10 standards,
regardless of the original forecast for that day. If it
appears that the burns may cause violations, then steps
I
should be taken to extinguish burns.
The second-level smoke dispersion evaluation should
include monitoring of local weather conditions and smoke
concentrations, and data from the NWS that would indicate
potential changes to the dispersion capacity of the
atmosphere. Monitoring of local weather conditions include
observing shifts in wind directions as indicated by changes
in the plume path, changes in mixing heights, and other
visible indicators related to smoke dispersion.
Sources of PM-10 smoke (e.g., RWC), in both the
nonattainment- area and its extended area, should be included
in all analyses concerning smoke dispersion evaluation. The
burn/no burn decision should apply equally to the
nonattainment area and its exterided area (i.e., areas from
which prescribed burning emissions contribute to PM-10
nonattainment). :
Each level of smoke dispersion evaluation should be
tailored to the location and types of burns associated with
each nonattainment area and its extended area. It is not
3-33 September 1992
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necessary for the State to implement the same smoke
dispersion criteria for each nonattainment area. In fact, flB
it may be entirely inappropriate to do so.
3-34 September 1992
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3.5 REFERENCES
1". National Wildfire Coordinating Group. Prescribed Fire
and Fire Effects Working Team. Smoke Management Guide.
February 1985. p. 15.
2. Reference 1, p. 15.
3. Reference 1, p. 16.
4. Reference 1, p. 16.
5. Leonidas G. Lavdas. An Atmospheric Dispersion Index
for Prescribed Burning. Southeastern Forest Experiment
Station. Research Paper SE-256. October 1986. p. 2.
6. .Horace R. Byers. General Meteorology. 4th Ed.
McGraw-Hill Book Co., NY. 1959. p. 17.
7. Frank Pasquill. "The Estimation-of Dispersion of
Windborne Material." Meteorological Magazine 90:33-49.
1961.
8. Frank Pasquill. Atmospheric Diffusion. 2nd Ed. New
York: John Wiley & Sons. 1974.
9. Frank A. Gifford. "Use of Routine Meteorological
Observations for Estimating Atmospheric Dispersion."
Nuclear Safety. 2(4):47-51. 1962.
10. D. Bruce Turner. "Relationships Between 24-hour Mean
Air Quality Measurements and Meteorological Factors in
Nashville, TN." Journal of Air Pollution Control
Association. 11:483-489. 1961.
11. D. Bruce Turner. "A Diffusion Model for an Urban
Area." Journal of Applied Meteorology. 3:83-91.
1964.
12. Reference 5, p. 2.
13. Reference 1, p. 16.
14. Reference 5, p. 2.
15. Reference 1, p. 15.
16. Reference 1, p. 16.
17. Reference 5, pp. 2,3.
18. Reference 5, p. 3.
19. Reference 1, p. 16.
3-35 September 1992
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20. Personal communication. Chuck Craig, Oregon Department
of Agriculture, with Ken Meardon, Pacific Environmental
Services, Inc. June 24, 1991.
21. Reference 1, p. 15.
22. Reference 5, p. 3.
23. M.L. Sestak and A.R. Reibau. U.S. Bureau of Land
Management. SASEM: Simple Approach Smoke Estimation
Model. Technical Note 382. BLM/YA/PT-88/003 + 7300.
August 1988. p. 1.
24. J.J. Shah, G2Environmental, and R. D. Ottmar, USDA
Forest Service. Air Quality Modeling of Emissions from
Prescribed Burning. Contract No. DE-AC79-86B)61197.
June 1989. p. 6.
25. Reference 23, p. 2.
>^
26. Reference 24, p. 6.
27. Reference 20.
28. Reference 24, p. 6.
29. Reference 24, pp. 6,7.
30. Reference 24, p. 6.
31. Reference 24, p. 3.
32. Reference 1, p. 21.
33. Reference 24, p. 3.
34. R.G. Bachman. USDA Forest Service. Smoke Management
Improvements Through Use of a Plume Trajectory Forecast
Model. (no date) 6 pages, p. 2.
35. Reference 33, p. 3.
36. Reference 33, p. 3.
37. Personal communication. Kathy Stevens, Arizona
Department of Environmental Quallity, with Ken Meardon,
Pacific Environmental Services, Inc. July 30, 1991.
38. P. Lahm. Smoke Management Practices Report: Arizona
Smoke Management Plan. Prepared for: Arizona
Department of Environmental Quality. Contract No.
22XX-XXXOXX-4-6-GC-0003. 1990. p. 26.
3-36 September 1992
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39. Reference 38, p. 26.
40. Reference 37.
41. Reference 38,.pp. 28,29.
42. Reference 38, p. 30. '
43. Reference 38, pp. 66,67.
44. Reference 38, p. 36.
45. California Air Resources Board. Title 17. Subchapter
2. Agricultural Burning Guidelines. Section 80100.
46. Reference 45, Section 80102.
47. Reference 45, Section .80330.
x-
48. Reference 45, Section 80110.
49. Reference 45, Section 80180(a).
50. Montana Smoke Management Memorandum of Agreement.
Revised January 1988. p. 10.
51. Reference 50, p. 10.
52. Reference 50, p. 10.
53. Reference 50, p. 13.
54. Reference 50, p. 13.
55. Reference 50, p. 13.
56. Reference 50, pp. 13,14.
57. Reference 50, p. 14.
58. Reference 50, p. 14.
59. Reference 50, p. 14,
60. Briefing Paper for Gov. James G. Martin. Subject:
Forestry Smoke Management Program. January 15, 1988.
p. 1.
61. National Weather Service. Fire Weather in North
Carolina. October 1986. p. 8.
62. L. Zimmerman. A Guide to the Operation of the
Monitoring Unit of the Montana State Assisted Group.
March 1, 1982.
3-37 . September 1992
-------
63. Reference 60, p. 2.
64. Reference 61, p. 8.
65. Reference 20.
66. F. Hansen, Dir., Oregon Dept.' of Environmental Quality,
to G. Achterman, Governor's Office. Smoke Management
"White Paper." Interoffice Memorandum. May 5, 1988.
p. 4.
67. Voluntary Smoke Management Guidelines (for North
Carolina). February 8, 1988. p. 9.
68. Oregon Department of Agriculture. 1990 Annual Field
Burning Report, p. 7.
69. Oregon Department of Agriculture. Field Burning Permit
Agent's Manual. Prepared fori. Willamette Valley Fire
District Permit Agents. May 1990. pp. 6, 20.
70. Reference 68, pp. 4,6.
71. Reference 68, p. 6.
72. Reference 68, p. 6.
73. Reference 66, p. 4.
74. Reference 66, p. 4.
75. Paul Bell, Don Matlick, and Mike Ziolko, Oregon
Department of Forestry. A Report on Prescribed Burning
in Oregon, 1990. Prepared for: The Joint, Interim
Environment, Energy and Ha2ardous Material Committee of
the Oregon Legislature. p. 16.
76. Oregon Smoke Management Plan Administrative Rule.
Smoke Management Plan, 629-43-043. Paragraph (d).
77. Bert L. Cole, Washington Dept. of Natural Resources.
Air Quality - Prescribed Burning Smoke Management
Program. Revised June 1975. Exhibit 9.
78. Reference 77, p. 8.
79. Reference 77, p. 10.
80. Reference 77, p. 10.
81. Reference 77, p. 6.
82. Reference 77, p. 11.
3-38 - September 1992
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83. Reference 77, p. 11.
84. Reference 77, p. 11.
3-39 September 1992
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-------
4.0 BURN PLANNING, AUTHORIZATION, AND ADMINISTRATION
4.1 INTRODUCTION
By using the results of the smoke dispersion
evaluation, the State knows the capacity of the atmosphere
on any given day to disperse smoke from prescribed burns so
as to avoid violations of the NAAQS for PM-10. In order to
ensure that this capacity is not exceeded, the State must
have in place a procedural framework that allows it to
identify how much burning is being planned and where it is
proposed to occur. This information allows the State to
make decisions as to which burns should be allowed to take -
place on any given day.
This procedural framework, therefore, must identify
methods by which (1) the burners can notify the State of
their wish to burn (burn request); (2) the State can
determine whether the proposed burn can be approved (review
of burn.requests); and (3) the State can identify which
burns will be allowed on any given day (granting of
approval). States with smoke management programs have
different frameworks. These frameworks are discussed as
they relate to burn requests (4.1), review of burn requests
(4.2), and granting of approval to burn (4.3). The chapter
concludes with a discussion of a suggested implementation
strategy for the burn planning, authorization, and
administration element available for the development of
area-specific BACM smoke management programs.
4.2 REQUESTS FOR PERMISSION TO BURN
Requests for permission to burn serves the primary
function of alerting the State of a burners intent to
conduct a prescribed burn. By requiring burners to submit
4-1 September 1992
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some type of request for permission to burn (e.g.,
registration form, application form), the State can obtain
the information it needswhat will be burned, how much, and
where. With this information, the State can begin to:
(1) track how much burning is being planned, (2) evaluate
smoke management needs, and (3) assign priority to
individual burns for days when all proposed burns cannot be
accommodated. This information will also assist the State
in determining who can burn how much if not all burns being
requested can be accommodated on a particular day.
Burn requests are handled very differently among the
States. Some require notification 1 year in advance of all
planned burns (e.g., Arizona), while others may only require
notification the day of the planned burn (e.g., North
Carolina). Some States (e.g., Colorado) use a single-step
notification process, while others (e.g., Montana) use a
two-step processregistration followed by a request to burn
on a particular day. The procedures used by six States for
receiving burn requests are described briefly below focusing
on who needs to submit the burn request, when it needs to be
submitted, and what information is required.
4.2.1 Arizona
In Arizona, an annual permit application is required
from each burner planning to conduct a prescribed wildland
burn. The application for the burn permit is submitted to
the Arizona Department of Environmental Quality (ADEQ) by
June 1 of each year and it must cite all planned burns for
the following fiscal year. The information in the permit
application is as follows:
estimated date of burn?
location;
elevation;
description of fuel to be burned"(e.g., type of
fuel, size distribution of fuel);
4-2 September 1992
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prescribed conditions (e.g., time of day, fuel
moisture, weather);
aspect of any slopes;*
24-hour contact number for responsible person; and
map of the burn with surrounding areas.1
For rangeland burning, it has been noted that the 1
year in advance notification provides hardships on land
owners and managers since they make their decisions based on
where to burn on late summer rains, after the June 1
deadline. In most places, description of fuel cannot be
adequately defined 1 year in advance on rangelands.2
Vx.
4.2.2 California
Everyone in California seeking to conduct a prescribed
burn is required to apply for a permit to burn. Information
included in this application is that which is required by
the designated agency for fire protection purposes and the
district in which the proposed burn is located.3 For
example, the Northern Sierra Air Quality Management District
(AQMD) requires the following information:
name and address, of the applicant;
location of proposed burn;
acreage or estimate tonnage and type of material to
be burned; and
any other information the air pollution control
officer (APCO) or designated agency may deem
pertinent.4
State law requires a permit applicant to file with the
district a statement from the Department of Fish and Game
certifying that the burn is desirable and proper for those
""Aspect of slope" affects the drying of fuels and fire
behavior. Fuels located on south-facing slopes dry faster
than those on north facing slopes.
4-3 September 1992
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burns done primarily for improvement of land for wildlife
and game habitat.5
State laws also require the following information to be
submitted for wildland vegetation management burns that
exceed a predetermined size or tonnage threshold level, or
for burns situated in zones specified by the district, for
review and approval in advance of the proposed burn:
location and specific objectives of the burn
project;
acreage or tonnage, type, and arrangement of
vegetation to be burned;
directions and distances to nearby sensitive
receptor areas;
fuel conditions, combustion, and meteorological
prescription elements developed for the project;
projected schedule and duration of project ignition,
combustion, and burndown;
specifications for monitoring and verifying critical
project parameters; and
specifications for disseminating project
information.6
As each air district in California adopts its own plan
for regulating prescribed burning, an air district may have
specialized rules to deal with the special types of fuels
that predominate in the district. For example, in the
Northern Sierra AQMD, each person planning to conduct a
forest, rangeland, and wildlands prescribed burn must first
notify the APCO of the planned burn projects for the
upcoming year, on or before September 1 of each year. This
notification must include the following information:
project number;
compartment/unit number;
project name;
legal description (township, range, section);
county;
4-4 September 1992
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acres;
tons/acre;
total tons;
type of burning (hand piles, machine piles,
broadcast); and
priority rating (from most critical to least
critical in terms of achieving the planned
objectives).
Then, at least 30 days in advance of the proposed burn,
each person must submit a burn plan to the APCO for review
and approval. Burn plan preparations that are
unpredictable, but are critical (high priority) for the
upcoming burn season, can be fast-tracked by the APCO and
allowed a shorter than 30-day submission, review and
approval process prior to ignition. The burn plan preparer
must indicate whether such burns must be absolutely executed
in the upcoming burn season or whether other burning
priorities would allow the burning to take place in
subsequent years. The information to be supplied in the
burn plan to the Northern Sierra AQMD is the same as that
listed in Title 17, Section 80175 (7), as identified above.7
4.2.3 Colorado
Under Colorado's smoke management program for
prescribed fire, an application for a permit for each
planned burn must be submitted to the Colorado Air Pollution
Division.8 This application (Form APC-90A) requires
information on: '
name of permittee;
location of burn;
burn dates;
total proposed acreage;
number of piles and average volume per pile; and
relative location to smoke-sensitive area.9
4-5 September 1992
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Applications do not need to be submitted at a
particular time, but the Colorado Air Pollution Control
Division has up to 20 days after receipt of a complete
application to inform the applicant as to whether a permit
in total or in part will be granted or denied.10
4.2.4 Montana
Prior to September 1 of each year, all members of the
Montana State Airshed Group (MSAG) are required to provide
Montana's Monitoring Unit and the appropriate local airshed
coordinator a list of all prescribed burns planned for the
fall burning season. The following information should be
provided for each planned burn: x- .
identification number (assigned by the program
coordinator to each member);
legal description of the site;
elevation;
number of acres;
estimation of fuel loading (tons/acre);
type of burn (broadcast, piles, etc.); and
airshed number.11
Once into the fall burning season, each burner is to
submit to the Monitoring Unit a daily report of the planned
burns for the following day. These reports include:
information on the number of burns planned for the following
day within impact zone(s); number of acres and number for
burns planned for the following day within the airshed, but
outside of the impact zone(s); and identification number for
burns planned for Saturday, Sunday, and Monday must be
submitted on Friday morning.12
Major burners (excess of 2,000 acres of grass or
cropland or 100 acres of forest slash per year) who are not
part of the MSAG are also required to submit a permit
4-6 ' September 1992
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application. Information requested in this application
include for each burn:
name of applicant;
type of material to be burned;
quantity (total acreage) to be burned per year;
number of burns per year required;
location (section, township and range or maps);
elevation;
« acreage?
average fuel loading; and
burn type.13
4.2.5 North Carolina
In North Carolina, prescribed forestry burns do not
need to be "registered" beforehand with the State. . Instead,
on the day of the planned burn, the burner contacts the
designated smoke management coordinator for the burner's
district. The burner provides the smoke management
coordinator with the following information:
total acres to be burned;
fuel tonnages;
name of the burn boss;
legal location of the site;
time of ignition; and
purpose of the burn.14
4 .,2.6 Oregon
Oregon has two major smoke management programs, one for
agricultural (grass seed) burning in western Oregon and one
for forestry (slash) burning in eastern Oregon.
4-7 September 1992
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4.2.6.1 Willamette Valley. In western Oregon, annual
field burning in the Willamette Valley averages around
200,000 acres, occurring from July to October. (As of
July 1, 1991, the legislated limit for any 1 year is 250,000
acres.) Every acre or field of grass seed or cereal grain
crop to be open burned in the Willamette Valley must first
be registered with and approved by the Oregon Department of
Agriculture. There are no exceptions. Registrations apply
to specifically identified fields and cannot be
"transferred" or applied to unregistered acreage.
Registration must be made by April 1 of each year. If a
grower decides to burn a field he did not register by
April 1, he must formally registerxthat field "late"
regardless of his plans for the fields he has already
registered.
Registration means:
a complete and accurate (i.e., a fully executed)
registration form;
map designation of all fields registered; and
payment of the registration fee.
A registration form is really a permit application.
Field-related information reported in the registration form
includes:
UTM coordinates of the field;
number of acres to be burned;
county zone number;
crop type; and
if the field is in a priority area near a city,
airport, or designated highway.15
4.2.6.2 Slash Burning. In eastern Oregon,
approximately 85,000 acres of slash are burned each year.
There are no permit requirements for these burns other than
4-8 September 1992
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pre-registration of burns and submission of monthly accounts
of prescribed burning accomplishments.16
Approximately 100,000 acres of slash are burned each
year in western Oregon.17 Slash burning in western Oregon
is restricted. Except for areas less than 2 acres, all
forest land that is intended to be burned must be registered
with the State Forester at least seven days prior to the. day
of burning. The seven day waiting period may be waived by
the State Forester contingent on a burning plan or
conditions of Federal prescribed fire policies having
already been approved.18 Information to be provided
includes:
location;
topographic features;
tonnage by class and fuel type;
distance to designated area;
acreage; and
type of burn.19
Permits are required to conduct burns located in any
restricted area in western Oregon.20
4.3 EVALUATION OF BURN REQUESTS
Although States review requests to burn before issuing
permits or granting approval, this review appears to focus
on making sure that the request/application is complete.
The level of review may be limited to this one aspect. In
many States, it appears few permits are denied or the rules
do not allow denial of a permit as long as the required
information has been submitted and the proper procedural
steps followed.
The Colorado smoke management plan identifies a number
of factors that will be reviewed before a permit to burn is
granted an applicant. That plan states:
4-9 September 1992
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In reviewing an application for an open burning
permit, the Division will recognize the land
management objectives for which the prescribed
fire is proposed by the applicant and must by
regulation consider several other factors.
o*
a. The existence of no practical alternatives to open
burning.
b. Proximity to populated areas.
c. Potential contribution to area air pollution.
d. Climatic conditions on the day or days of burning.
e. Compliance with applicable fire protection and
safety requirements.21
4.4 GRANTING APPROVAL TO BURN
This phase essentially starts at the point where the
State knows who wants to burn what, how much, where, and
when. A State will then evaluate the smoke dispersal
capacity for each day and follow some procedure for granting
approval to the burners to conduct their burns.
Some States have procedures for determining who gets to
burn a particular day if all requests to burn cannot be
accommodated.- Almost all States provide the burners with
some form of verifiable authorization that the burner has
permission to burn on that day. The size and complexity of
the procedure for granting approval to burn varies greatly
among the States. The following paragraphs describe how
several States grant approval to burn.
4.4.1 Arizona
When the time comes to conduct a burn, the permit
holder contacts the ADEQ the day before or the morning of
the burn. The ADEQ then makes a decision as to whether or
not to allow the burn. The ADEQ does not currently use
procedures to identify initially how much can be burned on a
given day. The decision to allow a particular burn is based
on the following criteria:
4-10 September 1992
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weather and dispersion forecasts as supplied by the
NWS;
local weather conditions and limitations;
other active local projects;
size of the project;
« location; and
fuels and potential smoke impacts of both the plume
and residual smoldering.
Other factors may be considered as well. The decision
of whether or not to allow the burn is usually rendered by
9:00 a.m. the morning of the scheduled burn.22 There is no
formal prioritization of requests, x.
4.4.2 California
When the time comes to conduct an agricultural burn,
such as a rice field, the permittee calls the district for
permission to burn that day. The district will request
certain information from the permittee, including:
agricultural burn permit number;
type of crop waste to be burned;
how long it has been drying;
location of field to be burned; and
number of acres to be burned that day.23
An acreage allocation equation, with a meteorological and an
air quality factor, is used in the Sacramento Valley to
determine distribution of acreages that can be burned in
each district on a daily basis.24 It appears that for
agricultural burning, there is no particular prioritization
procedure other than a waiting list.
The amount of waste that can be burned each day from
range improvement, forestry management, and wildland
vegetative management burns are also set in each district.25
To receive final approval for one of these burns, a
4-11 September 1992
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permittee submits a request for permissive burn or no burn
notice to the State Air Resources Board (ARE) at least 7
days before the date of the burn. The ARE will issue the
notice up to 48 hours before scheduled commencement of the
burn to allow fire managers time to prepare; however, the
ARE may cancel the permissive burn notice if 24 or more
hours remain before the scheduled start of the project, if
such cancellation is necessary to maintain suitable air
quality.26
4.4.3 Colorado
The approval process begins with the review of a permit
application by the Colorado Air Pollution Control Division
(APCD). The APCD then grants a permit with the allowable
dates to burn. Extension or modification of these dates
must be approved by the APCD.27 It then falls upon the
permittee to use their best judgement as to whether or not
to actually conduct the burn on a day covered by the permit.
As stated in the Colorado smoke management plan:
To the degree practical, all burning shall be done
conducive to smoke dispersal. Each signatory
shall use the meteorological information produced
by the National Weather Service Fire Weather
Forecaster before burning. Each signatory shall
endeavor to use the best meteorological
information reasonably available to assure burning
during conditions of at least "good" smoke
dispersal.28
The approved permit or copy must be made available
without unreasonable delay by the permittee upon request by
the APCD or their representative.29
Under Colorado's smoke management plan, it is also the
responsibility of the burners to initiate suppression action
promptly whenever (1) the prescription for a particular
prescribed fire has been exceeded (including impacts on
visibility), and (2) the conditions of the permit are not
being met (e.g., designated areas for burn, notification of
appropriate authorities and agencies).30
4-12 September 1992
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Burners are also required to initiate suppression
action whenever the APCD has determined that a prescribed
fire, planned or natural, is degrading air quality to levels
expected to violate either air quality standards or permit
conditions. Factors that the APCD considers in making this
determination include, but are not limited to:
modeled data that indicate expected violations of any
State ambient air quality standard;
monitored data that indicate expected violations of
any State ambient air quality standard;
proximity of the fire to smoke-sensitive areas,
especially rural or urban population centers;
citizen complaints;
National Weather Service Fire Weather Forecast
predictions;
fuel conditions; and
existing and predicted size of the fire.31
4.4.4 Montana
After completion of the registration/application
process, the granting of approval to burn proceeds as
follows. During the fall burning season, the local airshed
coordinator is notified of the burn plans for the next day
or two by permittees. The coordinator relays this
information to the Monitoring Unit. Also each day during
the fall burning season, the NWS fire-weather forecasters
include a general smoke dispersion forecast in their service
package. Whenever this forecast is less than favorable, the
State's Monitoring Unit meteorologist visits the NWS office
in the afternoon to discuss the need for issuing burning
restrictions. The Monitoring Unit reviews the weather
forecast, the planned burns for the following day, and
reports about air quality that have come into the unit from
airshed coordinator, health department officer, or crews
performing burns that day. Then, the Monitoring Unit
4-13 September 1992
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determines if and where burning restrictions are appropriate
for the next day, and issues such restrictions to all
airshed coordinators by 4:00 p.m.32 Restrictions may be
statewide, by individual airshed, by elevation within an
airshed, by impact zone, and by time period. The local
airshed coordinator then calls each burner in their district
to inform them of local restrictions by 5:00 p.m. of the day
before the scheduled burn.33 The problem of priority, or
whom to call first, is not addressed in the plan.
It is the responsibility of the individual agencies and
companies to ensure that all burning crews are aware of
restrictions. If a burner is not notified of a restriction
by 5:00 p.m., it is the burner's responsibility to call the
local airshed coordinator or the toll-free number in Helena
to determine if burning is authorized for the following
day.34
Even though approval may have been given to burn,
burners are expected to curtail burning if, in their
opinion, they are not getting adequate smoke dispersal, or
if local weather factors are such that smoke problems could
result. Conversely, the Monitoring Unit may grant an
exception to a restriction if local weather conditions are
more favorable for burning than what was forecast. In this
instance, the burner would contact the local airshed
coordinator for an exception to the restriction, who would
then consult with the Monitoring Unit. The Monitoring Unit
would then make the decision as to whether to grant an
exception.3S
4.4.5 North Carolina
In determining whether to approve a particular burn,
the smoke management coordinator determines the distance of
the burn from the nearest smoke-sensitive area and the
allowable tonnage that can be burned based on the category
day. (The tons of fuel allowed to be consumed per 25 square
mile block corresponds to the amount of particulates that
4-14 September 1992
-------
would be released. For each category day, maximum allowable
tonnages of fuel that can be consumed with an acceptable
level of resulting particulates have been determined. The
maximum allowable levels vary according to upwind distance
from sensitive areas.) The coordinator takes into
consideration all burning being done within the area of the
proposed burn for prioritization purposes. If all burning
does not exceed the maximum allowable fuel tonnage, all
applicants are advised burning is allowed. If the tonnage
exceeds the limits, the person making the last burning
reguest is advised to reduce the area to be burned or to
delay the burn.36
4.4,6 Oregon
Oregon's smoke management programs for agricultural
burning in the Willamette Valley and for slash burning use
very different approval procedures. Each program is
described below.
4.4.6.1 Willamette Valley. Grower and field
information from all registrations is entered into Oregon's
DEQ's mainframe computer. After all on-time registrations
have been entered, the computer calculates the percent of
250,000 acres represented on individual registration forms
(the maximum allowed) and assigns each form its appropriate
share of the 250,000 acre total (as a percent). (For
example, if the "allocation percentage" calculated is 80
percent, a registration form showing 100 acres would have an
allocation of 80 acres.) Allocation of allowable acres to
burn is not assigned to individual fields, but to the entire
registration form, whether it has one field or seven, for -
example. The allocation is written at the top of each
registration form. No field may be burned without
sufficient acreage allocation officially issued for it.
Allocation may be transferred between approved registration
forms to accommodate changing circumstances.37
4-15 September 1992
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Registrations, which apply to specifically identified
fields, cannot be transferred or applied to unregistered
acreage.38
Each fire district in the Valley is assigned a series
of registration numbers for its exclusive use. The computer
totals the allocation assigned to each registration number
within a district's sequence to obtain that fire district's
total allocation. In this process, the computer rounds off
each form's allocation to a whole number. This leaves a few
hundred acres of allocation after on-time registrations have
been assigned allocation. This "left over" allocation is
given to fire districts for late registration on a first-
come, first-served basis.39
Next, first phase permits for on-time registrations are
prepared and sent to growers by June 1. Fire districts are
sent copies of first phase permits, along with computer
printouts of registered fields and growers, as close to
June 1 as possible. Each fire district is advised of its
total allocation at that time. This first phase permit
consists of a photocopy of the registration form on one side
and a permit, listing conditions under which burning may
take place, on the reverse.40
Any time a grower wants to burn a field not registered
by April 1, he must complete a "late registration." Late
registration is allowed only if prior ODA approval (based on
availability of unallocated acreage) is obtained (usually by
telephone). Then the following procedure must be carried
out:
complete a registration form with "late" at the top;
complete a "correction/transfer" form; and -
distribute the materials in the usual manner.41
Burn permits are then issued by the permit agent to the
grower for each specified field on the day of the burn, in
exact accordance with the times, places, amounts, and other
4-16 September 1992
-------
provisions and limitations announced by ODA in the burn
release. This burn permit requires:
prior registration of the field and a first phase
permit;
prior issuance of a "validation number" given by the
agent to the grower; and
payment of the burn fee.
A fire permit is also required by State law, to be
issued in conjunction with the.field burning permit, and
should specify any provisions related to protection of
public safety or property.42
4.4.6.2. Slash Burning. The "amount of slash burning
that is approved on any given day depends on the
meteorological conditions and any resulting restrictions
placed on slash burning. These restrictions generally
relate to tonnages of fuel that can be burned per 150,000
acres. Table 3-5 in Chapter 3 summarizes these restrictions
and their associated meteorological conditions. In no
circumstances may forest land be burned without its first
being registered with the State forester.
The following describes the basic procedure for
granting approval to burn:
The smoke management meteorologists in Salem issue
daily weather forecasts to assist the field in
determining how well smoke would disperse and the
expected transport direction. The meteorologists also
issue burning instruction describing favored areas
where burning could be accomplished with minimal impact
on air quality. The instructions take into account
factors such as elevation, distance to smoke-sensitive
areas, and sizes of units to be burned.
After the field administrator receives the afternoon
forecast and instructions, he makes the local
determination of which units he has that would fit the
instruction criteria. He also takes into account local
situations such as nearby residences, existing and
projected forest fuel conditions, and logistical
requirements before approving a burn.
4-17 September 1992
-------
Once the afternoon approval to burn has been given for
the next day's burn, the burner will make plans to get
personnel and equipment in place for the burn. The
next day the local field administrators and landowners
will determine if conditions at the burn site are
acceptable and ensure that there have been no changes
in the forecasts or instructions. If they are
acceptable, the burn will commence. Local monitoring
of the burn will occur to ensure that the fire remains
under control and to determine smoke impacts.
As long as fuel conditions are favorable, the process
will continue on a daily basis. Under favorable
weather conditions, extensive burning may occur. When
stagnant weather conditions exist or are forecast to
occur, burning will be curtailed significantly. When
fuels become either too wet or too dry the process
ceases until fuels are once again within favorable
parameters.43 Xk
The State forester and each field, administrator also
must evaluate the priority rating system prior to approving
burns each day. The forest land burning priority rating
system was begun to reduce the amount of forest land burning
during the time when the maximum acreage of agricultural
burning occurs in the Willamette Valley. Under this system,
forest land burning is limited to those units that must be
burned to meet burning objectives specified in the burn
plan. Only those units that have a high rating will be
approved when "priority" is in effect. The forester gives
notice to all field administrators when the priority system
is initiated and rescinded. The priority rating system is
normally in effect for a 60-day period in mid-summer.44,
4.4.7 Washington
As in Oregon, the amount of slash burning that may be
approved and conducted on any given day depends on certain
meteorological conditions (see Table 3-6 in Chapter 3). The
Washington Department of Natural Resources does not approve
proposed burns of 100 tons (of fuel) or greater on weekends
and holidays between the period of July l through November l
of each year. (Eliminating weekend burning was designed to
4-18 September 1992
-------
improve air quality during weekends.) In addition, burns
are not approved under marginal conditions.45
Within existing smoke management guidelines, approval
for burning should be granted whenever possible in order to
accomplish necessary burning, considering the ban against
weekend burning from July 1 through November l and under
marginal conditions noted above. The typical procedure for
approving slash burning is as follows:
Using the 1:00 p.m. smoke management forecast as a
guideline, regions review and prioritize all proposed
burns on a daily basis. Regions assign highest
priority to prescribed burning being conducted to
eliminate extreme hazards. All burns permissible
considering constraints noted xabove (e.g., no weekend
burns) are given tentative "ok" and forwarded to fire
control for final review. Final approval is made on
the morning of the burn when current weather
information is evaluated and a burn-day declared.46
4.5 EFFECTIVE IMPLEMENTATION STRATEGY
The exact nature of the burn planning, authorization,
and administration (BPA&A) process is left up to the State.
States are encouraged to consider the decision-making
process of planning a prescribed burn in their local areas
as they develop their BPA&A program. At a minimum, a
State's smoke management program should provide procedures
for receiving burn requests, for evaluating burn requests,
and for granting approval to burn.
4.5.1 Burn Requests
All burners should be required to submit to the State
an application to burn (i.e., a burn request). This
includes burners in both the nonattainment area and the
extended area.
Burn requests should be required in a timely fashion so
as to allow the State adequate time to evaluate and
prioritize burn requests and to plan smoke management
strategies. Advanced notification of a burner's intentions
should be designed to allow applicants the opportunity to
4-19 September 1992
-------
properly evaluate their needs (which units and how many
acres) and anticipate fuel loadings and conditions. If the
schedule for submitting the information is "too early," the
burn request cannot be effectively evaluated. A State may
implement procedures that allow different notification
schedules, based on specific considerations of the burns.
Procedures that allow burners to notify the State for the
first time of their intent to burn the day before or the day
of a planned burn would probably be insufficient.
A State may elect to implement a tiered approach for
burn requests, in which the amount of information requested
takes into account the potential significance of the
emissions from the burn and the uniqueness of the burn.
All burn requests should contain at a minimum the
information necessary to allow the State use the smoke
dispersion model selected by the State as part of its smoke
dispersion evaluation.
In addition to the information needed for the smoke
dispersion model, the burn requests for small or simple
burns should contain, at a minimum, the following
information:
a. location (i.e., proximity to PM-10 nonattainment
areas);
b. size of unit (acres to be burned);
c. elevation;
d. type of fuel;
e. type of burn;
f. fuel loading;
g. resource objective(s) [i.e., purpose(s)] of the
burn (e.g., fuel reduction);
h. emission reduction techniques to be used; and
i. firing 'and mop-up plan.
4-20 September 1992
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Similarly, the following information, at a minimum,
should be included in the burn requests for large or complex
burns:
a. estimated date of burn;
b. required signature;
c. burn unit description (including type of fuel,
type of burn, and fuel loading);
d. size of the unit (acres to be burned);
e. vicinity map (location, i.e., proximity to PM-10
nonattainment areas);
f. project map;
NV.
g. legal location of the site (including elevation);
h. resource objective(s) [i.e., purpose(s)] of the
burn (e.g., fuel reduction);
i. treatment objectives of the burn (tons of fuel
removed, etc.);
j. fuel characteristics;
k. weather information;
1. smoke management (elements to be itemized by
individual states);
m. emission reduction techniques used;
n. firing and mop-up plan; and
o. post-burn evaluation.
Burn requests should be signed to stipulate that the
burn will be conducted in accordance with the information in
the burn request. Each burn request should contain a
statement or other means of declaration (e.g.,
identification of personnel and their qualifications) that
the burn will be conducted by personnel meeting the State's
requirements for training, qualifications, and
certifications, as appropriate.
4-21 September 1992
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4.5.2 Evaluation of Burn Requests
Evaluation of burn requests should involve the review
and approval of each burn request. The review of a burn
request would be to ensure that it is complete. If the burn
request is incomplete, the State should implement a
procedure for gathering the missing information.
Approval of a burn request should be limited to a
review of the proposed emission reduction techniques and the
firing and mop-up plan. (Approval of a burn request does
not mean that the burner has been given the "go-ahead" to
burn, but rather the burn request is complete and meets all
of the State's requirements concerning required emission
reduction techniques, firing techniques, and mop-up
procedures.) Approval should be given if (1) the burn
request shows the use of emission reduction techniques,
firing techniques, and mop-up procedures as specified by the
State for that type of burn, or (2) a demonstration by the
applicant that the proposed emission reduction techniques,
firing techniques, and mop-up procedures are at least as
equivalent in emission reduction to those specified by the
State for that type of burn.
The State air pollution agency should be responsible
for evaluating the burn requests. If expertise does not
currently exist within the agency to evaluate the proposed
emission reduction techniques, firing techniques, and mop-up
procedures, the agency should actively seek to develop this
in-house expertise. Until such time, the State should seek
the expertise and advice,of the member agencies and
associations of the National Wildfire Coordinating Group
(NWCG) in the establishment and initial implementation of
the State's BACM smoke management program, recognizing the
long-standing experience and insights of those members.
4.5.3 Approval to Burn
Granting approval to burn should be based on an
analysis that determines the airshed's capacity/capability
4-22 September 1992
-------
to disperse emissions on allowable burn days so that the
cumulative emissions from all burns and other sources in the
airshed will not cause or contribute to exceedances of the
PM-10 NAAQS.
Approval to burn on a burn day should be equitably
assigned among all categories of burners requesting approval
to burn while accommodating the "incentives" specified
elsewhere in this policy. In determining "equitably
assigned," the State should implement a procedure for
prioritizing each burn that is requested, considering the
following factors:
a. availability and costs of alternatives to burning;
x^
b. fuel prescription (window of opportunity);*
c. emission reduction techniques;
d. location of burn (avoidance opportunities);**
e. objective of burn; and
f. others identified by the State.
Each burn request should be assigned to a priority
burning category (e.g., Category I - highest priority,
Category II - next highest priority, etc.). The above
factors are not in any order of importance. The State
should develop their own weighting scheme, with the
participation of all affected parties.
When not all burning within a priority burning category
can be accommodated on a particular burn day (e.g., all
Category I burns can be accommodated, but not all Category
*For example, there is a narrower timeframe, or "window
of opportunity," available to burn a grass seed field than
is available to burn orchard prunings. The scheduling of
orchard pruning burns is usually much more flexible than for
grass seed fields.
**Burning in certain locations may lead to PM-10
exceedances. The State, therefore, may wish to give
priority to those burns that by virtue of their location are
unlikely to create or contribute to PM-10 exceedances.
4-23 September 1992
-------
II burns can be), the first order of determining which burns
are allowed should be based on emission reduction
techniques, with those burns using the most effective
emission reduction techniques and firing and mop-up
procedures receiving first priority.
All approved burns should be provided with verifiable
authorization. Thus, each State should implement a
procedure to provide verifiable authorization.(e.g., written
notification, permits, verbal permit number) to all burners
approved to burn. The type of verifiable authorization used
by the State in granting approval is left up to the State.
At the time of such authorization (e.g., when the permit is
granted), the date of the burn should be recorded. No burns
should be allowed without the issuance of verifiable
authorization.
There should be an appeal process if the burner wishes
to contest any aspect of the burfi approval process.
4-24 September 1992
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4.6 REFERENCES
1. Arizona Air Pollution Control Regulations. Article 4.
Emissions from Existing and New Nonpoint Sources.
R18-2-403. Forestry Management.
2. Personal communication. Greg Hendricks, Soil
Conservation Service, Washington, DC, to K.. Meardon,
Pacific Environmental Services, Inc., Durham, NC. June
26, 1991.
3. California Air Pollution Control Regulations Subchapter
2. Agricultural Burning Guidelines. Article 1.
General. 80120. Burning Permits, (h) and (i).
4. Northern Sierra Air Quality Management District.
Regulation III Open Burning. Adopted 11/10/88. Rule
3/2 Burning Permits.
5. Reference 3, 80160. Range Improvement Burning.(b)(8).
6. Reference 3, 80175. Wildland Vegetation Management
Burning. (b)(7).
7. Reference 4, Rule 316 Burn Plan Preparation.
8. Colorado Smoke Management Memorandum of Understanding.
Colorado Smoke Management Plan. II. Permits, p. 5.
9. Reference 8, Appendix A, Permit Application and
Reporting of Open Burning for Planned Ignition Habitat,
Forest and Range Management Projects. Form APC-90A.
10. Reference 8, p. 6.
11. Montana Smoke Management. Montana State of Montana
Cooperative Smoke Management Plan. (Revised: January
1988). p. 10.
12. Reference 11, pp. 10, 11.
13. Montana Air Quality Bureau. Major Open Burner Permit
Application.
14. North Carolina Division of Forest Resources. Smoke
Management and Fuel Tonnage Estimation Guide. 2/88.
15. Oregon Department of Agriculture. Field Burning Permit
Agent/s Manual. Prepared for: Willamette Valley Fire
District Permit Agents. May 1990. p. 5.
16. Peter Lahm. Smoke Management Practices Report.
Arizona Smoke Management Plan. Prepared for: Arizona
Department of Environmental Quality. 1990. p. 41.
4-25 - September 1992
-------
17. Reference 16, p. 42.
18. Oregon Smoke Management Plan Administrative Rule.
Burning Permits Within Restricted Areas. 629-43-041
(3)(b) and (c).
*
19. Reference 16, p. 42.
20. Reference 18, 629-43-041(1).
21. Reference 8, p. 6.
22. Reference 16, p. 26.
23. California Air Resources Board, Compliance Division.
Agricultural Burning Self-Instruction Handbook. 1990.
p. 3.
24. Reference 3, 80150 Open Burning in Agricultural
Operations in the Growing of Crops or Raising of Fowl
or Animals.(e).
25. Reference 3, 80160. Range Improvement Burning.(b)(2);
80170 Forest Management Burning.(b)(2); and 80175.
Wildland Vegetation Management.(b)(2).
26. Reference 3, 80110. Permissive Burn or No Burn Days.
27. Reference 8, p. 6.
28. Reference 8, p. 8.
29. Reference 8, p. 9.
30. Reference 8, p. 6.
31. Reference 8, pp. 6, 7.
32. Aaron L. Zimmerman. Smoke Management in the State of
Montana. 3 pp. p. 2.
33. Reference 11. pp. 13, 14.
34. Reference 11, p. 14.
35. Reference 11, p. 14.
36. Briefing Paper for Governor James G. Martin. Subject:
Forestry Smoke Management Program. January 15, 1988.
p. 2.
37. Reference 15, p. 9.
38. Reference 15, p. 5.
4-26 . September 1992
-------
39. Reference 15, p. 9.
40. Reference 15, p. 9.
41. Reference 15, p. 10.
42. Reference 15, p. 11.
43. P. Bell, D. Matlick, and M. Ziolko. Oregon Department
of Forestry. A Report on Prescribed Burning in Oregon,
1990. Prepared for the Joint, Interim Environment,
Energy and Hazardous Material Committee of the Oregon
Legislature, p. 16.
44. Operational Guidance for the Oregon Smoke Management
Program. Directive 1-4-1-601. December 1986. pp. 4,
5.
45. Memorandum. Art Stearns, Washington State Department
of Natural Resources, to Regional Managers. Subject:
Prescribed Burning. May 17, 1989. p. l.
46. Reference 45, p. 2.
4-27 September 1992
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-------
5.0 REQUIREMENTS FOR ENSURING BURNER QUALIFICATIONS
5.1 INTRODUCTION
The successful application of prescribed fire depends
on the prescribed fire team members possessing those skills
and qualifications needed to perform their duties. Even
small prescribed burns can create problems (e.g., escape of
fire outside the boundaries of the ^prescribed burn) if not
conducted by qualified personnel. . It is generally
recognized that Federal, as well as some State, natural
resource management agencies currently require certification
that prescribed fire personnel possess certain knowledge,
skills, and experience necessary to carry out prescribed
fire activities. Member agencies of the National Wildfire
Coordinating Group (NWCG) are currently working to establish
minimum national qualifications and standards for prescribed
fire personnel that would be adopted by all "member agencies.
For informational purposes, examples of basic types of
personnel needed to conduct a prescribed burn and their
roles are described. This is followed by an identification
of the basic skills and qualifications generally needed in
each role. Next, a discussion is presented that provides
examples of several Federal agency burner qualification
programs. It is important to note that these will change as
the NWCG develops national standards. The chapter concludes
with a discussion of an effective implementation strategy
for the burner qualifications element available for the
development of an area-specific BACM smoke management
program.
5-1 September 1992
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5.2 PERSONNEL"ORGANIZATION
The conduct of any prescribed burn requires individuals
to perform a number of specific tasks, ranging from setting
the fire to supervising the entire burn. These individuals
are frequently organized according to a chain-of-command
hierarchy, especially for burns conducted by Federal
agencies and large non-Federal burners. Figure 5-1 shows a
typical chain of command for prescribed burns as might be
used by the U.S. Forest Service.
The actual number of people used to conduct a burn will
vary according to the size and complexity of the burn. In
some instances, one individual will play more than one role.
Nevertheless, regardless of the number of people used in a
burn or the number of roles a particular individual plays,
at least eight positions can be identified for each burn to
ensure that all the tasks associated with a prescribed burn
are carried out. These eight positions are:
Project Coordinator
Prescribed Fire Manager
Burn Boss
Fire Behavior and Weather Specialist
Ignition Boss/Specialist
Holding Boss/Specialist
Mop-Up Boss/Specialist
Crew Member (lighting, holding, mop-up)
Table 5-1 summarizes the various typical
responsibilities associated with these positions. The exact
responsibilities may vary depending on the specific burn.
5.2.1 Project Coordinator
The project coordinator directly supervises the
prescribed fire manager and develops the prescribed fire
burn plan for each prescribed fire in the area.
5.2.2 Prescribed Fire Manager
The prescribed fire manager is assigned to the job by
the project coordinator and coordinates the efforts of the
5-2 September 1992
-------
Project Coordinator
Prescribed
Fire Manager
Burn Boss
Fire Behavior
and Weather
Specialist
Ignition
Boss/
Specialist
Holding
Boss/
Specialist
Mop Up Boss/
Specialist
Lighting Crew
Holding Crew
Mop-Up Crew
Figure 5-1. Personnel Used In Typical Prescribed Burn
5-3 September 1992
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TABLE 5-1.
RESPONSIBILITIES OF TYPICAL PRESCRIBED
BURN TEAM MEMBERS
Title
Responsibilities
Project Coordinator
(Prescribed Fire
Planning Specia-
list)*
Supervise prescribed fire
manager.
Develop prescribed fire burn
plans. ^^
Prescribed Fire
Manager*
Implement and coordinate
prescribed fire activities.
Coordinate and schedule the
ignition and management of 2 or
more management ignited
prescribed fires, or the
management of a single
prescribed natural fire.
Develop and implement the
Prescribed Natural Fire Burn
Plan for prescribed natural
fires.
Coordinate personnel and
equipment requirements.
Ensure appropriate public notice
is given prior to and during the
burn.
Coordinate prescribed burn
projects to avoid slop over.
Monitor prescribed burn
projects.
Record and report costs and
accomplishments and recommend
improvements.
Direct supervision of burn boss.
Burn Boss*
Make the decisions to proceed,
accelerate, defer, or curtail
operations.
Certify that the fire is out.
Carry out the duties of the
prescribed fire manager if one
is not assigned.
Ensure safety of personnel.
Supervise all operations on the
site.
5-4
September 1992
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TABLE 5-1,
RESPONSIBILITIES OF TYPICAL PRESCRIBED
BURN TEAM MEMBERS
(Continued)
Title
Responsibilities
Burn Boss
(Continued)
Ensure that the fire
prescription is met before
proceeding with ignition.
Ensure that the forecast and on-
site weather parameters are
within prescription.
Ensure that all Prescribed Fire
Burn Plan requirements are met.
Control directly, or through
supervision of lighting bosses,
the method, rate and location of
firing.
Ensure the availability of fire
suppression equipment.
Monitor the fire behavior.
Supervise mop-up (if mop-up boss
is not used).
Maintain immediate and clear
communications with the lighting
and holding bosses at all times.
Fire Behavior and
Weather Specialist
Collect weather and fuels data
prior to and during burn.
Observes fire behavior and smoke
movement and makes fire
prediction calculations to aid
and advise the burn boss.
Ignition/Lighting
Boss3
Maintain control of all ignition
sources.
Ensure the deployment, sequence,
and timing of all ignition
sources to meet project
objectives.
Supervise assigned personnel and
ensure their safety.
Maintain immediate and clear
communication with the burning
and holding bosses at all times.
If aerial ignition is used,
ensure that the aerial ignition
pilot is briefed on the job
safety and health hazard
analysis.
5-5
September 1992
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TABLE 5-1,
RESPONSIBILITIES OF TYPICAL PRESCRIBED
BURN TEAM MEMBERS
(Concluded)
Title
Holding Boss*
Mop-Up Boss/
Specialist
Crew Member
Responsibilities
Supervise pre-burn crew in
construction of fire control
lines and fire barriers.
Supervise holding crew during
burn and ensure their safety.
Confine the prescribed fire
within the planned area.
Take action when the fire
exceeds, or has the potential to
exceed, the planned area.
Confer with the lighting boss,
burn boss, or prescribed fire
manager to match holding and
fire escape plans with the
firing sequence.
Maintain immediate and clear
communications with the burn
boss, lighting boss, or
prescribed fire manager as
appropriate, at all times.
Supervise mop-up crew.
Set fire.
Hold fire within prescription or
fire lines.
Patrol area.
Mop-up fire after fire fronts
have passed.
a Reference 1.
5-6
September 1992
-------
prescribed fire crew(s). The number of prescribed fire
crews depends on the number and complexity of the burn(s)
occurring simultaneously. The prescribed fire manager has
direct supervision of the burn boss and is responsible for
recording data about the burn, reporting costs and
accomplishments of the burn(s), and recommending
improvements.
5.2.3 Burn Boss
The burn boss is responsible for planning, executing,
and evaluating the prescribed fire. The burn boss
supervises the ignition, holding, and fire-weather
monitoring specialists. The burn boss is responsible for
carrying out the burn according to the burn plan. The burn
boss makes the decision of whether to proceed, accelerate,
defer, or stop operations based on burn plan criteria and
the advice of his crew. In many instances, the burn boss is
also responsible for the mop-up operation. Finally, the
burn boss is responsible for certifying that the fire is
out.
5.2.4 Fire Behavior and Weather Specialist
The fire behavior and weather specialist collects
weather and fuels data prior to and during the burn. The
specialist observes fire behavior and smoke movement and
makes fire prediction calculations to aid and advise the
burn boss as to whether to proceed, accelerate, defer, or
stop operations.
5.2.5 Ignition Boss/Specialist
The ignition boss/specialist is responsible for
planning the type and sequence of ignition prior to the
burn. The ignition boss/specialist supervises the lighting
crew in the deployment, sequence, and timing of ignitions
during the burn. During and after the burn, this specialist
5-7 September 1992
-------
also evaluates the lighting performance job and makes
necessary changes.
i
5.2.6 Holding Boss/Specialist
The holding boss/specialist supervises the pre-burn
crew in the construction of fire control lines and fire
barriers and, during the burn, supervises the holding crew.
It is the duty of the holding crew to confine the fire to a
predetermined area (prescription).
5.2.7 Mop-Up Boss/Specialist
The mop-up boss/specialist supervises the mop-up
operation (if not done by the burn^boss).
5.2.8 Crew Member
Crew members perform the physical job of setting the
fire, holding it within prescription or fire lines,
patrolling the area, and mopping up the fire after fire
fronts have passed.
5.3 NECESSARY SKILLS AND QUALIFICATIONS
As stated earlier, the successful application of
prescribed fire depends on the prescribed fire team members
possessing those skills and qualifications needed to perform
their duties. Typical skills/qualifications associated with
each position are outlined below.
Position Title Required Skills/Qualifications
Project « advanced fire effects
Coordinator prescribed fire manager
certification
Prescribed Fire advanced fire effects
Manager prescribed fire management
smoke management techniques
burn boss certification
5-8 September 1992
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Position Title
Burn Boss
Ignition
Boss/Specialist
Holding
Boss/Specialist
Mop-Up
Boss/Specialist
Crew Member
Required Skills/Qualifications
prescribed fire for burn
bosses
fire suppression tactics
smoke management techniques
fire behavior calculations
certified ignition
specialist
Fire Behavior and «
Weather
Specialist
analysis of prescribed and
natural fires
advanced fire effects
fire supervision
advanced fire behavior
calculations
smoke management course
fire monitoringt
observation ,x.behavior and
use of HP71B calculator
certified crew member
firing equipment and methods
ignition specialist training
certified holding specialist
fire supervision, basic
incident command system
use of pumps, water,
tractors and power saws
crew boss
fire suppression tactics and
behavior
air operations/helicopter
training
fire business management
principles
certified crew member
mop-up supervision
basic firefighting
introductory fire behavior
5-9
September 1992
-------
5.4 FEDERAL BURNER QUALIFICATION PROGRAMS
A survey of several State agencies revealed that the
surveyed States require burners to conduct their burns
according to conditions specified in the burn permit, but do
not require burners to possess certain skills or experience.
On the other hand, Federal agencies that conduct prescribed
burning [Bureau of Land Management (BLM),' National Park
Service (NFS), Bureau of Indian Affairs (BIA), Forest
Service, and U.S. Fish and Wildlife Service (F&WS)] require
the use of qualified personnel in all positions. Each
Federal agency identifies specific skill/knowledge levels
for each position.
The following paragraphs describe the qualifications of
personnel used by the BLM, the NFS, and the BIA in the
conduct of prescribed burns. The NPS and the BIA have
essentially the same qualification requirements. The U.S.
Fish and Wildlife Service's burner qualification program is
not discussed as it is currently undergoing potentially
significant changes.
5.4.1 The Bureau of Land Management2
It is a stated objective of the BLM smoke management
plan to train and maintain qualified personnel to plan,
review, implement, and evaluate prescribed fire activities.
The BLM policy further states that each prescribed fire,
planned and unplanned, is to be managed and executed in
conformance with the approved plan by qualified personnel.
The term "qualified" generally means to include experience,
training, and physical fitness for key positions. All
personnel must be properly trained and qualified in
accordance with the standards presented in Table 5-2.
Seven job categories for prescribed fire positions are
recognized by the BLM. These are project coordinator,
prescribed fire manager, burn boss, ignition specialist,
holding specialist, fire and weather monitor, and crew
member. These are considered by BLM key positions when
5-10 September 1992
-------
implementing any prescribed fire plan. However, not every
prescribed fire will require that each position be filled by
a separate individual, while some prescribed burns will
require additional positions (e.g., mop-up crew).
Each local BLM office planning a prescribed fire
determines the organization that is needed. At a minimum, a
burn boss is assigned to every project, even in the case of
prescribed natural fire on public lands. The BLM personnel
not qualified in one of the aforementioned positions may be
used on prescribed fire duty in a support position only. At
no time are unqualified personnel authorized to be involved
in lighting or holding operations.
x-
5.4.2 The National Park Service/Bureau of Indian
Affairs4-5
The NFS and the BIA have essentially the same
qualifications and are presented together to describe the
roles of each prescribed fire team member and their required
skills, training, and qualifications.
The BIA policy states that each prescribed fire is to
be conducted under the supervision of a qualified burn boss.
This burn boss is to be experienced with the conditions of
weather, fuel, and terrain that are applicable to the
particular prescribed burn being conducted. If complex
burns are being conducted, BIA requires ignition and holding
specialists as well.
Personnel that meet the qualifications required for
each position are to be named in the prescribed fire plan.
The organization will, of course, vary with the size and
complexity of the prescribed fire project. On smaller, less
complex projects, one person may perform all the required
duties; while on larger, complex projects, more people are
required. In any case, the organization must be described
in the prescribed fire plan and qualified personnel must be
used.
5-11 September 1992
-------
TABLE 5-2. BLM STANDARDS FOR PRESCRIBED BURN POSITIONS
Position Title
Qualifications/Experience
Project Coordinator
Prescribed fire management and
organization video; and be able
to perform all of the project
coordinator tasks in the "Pre-
scribed Fire Job Task Hand-
book." NOTE: Fire Effects
course is recommended.
Prescribed Fire Manager
Be able to perform all the
tasks for burn manager in the
"Prescribed Fire Job Task
Handbook"; and in addition have
the experience of acting as
burn boss on two projects.
Burn Boss for specified
fuel group, (e.g.,
grass, brush, chaparral,
slash or timber).
Trained on First Attack
Incident Commander S-200; in
Fire Behavior Calculation,
e.g., as achieved using TI-59
or HP-71B. Completed burn boss
course, Fire Effects course,
Smoke Management course and
understand ignition methods as
appropriate for devices on
project. In addition, have
experience as a qualified
holding specialist and
qualified ignition specialist.
OR
Be certified in all the tasks
listed in the "Prescribed Fire
Job Task Handbook" for burn
boss for each representative
fuel group and have had
satisfactory performance as a
burn boss trainee on two
prescribed fires for each fuel
group in which qualified.
5-12
September 1992
-------
TABLE 5-2.
BLM STANDARDS FOR PRESCRIBED BURN POSITIONS
(Continued)
Position Title
Qualifications/Experience
Burn Boss (Continued)
Burn bosses maintain position
qualifications by successful
performance as a burn boss in
representative fuel group
within the last three years.
Weather and Fire
Behavior Specialist
Trained in Fire Behavior S-390.
Completed satisfactorily
Weather, Soil and Fuel Data
Collection course, have
familiarity with Fire Behavior
Calculations, e.g., using TI-59
or HP-7-1B and have completed
the Smoke Management course and
have experience as a crew
member holding and ignition on
two fires each in fuel group.
OR
Completed Fire Behavior Analyst
S-590 or Fire Behavior for
Managers course and the
Weather, Soil and Fuel Data
Collection course and have
experience as a crew member
holding and ignition on two
fires each in fuel group.
This specialist maintains
qualification by satisfactory
performance as weather and fire
behavior specialist within the
last three years.
Ignition or Holding
Specialist
Be certified in all tasks
listed in the "Prescribed Fire
Job Task Handbook" for ignition
or holding specialist for each
representative fuel group.
OR
5-13
September 1992
-------
TABLE 5-2,
BLM STANDARDS FOR PRESCRIBED BURN POSITIONS
(Concluded) .
Position Title
Qualifications/Experience
Ignition or Holding
Specialist (Continued)
Have experience as a qualified
firing or holding boss, and
have satisfactory performance
as a trainee on two prescribed
fires for each representative
fuel and technique group for
which qualified.
Qualifications are maintained
by satisfactory performance
within the last three years.
Crew Member (holding,
ignition, mop-up)
Trainedx/certified in all tasks
listed in the "Prescribed Fire
Job Task Handbook" for crew
member.
SOURCE: Reference 3.
5-14
September 1992
-------
Table 5-3 identifies the positions and the skills,
training course, and qualifications necessary for an
individual to be certified in each position. The
progressive skill levels within the prescribed organization,
from entry into the system as a prescribed fire crew member
and progressing towards qualification as prescribed fire
manager, have been designed to begin with existing skills
and to build on those skills with additional training and/or
experience for qualification at the next higher position.
A BIA curriculum is now being developed to assist the
resource manager to plan personnel training. The curriculum
is performance-based, encouraging documented on-the-job
training (OJT) whenever possible. "Those needs that cannot
be met by OJT will be met through formal study by a
combination of classroom and self-study processes. The
curriculum promotes on-the-job performance testing rather
than the normal .paper and pencil classroom testing.
Trainees in the prescribed burn boss position are required
to successfully complete two certification burns. These
burns are to be specific to each fuel type. The course on
prescribed fire for burn bosses is the primary training for
burn bosses, providing skills that may not be available in
an ordinary job setting. '
The following paragraphs describe in more detail the
responsibilities and training required for each prescribed
burn position.
5-4.2.1 Prescribed Fire Manager. This individual is
the BIA focal point for all prescribed fire operations. The
person works closely with Tribal personnel as well as other
resource and technical specialists. This position
supervises the burn boss(es) and is assigned based on the
number of and complexity of simultaneous burns. Prescribed
fire managers must be certified as a burn boss.
5-15 September 1992
-------
TABLE 5-3. PRESCRIBED FIRE POSITIONS AND SKILLS,
TRAINING COURSES, AND QUALIFICATIONS NEEDED
FOR CERTIFICATION, NATIONAL PARK SERVICE/
BUREAU OF INDIAN AFFAIRS
Position
Skills, Training Courses, Qualifications
Prescribed
Fire Manager
(RX01)
.Completed two training experiences
Have task book skills provided in:
- RX93 Advanced Fire Effects or Fire in
Resource Management (NARTC)
- RX95 Smoke Management Techniques
Qualified Burn Boss
Prescribed
Fire Burn
Boss I (RX07)
Certified Skill #0204003
Completed two certification burns
Completed task book
Have task book skills provided in:
- S490 Advanced Fire Behavior
Calculations
- RX95 Smoke Management Techniques
Qualified Burn Boss II
Prescribed
Fire Burn .
Boss II
(RX02)
Basic Fire Effects
Fire Behavior Calculations (S390 level)
Field observer skills (map and compass,
etc.)
Fire Effects Monitoring (fire behavior,
smoke, etc.)
HP71B or PC Behavior (Firel, Fire2)
Certified prescribed fire crew member
Ignition
Specialist
(RX03)
Completed two training experiences
Completed task book
Have task book skills in:
- S215 Firing Equipment and Methods
- RX96 - Ignition Spec.
Qualified Holding Specialist
5-16
September 1992
-------
TABLE 5-3. PRESCRIBED FIRE POSITIONS AND SKILLS,
TRAINING COURSES, AND QUALIFICATIONS NEEDED
FOR CERTIFICATION, NATIONAL PARK SERVICE/
BUREAU OF INDIAN AFFAIRS
(Concluded)
Position
Skills, Training Courses, Qualifications
Holding
Specialist
(RX05)
Completed two training experiences
Have task book skills provided in:
- 1220 Basic Incident Command System
- S201 Fire Supervision
- S211 Portable Pumps and Water Use
- S214 Ground Tanker Use
- S215 Driving for Fire Service
- S217 Interagency Helicopter Training
- S230 Crew Boss
- FST Fire Suppression Tactics
- S260 Fire Business Management
Principles
- S270 Basic Air Operations
- S390 Fire Behavior
Qualified Prescribed Fire Crew Member
Fire Behavior
and Weather
Specialist I
(RX08)
Completed two training experiences
Have task book skills provided in:
- RX93 Advanced Fire Effects or Fire in
Resources Management (NARTC)
- S201 Fire Supervision
- S490 Advanced Fire Behavior
Calculations
Qualified Fire Behavior and Weather
Specialist II
Fire Behavior
and Weather
Specialist II
(RX04)
Completed two training experiences
Have task book skills provided in:
- RX91 RX Fire Monitoring
- S244 Field Observer
- S390 Fire Behavior
- HP71B Calculator
Qualified Prescribed Fire Crew Member
Prescribed
Fire Crew
Member (RX06)
Completed two training experiences
Have task book skills provided in:
- S130 Basic Firefighter
- S190 Introduction to Fire Behavior
Viewed Prescribed Fire
Management/Organization Video
SOURCE: References 5, 6.
5-17
September 1992
-------
5.4.2.2 Burn Boss. This person is responsible for
planning, executing, and evaluating a prescribed fire. The
person in this position works closely with the prescribed
fire manager and supervises the ignition, holding, and
weather/fire behavior specialists. The burn boss is
accountable to the prescribed fire manager, or the line
officer if there is no prescribed fire manager. The burn
boss's responsibilities include performing the burn in
accordance with the specific plan and having direct
supervision of the prescribed fire team. A key
responsibility of the burn boss is the decision to proceed,
accelerate, defer, or curtail operations based on completion
of prescription criteria. These decisions may not be
redelegated. The prerequisite qualifications for this
position are certification as ignition specialist and 1C
Type 4.
5.4.2.3 Fire Behavior and Weather Specialist. This
person also reports to the burn boss and is responsible for
collecting appropriate weather and fuels data and for making
fire predictions. The prerequisite qualification for
Specialist II is certification as a prescribed fire crew
member and for Specialist I, certification as a Specialist
II in this grade.
5.4.2.4 Ignition Specialist. The ignition specialist
reports to the burn boss and is responsible for planning,
carrying out, and evaluating the ignition process. The
prerequisite qualification for the ignition specialist is
certification as a holding specialist.
5.4.2.5 Holding Specialist. This person reports to
the burn boss and is responsible for confining the fire to a
predetermined area. Effective supervision and initial
attack procedures are key in this position. The
5-18 September 1992
-------
prerequisite qualification is certification as a prescribed
fire crew member.
5.4.2.6 Crew Member. This person reports to any of
the above specialists positions. In the absence of those
positions, the person would report to the burn boss. The
prerequisite qualification is a firefighter.
5.4.3 U.S. Forest Service
It is the stated policy of the Forest Service to use
only trained and qualified personnel to execute each
prescribed burn.7 Minimum national standards have been
established for prescribed fire specialists and prescribed
fire managers for each of the 24 ski11/knowledge elements.
These standards are shown in Table 5-4.
Each regional forester may establish more stringent
standards for these two positions. It is the responsibility
of each regional forester to set standards for burn boss,
lighting boss, and holding boss. Depending on the specific
region, the regional forester may set requirements in
addition to those identified in Table 5-4.
As seen in Table 5-4, there are three levels of skills
that are used to define the standard for each
ski11/knowledge element: expert, working, and basic.8 A
person who is at the expert level is one who has acquired
advanced skills and knowledge in the use of prescribed fire
in the most complex applications. A person at this level is
capable of working with great latitude and developing
techniques to apply skills to new or unfamiliar situations.
A person at the expert level is able to handle complex
situations where failure could produce serious consequences.
A person certified at the working level is a person
skilled and experienced with prescribed fire and can apply
this knowledge in planning and accomplishing a task. A
person at the working level can perform routine, familiar
jobs with minimum supervision, or in unfamiliar situations
5-19 September 1992
-------
TABLE 5-4. SERVICE-WIDE MINIMUM PRESCRIBED FIRE
SKILL/KNOWLEDGE ELEMENTS TABLE, U.S. FOREST SERVICE
Skill /Know! edge
Elements
1. Safety
2. Fire history
3. Fire ecology
4. Uses of prescribed fire
5. Fire effects
6. Fire behavior
7. Objectives
8. Site descriptions
9. Fire prescriptions
10. Firing techniques
11. Equipment capabil i ties
12. Personnel capabil ities
13. Supervision and organization
14. Legal requirements
15. Public information
16. Smoke management
17. Fire suppression technology
18. He! i copter /Aerial ignition
operations
19. Prescribed fire evaluation
20. Cost analysis
21. Risk assessment
22. Wilderness values
23. Wilderness objectives"
24. Management of long duration
fires
Prescribed
Fire
Special 1st
2
1
1
1
1
1
1
2
1
1
2
1
2
2
2
2
2
1
2
2
1
1
1
1
Prescribed
Fire
Manager
2
1
1
1
1
1
1
1 "
1
2
2
1
2
1
2
1
2
1
1
1
1
1
1
1
Burning
Boss
_
_
_
_
_
_
_
_
_
_
_
.
_
_
_
.
_
_
Lighting
Boss
_
_
_
.
_
_
_
.
_
_
.
.
.
_
.
_
Holding
Boss
_
.
.
_
,
_
Key: 1 = Expert level
2 = Working level
3 » Basic level
SOURCE: Reference 1, Section 5143.1 - National Standards.
5-20
September 1992
-------
with supervision and direction, where failure would produce
less serious consequences.
A person certified at the basic level is one who has
fundamental skills and knowledge in the use of prescribed
fire and can perform the simplest of jobs. Such a person
can handle situations where failure would produce minor
consequences. .
Mastery of the skills listed in Table 5-1 at levels set
by the regional forester enables persons to become certified
for positions on prescribed fire teams for the Forest
Service as well as for other Federal agencies. These skills
are the same knowledge/skills covered by the training
courses mentioned in the discussion- on the NPS/BIA
qualifications, although the standards (levels) may be
different.
5.5 EFFECTIVE IMPLEMENTATION STRATEGY
All burns should be conducted by qualified and
certified burners. "Qualified" means the possession of
quantifiable skills and training. "Certified" means that
the person has passed certain field tests and/or
successfully completed appropriate training courses. Also,
a long-term goal is to support an improvement in the
qualifications and capabilities of all burners.
Burns conducted by Federal agencies are already
required by Agency rules to be conducted by qualified/
certified personnel. As long as such requirements remain in
effect, Federal burners should be exempted from the State's
burner qualification/certification program. The State's
program, therefore, should be directed at the non-Federal
burner, including private landowners who conduct their own
burning.
The size and complexity of burns impacting on a PM-10
nonattainment area will vary considerably, from very small,
simple burns to large, complex burns. Not all burns,
therefore, will require the same number of personnel or the
5-21 September 1992
-------
same structure. The State should evaluate each burn (e.g.,
size, complexity, potential consequences if the fire
escapes) to determine the appropriate number of personnel
and structure needed to accomplish the burn. A State may
elect to develop general categories for grouping similar
burns (in terms of size complexity, etc., not resource
objectives) and then assign a basic structure and personnel
to each category.
While recognizing that the number of personnel required
will vary with the size and complexity of each burn, each
burn should be conducted under the auspices of, at minimum,
a burn boss or equally qualified person. Each burn should
be conducted by someone who is qualified in the basic roles
necessary for each burn. For most burns, this includes
ignition, holding, mop-up, and weather monitoring.
All burners should be trained in smoke management
techniques to ensure that all objectives of the burn,
including emission reduction efforts, are implemented
effectively. The Federal programs discussed in this chapter
provide guidance on the type of training, skills, and
qualifications required on burns conducted by the Federal
land management agencies. These burns are typically large,
complex burns. The level of burner qualification
represented by these programs will not be required for every
burn impacting PM-10 nonattainment areas. Therefore, a
State should relate the skill level and amount of training
required of a burner to the particular circumstances of
burns (e.g., their size and complexity) and to the amount of
burning being conducted by a particular burner. In some
instances, this may require skills and training be at least
equivalent to those specified by the NWCG.
Training- should be reasonably available for all
burners. For burners of exempt burns located in the
extended area, this training may be made available on a
voluntary basis. For all other burners, this training dfe
should be mandatory. Alternatively, the State may waive
5-22 September 1992
-------
training requirements for experienced burners who
demonstrate proficiency in an on-site review.
The State should provide for training seminars and
other institutional opportunities to burners in the State to
gain the necessary skills in smoke management techniques.
To the extent feasible and as appropriate, a State may
utilize course material, training, etc., already used by
Federal agencies.
5-23 September 1992
-------
-------
5.6 REFERENCES
1. U.S. Forest Service. Forest Service Manual, Chapter
5140-Prescribed Fire. Sections 5142.31 through
5142.35.
2. Bureau of Land Management. BLM Manual, 9214-Prescribed
Fire Management. 2/2/88.
3. Reference 2, 9215-Fire Training and Qualifications.
7/7/87.
4. Frank Boden, Bureau of Indian Affairs. Prescribed Fire
System Handbook. December 1986. pp. 7 through 10.
5. Personal communication. Charles Tandy, U.S. Bureau of
Indian Affairs, to Ken Meardon, Pacific Environmental
Services, Inc. June 17, 1991.
6. Bureau of Indian Affairs and National Park Service.
Prescribed Fire Qualifications System^
7. Reference 1, Section 5140.3-Policy.
8. Reference 1, Section 5143.3-Performance Levels.
5-24 September 1992
-------
-------
6.0 PUBLIC EDUCATION AND AWARENESS PROGRAM
6.1 INTRODUCTION
A public education and awareness (PE&A) program can be
directed toward two audiences in order to achieve two
different goals. One goal is to inform the general public
concerned with air quality about what is being done to
address smoke from prescribed burning. The other goal may
be to inform burners of the requirements of a smoke
management program and available emission reduction
techniques. The usefulness of a PE&A program towards
improving the air quality would be hard to quantify in terms
of emission reductions but indirectly some benefits may be
gained. It is also an unenforceable measure and no standard
PE&A program can be defined since it must reflect site-
specific circumstances. Thus, no emission reduction credits
can be awarded for this component of the smoke management
program.
The purpose of this chapter is to illustrate available
methods that can be used to achieve these two goals. The
need for and aggressiveness of a PE&A program will vary from
State to State and thus is left to the discretion of each
State. Therefore, an effective implementation strategy is
not discussed for the PE&A element available for the
development of area-specific BACM smoke management programs.
,' " .
6.2 INFORMING THE GENERAL PUBLIC ~
Smoke from prescribed burning is highly visible to the
general public and can easily cause a nuisance. States that
receive frequent complaints might wish to inform the public
that emissions from prescribed burning are being addressed
through smoke management programs. In describing smoke
6-1 September 1992
-------
management programs/ it should be emphasized that they
include techniques to minimize emissions, as well as
restrictions on when and where burning can occur.
The State may also wish to put prescribed burning
emissions in perspective to the overall PM-10 problem in the
area. It could do this by indicating how much of the
problem is due to prescribed burning in relation to the
other sources of PM-10 and mention, as applicable, that
those sources are also being controlled.
Another possible audience are marketers of equipment
used for alternatives to burning and users of wood products
(to encourage increased use of unmerchantable wood). A
State may wish to encourage businesses to develop innovative
technologies or approaches as solutions to the problem of
alternatives to burning. An example would be to encourage
development of a market for the leftover wood products from
a forest harvesting operation.
6.3 INFORMING THE BURN COMMUNITY
The second goal of a PE&A program is to inform the burn
community of any new obligations they have under the smoke
management program in place and available emission reduction
techniques or alternatives to burning. As opposed to an
informed general public, an informed burn community can
result in improved air quality.
Persuading prescribed burners to change the way they
conduct their burns is an effective means to control PM-10
emission levels. As part of that effort, a PE&A program can
educate the burners to abandon poor prescribed burning
habits. The PE&A program element must take into account the
prevalent burning patterns ~and practices for a given area in
order to know how to target unacceptable (poor) practices.
The use of a survey is one way to obtain this information.
Such a survey is also useful in selecting and developing
program elements to mandate improved prescribed burning
performance.
6-2 September 1992
-------
6.4 PE&A TECHNIQUES1
There are three categories of media for conducting
public information/PE&A efforts: public contact/public
education (education classes and public hearings), broadcast
(TV and radio), and print (primarily newspapers and
brochures). The most effective PE&A program element uses a
combination of these three media which, when coordinated,
forms a comprehensive and potent means of ensuring the best
chance for meeting PE&A goals. Table 6-1 gives the relative
strengths and weaknesses of each medium.
The three types of PE&A media differ in their degree of
impact, from "passive" (broadcast) to proactive (public
contact/public education). Enlisting the help of the news
media to promote strong public awareness of the origin of
ambient smoke and a State's smoke management program may be
desirable. Widespread media support may be obtained by a
strong initial effort to garner press support by holding 1-
day workshops and press conferences that included articulate
experts to discuss the need for the smoke management
program, and an ongoing public information effort that
focuses on the potential adverse environmental impacts of
prescribed burning.
The following is a discussion of the three media
direct public contact, broadcast (or electronic), and print.
6.4.1 Direct Public Contact/Public Education Medium
6.4.1.1 Seminars and Workshops. Washington's PE&A
program element for residential wood combustion (RWC) is an
example of an active public education program that might be
adapted for prescribed burning. In that program,
coordinating classes with the Washington Energy Extension
Office, the State employs wood smoke specialists to conduct
seminars and workshops on different aspects of wood heating.
Through class curricula developed by Washington's Department
of Ecology (DOE), the major message of the workshops is for
each class participant to reconsider, after hearing the
6-3 September 1992
-------
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6-4
September 1992
-------
facts about RWC, the practicality of buying or continuing to
use an RWC device. The degree of receptivity to the ideas
presented in the seminars is gauged by having class
participants evaluate the course.
6.4.1.2 Community Group Programs. The power of
community group programs should not be underestimated.
Again, looking to RWC PE&A efforts, residents in Washington
State formed a nonprofit organization, known as Citizens
Against Woodstoves Fumes (CAWF), that played a major role in
the State's 1987 RWC control legislation. CAWF publishes a
newsletter and has an advisory board comprised of an
environmentally diverse background "of professionals.2
6.4.1.3 Speaker's Bureau. Another approach is the use
of a speaker's bureau, as has been done in Klamath County,
Oregon, for RWC PE&A. In Klamath County, the Klamath County
Health Board developed a list of organizations that would be
likely audience^ for public speaking forums on RWC issues.
The Board also established an industrial education program
that targets employers with printed material and lectures.
The Board then uses the roster of employees of the different
industries as a base for neighborhood meetings.
The neighborhood meeting approach for RWC in Klamath
County involves informal, person-to-person information
sessions in private homes to discuss and present material on
all topics of wood heating. These meetings are held in the
neighborhoods in areas that experience the poorest air
quality conditions and are scheduled to avoid conflicts with
popular television programs.
A similar approach could be adopted for prescribed
burning. A list of organizations that would be likely
audiences for public speaking forums on prescribed burning
issues could be developed. A prescribed burning techniques
education program that targets burners with printed
materials and lectures could be established. Even
6-5 September 1992
-------
neighborhood meetings could be held to discuss and present
material on all topics of prescribed burning. Such meetings
would be held in neighborhoods hardest hit by smoke from
prescribed burning.
6.4.1.4 Public School Programs. For its RWC PE&A
program, Klamath County began two RWC PE&A program elements
in the public school: a "compliance volunteers program" and
a "Breath of Life" fair. The PE&A program for prescribed
burning could implement similar elements. In a "compliance
volunteers program," several prescribed burning issues
(alternatives to burning, pollution, health, emission
reduction techniques, and PM-10 compliance program) would be
addressed through student-oriented projects. T-shirts
displaying related messages and newspapers that the children
write and design themselves would also be part of that
program element.
The "Breath of Life" fair in Klamath County combines
the ideas of an RWC device trade show with public
information about wood heating. A similar fair could be
developed for prescribed burning. The fair would be a
collaborative effort of school administrators, air pollution
agency staff, burners, and local civic groups. The
prescribed burning fair would combine the ideas of an air
pollution control device trade show (in this case,
alternatives to burning and emission reduction techniques)
with public information about prescribed burning. The key
element to this fair would be its emphasis on community
involvement.
6.4.2 Broadcast Medium
The broadcast medium (TV and radio) is the second most
common vehicle for disseminating public information about
PM-10 issues associated with RWC. This medium could be
adopted for prescribed burning messages. TV and radio
"spots" can be used to various degrees of sophistication.
6-6 September 1992
-------
6.4.2.1 Radio-TV-Spots. In Washington, the radio and
television element is a major portion of the State's PE&A
program element for RWC. In addition to the normal spots
run as radio and TV public service announcements (PSA's),
the State produced a public access television program as an
educational tool. Similarly, the Butte-Silver Bow, Montana,
Health Department produced a radio talk show to address
topics relating to wood heating and the local PM-10
ordinance. These ideas can be adopted for prescribed
burning.
6.4.2.2 Telephone Hotlines. Although not a broadcast
medium in the technical sense, the telephone is another type
of electronic media that can be used to inform the public of
different aspects of an area's PM-10 program. The
telephone, through the.use of "hot lines," becomes a de
facto PE&A medium by coordinating public information with
curtailment notices. For instance, by including relevant
information about prescribed burning in the recorded
messages along with notices of curtailment, regulatory
agencies can reinforce the connection between poor
prescribed burning practices and their immediate
consequences (i.e., poor air quality that can necessitate
curtailment).
6.4.3 Print Medium
The print medium is in general the most popular method
to promote public information. Largely because of the many
possibilities for distribution, the printed message is the
linchpin of almost all PE&A program elements. Its two great
advantages are diversity and specialization. Whether
through the most common forms of publications (newspapers
and brochures) or through more novel approaches (posters,
restaurant placemats, utility bill inserts), the print
medium has the greatest potential to reach -the broadest yet
specific target audience. When compared to the costs of
6-7 September 1992
-------
public speaking efforts, printed information is very
economical, making the production and distribution of highly
focused messages a powerful tool.
6.4.3.1 Newspapers. Publicizing prescribed burning
information in the newspapers can be effective because
newspapers usually enjoy a wide circulation and are highly
visible. The fluid nature of newspaper layout allows for
strategically placed items of informationfrom front page
forecasts of the day's air quality or the notification of
that day's curtailment episode, to detailed articles or
regular columns scattered throughout the paper that discuss
selected prescribed burning topics .x Daily (and even weekly)
newspapers that carry some form of PM-10-related information
serve as a regular reminder of the existence of a
community's PE&A goals and efforts towards meeting those
goals. Over time, this awareness can become a conscious
part of a newspaper's readership.
6.4.3.2 Brochures. Brochures are a common type of
printed medium used by many agencies, both public and
private. Figure 6-1 shows an example of a brochure
targeting rice burners in California. This brochure was
produced by the California Air Resources Board.3
The basic information found in one State's pamphlet or
brochure may be useful to another community to educate its
public, but distinctive types of burning between the two
communities may preclude this. Some brochures and fact
sheets of relevant information may be suitable for
reprinting by smaller municipalities with limited budgets.
As an alternative to using PE&A material developed by an in-
house staff or relying on previously published material,
the State of North Carolina worked with an ad agency to
produce a public information campaign on the burning in the
Blue Ridge Mountains of all the trees felled by Hurricane
Hugo.
6-8 September 1992
-------
the burning of aateuttuimtmitartatt produced on cultivated facmtand
yTl This ha
»*J only. tt
' Management and WlMllfe Habitat Improvement oummg. Nordoes tt caver other regulated Open
Burning. Contact your local district for more information about these types of bums. .
Table of Contents
Wiv flecuce Air Psriut.sn
What .sAgncuitufar B^ta-fs
3urning is fleguiatea,
Air Pciluiian Pfooiems
What ts Smotte ...
Smew Contains Toxics
Minimize SmoKa Procya:=n ;
Stale Burning fleouirements .
=-i'Q C.-oo Orvmg Times
f eia Croo igniting Tecnmaues
Diicn ana Weea Burning
C-'cnara ana Vine Burning
2urn ana No-Bum Days
3urmng Hours
Sum Checxiist
Why Reduce Air Pollution?
Air ooiiulion artecis minions ol Caiifomians even/ oay. Sometimes you can sea it ana
feel it wttn everv oreain in
-------
Air Pollution Problems
"ittsu-'tu * la ~^a-av*:iM significant ar^em'cuiccori air
?*« * ^:*t. Ozone. tn«nuior mgrtotem in pnotocnemical smog, is
:*wann tjsfu ciaeavs mm oomiiams win :anwiar names- NO, louces or
!C;in> I'a ~.vcr£earooni cul a.ta damat^es vegetation, necem resaarcn conoucea at ;n«
.'^urttt CT Ci-tsrua at Ftvtrjsoa esomaias inat croo yield reductions m Caiifomia
Si* » oxen* damage eouai ai tta it 330 million doitani eicn year.
PtrticuW* Uatter n me »cona aaa r*siwatoiY«mtant.tt also cotnomaswrttt water vaportoform add
rain and *c*d fog.
Pounds of Pollutants Emitted' from Burning 10 Acres
CiflB'
Almond
Avocado
Qartey
CItru*
Com
Crap*
P**ch\i.
Prun*
Rice
SafttovMf
Walnut
Wheat
J987_ftCTM
416.172
75.297
350,417
239,951
217.725
74,654
57.780
73.421
338.813
72.912
133.312
575.399
.LE"
16
15
17
1O
42
25
25
12
30
13
12
19
02
736
1740
2669
10
4536
1Z7S
1050
504
2S40
1672
564
2052
h£-
96
375
255
90
504
125
100
24
240
260
72
171
EM
96
315
374
60
583
125
150
36
270
234
72
247
£122
42
65
92
43
175
90
118
52
180
58
S2
76
Smoke Contains Toxics
3**3»« -3- trin s-.'mng atsa cortairs sctra marenais
.v«*»ure*otatfoo«uiion « an arecnot tne ormooal source. Insom*
"0«r*. nowtver, < is a significant contributing source.
Why Do People Complain?
T>«m*or*KOO*j*oncomattjras are odor ana fciterterene* wHh vl«iwaty, ootn
Jeuneoeaily ana frem * taitty suneooinc. Smo** from agncusural burning is a
rgn-pfcwe sourc* ot ves* prowems. Ites* acoDonat annoyancas must b* added to
r>e neasn^ciated preotems caused oy oreatnmg MI smoiut oaredej and gases.
Minimize Smoke Production
To Bum Clean and Reduce Smoke, the Fire Must Be HOT!
Burning, or comdusUoo. .aan
burning) ana moisture.
2. Kindling Temperatunt » 're temoeraiure to wmcn a fuel must oe heated to
caicn fire. Wcoc >=-;,:« at tamoeratures oetween 375* ana 5 :0' F Any
* moisture HI or onr^e KJCI-WHI nava to o* boiled oft (at 2171 F, or tess ;or
votaWe piant saoi aeror* tne tuet can gat not enough, to oum w«l. Burning
at lowietnoeraiures creates smofc*. tn* result ot incompMte camouston.
X Oxygen *a>l fuels oanioumthe same way. out afl require ptenty of oxygen from
ttio surreunoing a-r. Smaller daces at fuel wtrt bum easier and (aster tnan
.
TOO iitn* oxygen ts avauaoi*. caroon monairt* and soot are orooucca.
REMEI4BEH!! Dry Fuel. High Temperatures, and PJentgof Oxygan Help
Reduce The Amount of Smoke Generated During A Burn.
NOTE: OaNottrav«yourF>r*Un4m«ad
-------
State Agricultural Burning Requirements
-ciicwirc:re Burning Requirements', steooetow wocarrytne ooiiuiams rue-. -:2 :re air
;-.:s:srB3!pnQ -arcs, ana scatter resveraarcaaarea.
The material to ot Burned sriouia Oe: *
i. F*»e ot Non-Agricultural Materials - no taroaoer.
-snsTttJ&wn csons. oetmtevm wastes, .ires. tar.
eta salvage, oiasocs. etc.
2. Arranged so is to Allow Air to
Circulate ErflfiJif, Staotiooseiv
~il tnat cxyggn in mere!
3. Free of Qirtor Surface Moisture. Dot vmniBurn.
anaitatsoKeeostneair. ana oxygen, away Irom
:-a tuet. Ana mat surface moisture wm nave to
se aoffifffltf oflfowms/uw canneawoenougn
;o cum wnnout excess smo««.
4. Dried For «t t,eajg the Minimum Drying Periods.
You an wasting tuet energy 10 oaii art water
£ tna fuel, ana will generate man smote.
Field Crop Drying Times
is cesenos on ;-ie crop ancire «*! moisture. C.-ee* wnrt vouf otsirict.]
RICE Drying Time aacmrgo r -« Sacramento arto San Joaauin Varlav Air 8asirs
3 Days (or Spread Straw ' 10 Days tor Rowed Straw
The "Crackte" Teat
Sampt* Savcral Arats
:' :r^{ice straw maxes an auoi&e 'crackle ' wnen it is bent sharply, it is dry enaugn to
0'jm.«vanrttMmmirriumciryiivf tr-esarenatcomoiaioa Sevenl straw samples must
Setesteo. mc)udingsam«tromurKMftnemat. iRtnaceflterattrwmat. and tram s
Burning after 0.15" or more flaJn - :ne nee straw must pass tn« "Crackle" Test!
Field Crop Igniting Techniques
i. Use an AoorovM Ignition Device wntcn ooes not oroouce otaot smcKe. sucn az
sutane orosane.LPGofOi«s«ioiiourrers. ASK your osinawnai is aotwovea^ your area
NOTE: A ourning lire is not an aopravw ignition oevice.
Orchard and Vine Crop Burning
Hecomnwnd«d Drying Times:
2. Ugh ti Test Rre. See now weilinew
Ouil tar now it tne tuai is too aamo or s
stamatenat DumsanawneretnesmcKeisgoing
one
-------
Permissive Burn and No-Burn Days
When Cut I Sum? /#
^^
OnPermfssrveBumQays- meteeroioqms
^aveottinnneairiatweainGrca nations
*-J oeflnt good dispersal at :ro smone.
/so may atso need autnoruaacn to ourn
a astna may ceciare ims I
; create a oottntiai fire hazaro.
c tifil en N«-eurn Orrs - metKroto^sn
nave geitrmmea tnai ine atr it
stagnant w«n «tie movement
or venottoon. and ooswxv *rt aov
ajo*3*f«ioo*jtant3 ~
MXM net cuoene,
SSlSeortrMotteiT110^" 1^(Iuma(WWasoeMMrw"rMl»n0wy0ufatf
-ur net betnqaoie 10 oum TODAY. C^ecJS^rSSIa^^^so^e'SS'11
Burning Hours
Ybtx Sum otirm snoua hn tne nours.
Knot, eat your anna. Note-ta.nmng
oetore or «fttf aaowea noun is illcgii.
at a Mhtlns hMlta «n «iliting tlr*.
NO Burning [alflalOamoriflif 3 pm.
Mor* rtitnavt Dwreog roors may M mswww m your a«a at cenan mnt s ot m« y
omtsmoi(»inilr^9. Smoxttuxu
tfl* erauM«ffwxurToo«40own«no'MmcwQam anamfntvmenliaanxi .«/» mar
»T>ow auy net w«y* m« 9«l K»*«r tor good Or dniititlon.
Uit*fl«J |o ^« bum*d must EM (TM o* dirt «nd *MT«C« motnura.
Local District Rules Which Apply:
Approved l^rauan Technique* _
_ Ffcn, and Gam*
_ Before Burning.
Burning Haunt.
Bum Oey %aew InfofTTMttton n
Upft Thet You, me Grower. Can Do to Reduce Air PoHuttoo from Burning:
Ber(4Oei44».tl3S
: (TOTI 44S-9093
__i«
:MiaiaT3-<«00
M9ieie«ft4i4e
(910) 741.7SOO
(!«! 827-4004
Tafec(MeiT4X-e4a4 ^^^
Figure 6-1. Rice Burner Brochure from California
(Concluded)
September 1992
6-12 1
-------
Brochures are especially useful since they can treat
any single topic in as much detail as is necessary. Again,
looking at RWC as an example, a series of brochures dealing
with such issues as catalytic wood stoves, certified wood
stoves, and sizing wood stoves has been developed by
Oregon's Department of Environmental Quality. 4's-6 Similar
brochures could be developed for a variety of alternatives
to burning and emission reduction techniques. These
brochures could lay out specifics about each emission
reduction technique, how to apply it, and its costs.
The value of any brochure, regardless of how well
designed and written it is, depends on getting it into the
hands of the burner community and the public. Mass mailings
is one option. Pamphlets and brochures should always be
available on request. One method of distribution may be to
include brochures along with monthly utility bills.
Perhaps the most potent way of distributing PE&A
material is to mail it with notices of ordinance violations.
This approach has the advantage of reaching a select segment
of the public that could benefit by appropriate educational
material. Receiving prescribed burning information along
with an official citation: (1) reinforces the connection
between poor burning practices and diminished air quality,
and (2) serves as a verifiable record that a violator is
aware of the ordinance and public responsibility.
6.5 PROGRAM IMPLEMENTATION
The public education and awareness program should also
describe what a smoke management program is; its goals
(i.e., to prevent exceedances of the PM-10 national ambient
air quality standards by minimizing or eliminating smoke
production and impacts, to protect visibility, and so on);
and how it functions. The public education program should
be used to explain the procedures used to (1) determine days
when burning can occur, (2) who may burn, (3) where burning
can occur, and (4) how much can be burned. Finally, the
6-13 September 1992
-------
State should be prepared to answer any questions related to
prescribed burning, including but not limited to: What is
being burned in the State? How much is being burned? Where
is it being burned? Why is it being burned? What
techniques are being used to reduce emission from burning?
What alternatives are there to burning and how are they
being utilized?
The State should pursue a specific public relations
process for disseminating information concerning the smoke
management program. In conjunction with the fire management
agency and natural resource agencies, the State air
pollution agency should identify:
a. the audience (e.g., rural-urban, age group, owners
of property, geographic area);
b. time to advertise; and
c. media type.
For example, key times to interact with the public
include:- (1) changes from no burn to burn seasons; (2)
beginning of each burn season; (3) beginning of each
nonattainment season; (4) changes from burn to no burn
seasons; and (5) particular large burns, especially if not
part of normal burns for an area.
The State should consider using all media (e.g., PSA's,
agricultural extension service, brochures, television,
radio, newspaper, etc.). For example, brochures containing
the above information could be disseminated to the public.
The State could use PSA's to inform the public of (1) the
start of the burn season and (2) where information on the
State's smoke management program can be obtained (e.g.,
local agricultural extension offices, State air quality
office, local air quality offices). These announcements
could be transmitted through newspaper ads, television
spots, and radio spots. Information should be made
available through written or telephone requests.
The following is an attempt to characterize three
levels of effort for a stand-alone (i.e., not combined with
6-14 September 1992
-------
other programs elements) PE&A program element. Table 6-2
describes each, of the three hypothetical levels of effort in
terms of communication media and level of intensity (or
frequency). It must be emphasized that these are presented
for illustrative purposes only. The design of a specific
PE&A program element must take into account attitudes,
resources, demographics, and other site-specific factors.
6.5.1 Minimum Level of Effort Use of One Medium Only
Reliance on any one broadcast medium will be the
weakest approach, whereas a comprehensive mix of print,
broadcast, and public contact media would yield the best
results. Of the three media discussed, TV and radio (i.e.,
broadcast).alone would likely be the least effective at
achieving PE&A goals. This medium's primary advantage
appears to be in alerting people to current air quality
conditions for purposes of curtailment, although there is
probably a long-term cumulative effect on the burn community
from repeated warnings and alerts.
6-5.2 Medium Level of Effort Broadcast Plus Public
Contact
A medium level of effort of a PE&A program element
would combine the broadcast and public contact media. A
community could initiate its PM-10 program process through a
PE&A program element that focuses first on at least three
methods of public contact: (1) town or neighborhood
meetings, (2) talks with civic groups (e.g., Kiwanis or
Rotary Clubs), and (3) trade shows. Regulatory agency
officials and health experts would discuss the smoke
management program as a whole, then emphasize the adverse
impacts of prescribed burning that have the greatest
psychological impact on the audience. Once all segments of
the community have had a chance to attend the public forums,
the program element would then rely on a regularly
scheduled, weekly TV and radio PSA's that act as periodic
6-15 . September 1992
-------
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6-16
September 1992
-------
reminders of the PM-10 program, as well as giving
curtailment notification.
6-5.3 High Level of Effort - Multimedia/Extensive Effort
A third, more powerful PE&A program element would
establish a comprehensive network of print, broadcast, and
public contact/public education media, in which each
approach is coordinated with and reinforces the other two.
Public education through workshops, seminars, trade fairs,
and community/public schools would be augmented by an
extensive range of printed material distributed at each
education event. Brochures should cover a range of topics,
including:
adverse effects of prescribed burning;
selection and proper procedures for using emission
reduction techniques; and
alternative options to prescribed burning.
An aggressive public education plan that pairs printed
messages with hands-on involvement forms a robust PE&A
program element in which various agencies can continue to
address PM-10 related issues (health, quality of life,
etc.). Use of printed material such as billboards and
bumper stickers could also be a part of this program
element.
Enlisting the support of the broadcast and newspaper
media early in the PE&A process can help ensure popular
support for the,PM-10 program goals.8 Developing prescribed
burning-related TV and radio programs that go beyond simple
PSA's, as well as regular newspaper articles with in-depth
coverage of relevant topics, is ideal for large metropolitan
areas.
The most effective approach to PE&A program elements
emerges as a broad-based, comprehensive use of public
speakers, all types of printed material, and well-timed,
highly visible broadcast efforts. What is essential for
6-17 September 1992
-------
each regulatory agency is to understand what program
elements are best suited to the unique complexion of the
community. Changing individual habits of prescribed burners
through an enlightened, aware public can be a "very important
component to achieving long-term reductions in PM-10 levels.
The key is establishing, then maintaining, a flexible and
varied PE&A program element that involves the community and
its resources as a whole.
6-18 September 1992
-------
6.6 REFERENCES
1. U. S. Environmental Protection Agency. Guidance
Document for Residential Wood Combustion Emission
Control Measures. Guideline Series. EPA 450/2-89-015*.
September 1985. pp. 2-6 through 2-20.
2. "Citizens Against Wood Fumes Newsletter." Seattle,
Washington. 1988.
3. California Air Resources Board, Compliance Division.
Agricultural Burning Self-Instructional Handbook.
1990.
4. Oregon Department of Environmental Quality. Catalytic
Wood Stoves. Portland, Oregon. 1986.
5. Oregon Department of Environmental Quality. Certified
Wood Stoves. Portland, Oregon, 1986.
6. Oregon Department of Environmental Quality. Sizing
Wood Stoves. Portland, Oregon. 1986.
7. Reference 1, pp. 2-20 through 2-24.
8. N. Maylcutt. Puget Sound Air Pollution Control
Authority, Seattle, Washington. January 17, 1989.
6-19 September 1992
-------
-------
7.0 SURVEILLANCE AND ENFORCEMENT
7.1 INTRODUCTION
When prescribed burns are being conducted, the State
air quality agency and the' burners share concerns regarding
the potential for off-site effects of the smoke on public
health and air visibility. For the State air quality
agency, an immediate concern is ensuring that ambient air
quality standards are not exceeded,- while for the burner,
more immediate concerns are the safety of the personnel
conducting the burn and the property of others that may be
directly affected by the fire (e.g., through an escaped
fire).
Prescribed burns need to be monitored to ensure that
these concerns are met. In addition, a State agency needs
to be prepared to enforce its smoke management program to
ensure that these concerns are met on a continuous basis.
If the smoke management program is properly designed and
implemented in the field, there should be minimum public
complaints. Excessive public complaints may indicate a
poorly designed smoke management plan or improper
implementation by the burner and lack of adequate
enforcement.
This chapter examines methods available to monitor
prescribed burning as it occurs and several examples of
State monitoring programs (surveillance) (7.2) and the means
by which a State enforces its smoke management program
(7.3). In addition, the procedures used by States to handle
complaints are also addressed (7.4). The chapter concludes
with a discussion of an effective implementation strategy
for the surveillance and enforcement element available for
7-1 September 1992
-------
the development of area-specific BACM smoke management
programs.
7.2 SURVEILLANCE
Surveillance can be conducted'to identify (1) changing
weather conditions or air quality levels that indicate the
need to suppress burning activities and (2) violations of
burning permits, smoke management rules, etc. Various
techniques can be used to accomplish these goals. These
techniques include:
Visual Estimates. This is the most common method in
use by land managers to monitor smoke from prescribed
burns. Some agencies use a test fire coupled with
visual observations to ensure xthat the smoke plume does
not affect a smoke-sensitive area.1
Aircraft Plume Tracking. Aircraft tracking is in
limited use by researchers and some regulatory
agencies. In Oregon, aircraft are being used to
identify violations of air quality/smoke management
regulations and to verify forecasts.2 Many burners
also track smoke plumes with aircraft.3
Photo Documentation. Photo points are established
adjacent to project locations to obtain a permanent
record of plume height, color, and direction. This
method has proven valuable in documenting responses to
public complaints.4
Balloons. Small helium-filled balloons can be used by
fire managers to determine mid-level wind direction to
ensure that their smoke does not impact any smoke-
sensitive areas.5
High Volume fHi-Vol) Samplers. The most widely used
particulate matter sampler, the Hi-Vol, is the standard
reference method used by EPA and States to monitor
compliance with the NAAQS for total suspended
particulates (TSP). The Hi-Vol is a large filter
connected to a vacuum type motor/blower and a timer.'
This type ~of sampler "presumes" it is sampling a well-
mixed air sample representative of a very large area
surrounding the sample site. If located near a single
source, the monitoring results will not be
representative of the larger, designated area.6
Dichotomous or Size Selective Inlet Samplers. These
monitoring devices operate like Hi-Vol samplers, but
7-2 September 1992
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are designed to screen out particles larger than 10
microns.7
Beta-gauge Monitors. These monitors measure hourly
particulate concentrations by detecting the reduction
of beta rays as they pass through the sample.8
Nephelometers. These devices measure the amount of
light scattering associated with fine particles in the
atmosphere that reduce visibility. They can be used as
an indication of TSP concentrations if a
nephelometer/Hi-VOl correlation can be established.9
Teleradiometer. This device measures light intensity
or brightness over a given distance or path length,
which may be 20 or 30 miles or more.10
The level of surveillance varies from State to State,
ranging from negligible (e.g., Arizona) to extensive (e.g.,
Oregon). For example, in Arizona, there is basically no
surveillance conducted. Instead, smoke accumulation is
generally gauged by public complaint levels.11 In both
Arizona and Washington, real-time air quality monitoring of
particulate matter levels or visibility reduction is not
used.12 For Federal agencies, considerable effort is often
made to monitor prescribed burns, even in States with
negligible State monitoring. For example, the BIA and the
National Park Service (NFS) have standard monitoring
operating procedures, which are described in the NFS Western
Region Monitoring Handbook 1991.13
The following paragraphs describe several State
programs that incorporate desirable features of a
surveillance program.
7.2.1 Colorado
There is a provision for real-time monitoring in
Colorado's State Smoke Management Plan. Under these
provisions, the Colorado Air Pollution Control Division
(APCD) can require the responsible land management agency to
monitor and/or model pollutants in or near population
centers impacted by smoke from prescribed fire or wildfire
September 1992
-------
when pollutant levels are anticipated to create a
significant threat to human health.14
Under the smoke management plan, the APCD will assist
in the identification of instrumentation; site selection;
installation, operation, and calibration of instrumentation;
quality assurance and control; laboratory analysis; data
interpretation; and supplies. The APCD is allowed to
negotiate on a case-by-case basis with the responsible land
management agency concerning cost sharing and resources
before modeling or monitoring is begun. With respect to
prescribed fires, the smoke management plan states that "the
ultimate responsibility and financial burden is on the land
management agency consistent with the principal that the
source of pollution should internalize the costs of its
pollution."15
Furthermore, the smoke management plan requires the
responsible parties to initiate promptly suppression action
whenever "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.)."16 The
responsible parties are also required to initiate promptly
suppression action whenever the APCD, in consultation with
the responsible land management agency, determines that the
prescribed fire is '^'degrading air quality to levels expected
to violate standards and/or permit conditions."17
Factors that the APCD will consider in determining
whether air quality levels may result in exceedances
include, but are not limited to:
modeled data;
monitored data;
proximity of the fire to smoke-sensitive areas;
a
citizen complaints;
7-4 September 1992
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National Weather Service Fire Weather Forecast
predictions;
fuel conditions; and
existing and predicted size of the fire.18
7.2.2 Montana
The burners are expected to curtail burning if, in
their opinion, they are not getting adequate smoke
dispersion, or if local weather factors are such that smoke
problems could result.19 Most members of the Montana State
Airshed Group (MSAG) only monitor burns through ground
observations.20
The Monitoring Unit of the MSAG is responsible for
notifying Local Airshed Coordinators when acceptable limits
of smoke accumulation are threatened to be exceeded.21 A
nephelometer network, established for monitoring woodstove
smoke, is providing real-time air quality data on
particulates that is helping to increase the accuracy of the
restrictions imposed on prescribed burning.22
7.2.3 North Carolina
Some surveillance of burns is conducted using ground
and aerial visual observations. County personnel will
patrol an area where burns are being conducted. In
conjunction with normal fire patrols, air observation of
fires in an area will also be used on occasion.23 The
Department of Environmental Management has placed
particulate matter samplers around problem locations in the
State to monitor smoke impacts.24
7.2.4 Oregon
7-2.4.1 Willamette Valley. Oregon has an extensive
real-time surveillance network for monitoring prescribed
burning in the Willamette Valley. The methods used include
ground and aerial visual observation as well as various
-'. 7-5 September 1992
-------
types of monitoring devices (particulate samplers,
nephelometers, pilot balloons). Constant aerial
surveillance by trained airplane-based observers is used.25
The air monitoring network, shown in Figure 7-1,
consists of a number of telemetered stations, which.report
continuously on surface winds (direction and speed) and
smoke concentrations. The surface wind data are used to
plot probable smoke trajectories and to gain advance
indication of wind shifts in an effort to avoid direct
intrusions into populated areas. Temperature data are used
to supplement other information in gauging the onset of
nighttime cooling or marine air influence. Smoke
concentration measurements warn of Asmoke intrusions as they
begin to occur so that immediate corrective action can be
taken.26
Pilot balloons are used to take frequent measurements
of upper-level winds. This information supplements visual
observations by ground and aerial-based staff of upper-level
smoke plume measurements.27 Direct visual observation by
inspectors, permit agents, and others often provides
information of possible rule infractions.28
Other data on meteorological conditions and phenomena
are gathered from the NWS and satellite weather imagery to
predict weather phenomena not readily discernible from the
local data or visual observation.29
7.2.4.2 Prescribed Forest Burns. Oregon's smoke
management program for prescribed forest burns requires
periodic aerial monitoring of prescribed burning operations
(discussed in more detail below) and the use of other
monitoring means to ensure compliance with the smoke
management program and to determine the effectiveness of
smoke management procedures. The State forester has real-
time air quality monitoring data available through a
computer link with the Oregon Department of Environmental
7-6 September 1992
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N
GRAND
ROND
BLODGETT
SHEET HOME
- i ^ ^~^<. ^"""'V.
SMOKE MEASURING SITE^' SPRIHG"e.o
A WIND MEASURING SITE
-^COMBINED SMOKE/WIND MEASURING SITE
©PILOT BALLOON (upper winds) MEASURING SITE
Figure 7-1. Willamette Valley Field Burning
Air Monitoring Network
SOURCE: Reference 25, p 5.
September 1992
7-7
-------
Quality (DEQ). This information is to be used by the State
forester in the preparation and validation of daily smoke flB
management instructions as appropriate.30
To evaluate compliance with the smoke management
program, the State forester conducts an audit of
approximately 1 percent of the units burned each year. Each
audit consists of a site visit during the burn, visual
tracking and documentation of long range plume behavior, and
a determination of compliance with the conditions of the
burning permit, provisions of the smoke management
administrative rules and directives, and the smoke
management program instructions.31
During the mid-to-late 1980's^ the Oregon Forest
Service began a limited program of aerially monitoring of
smoke from their burning. Initially, the Forest Service
combined the smoke monitoring flights with existing fire
detection flights during the fire season. By the late
1980's, smoke management flights also occurred outside of
the fire season. Similar, but more limited, monitoring
activities occurred for private land burning.32
Under the current monitoring program, the primary
objective is to maximize burning opportunities while
minimizing the effects of smoke in designated areas. With
aerial monitoring, the Oregon Forest Service expects to be
able to:
track and record actual movement of smoke;
verify weather forecasts;
provide real-time weather-related information to
forecasters and field offices;
evaluate smoke dispersal patterns and downwind
impacts; and
report impacts of other smoke sources.33
Flights are generally scheduled under five conditions: (l)
burns are occurring upwind from a designated area, (2) burns
are on a border with another district or agency, (3) test
7-8 September 1992
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burns are occurring, (4) multiple burns are expected or
clearance has been given to exceed tonnage limits or unit
spacing, and (5) the forecaster requests information to help
him make decisions for his instructions.34
Among the recommendations being made for the aerial
monitoring program are: (1) observer training to ensure
consistency and uniformity in reporting, (2) survey-type
monitoring in central and eastern areas of Oregon to
determine the degree of smoke impacts in those areas,
and (3) establish an efficient means of direct radio
communications between aircraft and the Salem meteorologists
to allow faster response to changing conditions (either to
allow more burning if conditions ar;e favorable or to
accelerate the stopping of burns to avoid smoke impacts).35
7.3 ENFORCEMENT
Depending upon the State, one or more agencies can
enforce rules for controlling wildland and agricultural
burning. In most cases, any one agency does not have
exclusive authority. Federal, State, city, county agencies,
and fire control and air management districts may all be
involved.
The Fire and Fire Effects Working Team's Smoke
Management Guide summarizes penalties for violations and
potential for liability for prescribed fire managers:
Prescribed fire managers are subject to numerous
penalties for violations of open burning rules. These
penalties should not be taken lightly. They can range
from administrative warnings without fines to criminal
proceedings with mandatory fines and jail sentences.
Some authorities have arrest powers, but most use
administrative actions to enforce their rules. More
severe infractions merit civil, injunctive, or criminal
actions. Fines can be as low as $25 for misdemeanors
or as high as over $25,000 per day per offense for
criminal violations. In addition to fines levied
through criminal actions, prescribed fire managers can
also be subjected to civil suits, which can run into
millions of dollars.36
7-9 September 1992
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The following paragraphs describe several State
enforcement programs, focusing on the types of violations
and penalties associated with the violations.
7.3.1 Arizona
In Arizona, any person who violates any provision of
the rules and regulations adopted to control prescribed
forest burns or any effective order of abatement issued
pursuant to prescribed burn rules is guilty of a petty
offense for each day that the violation continues. Peace
officers and the air pollution control officer and his
deputies have been given enforcement authority to issue
notices of court appearance for violations of provisions of
the rules and regulations or any effective order of
abatement issued in conjunction with the articles.37 The
lack of criminal intent shall not constitute a defense to
any violations.38
Open burning permits are subject to revocation if
emissions from the permitted fires create excessive air
pollution, a public nuisance, or a safety hazard.39
7.3.2 California
California law provides that the enforcement of rules
and regulations for open burning are to be specified in each
air quality management district's implementation plan for
open burning.40 .
In a booklet published by the California Air Resources
Board, penalties for violations of agricultural burning
regulations are to include one or more of the following:
a maximum fine of $25,000 per day;
receipt of a citation or a notice of violation;
court appearance;
payment of penalty fees;
loss of agricultural burning permit; and
7-10 September 1992
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reimbursement to the fire department of the cost of
putting out the illegal fire.41
The Northern Sierra AQMD open burning regulations state
that a violation of the provisions of its open burning
regulation, or of the sections of the law dealing with burn
permits (41852 or 41800 of the California Health and Safety
Code), is considered a misdemeanor, punishable by criminal
or civil penalties as specified in section 42400 in addition
to the costs of putting out the fire. Every day during any
portion of which said violation occurs also constitutes a
separate offense.42
7.3.3 Colorado.
The Colorado smoke management plan states that the burn
permit is to ensure compliance with State air pollution
control requirements only and is not a permit for anyone to
violate any existing local laws, rules, regulations, or
ordinances regarding fire and open burning. Land managers
must be certain that their actions comply will all
procedural and substantive requirements contained in State
and local air pollution control regulations and
agreements.43
The Colorado APCD may revoke the permit for a burn if
it determines that any condition of the permit is not being
complied with. At such time, all burning activities at the
site of the noncompliance shall be terminated. In addition
to revocation of the permit, the APCD may take any other
enforcement action authorized under State statutes, rules,
and regulations.*4
7.3.4 Florida
Permission for burning must be obtained from the
Division of Forestry of the Department of Agriculture and
Consumer Services prior to conducting a burn.45 In Florida,
it is unlawful for any person:
7-11 September 1992
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to burn or cause to be burned, or to set fire to, or
cause to be set fire to, any forest, grass, woods,
wildlands, marshes, or vegetative land-clearing
debris owned or controlled by such person without
first obtaining authorization from the Division of
Forestry; or
to fail to provide adequate fire lines, manpower,
and/or fire fighting equipment for the control of
such fire; or
to fail to watch over an authorized fire until it is
extinguished; or
to permit an authorized fire to escape from the
authorized area. However, no authorization shall be
required for the setting of fire in a forest
protection district where written permission to set
such fire has been obtained^ from a duly-appointed
fire warden.46
Any person burning for agricultural, forestry, or land
clearing purposes without the authorization of the Florida
Division of Forestry is guilty of a misdemeanor of the
second degree. This is also the charge for carelessly
allowing any fire to escape control and burn onto the
property of another person. The penalty for a second degree
misdemeanor is up to 60 days imprisonment and/or a fine of
up to $500."
7.3.5 Georgia
In Georgia, any person who violates the State's burning
restrictions is guilty of a misdemeanor and may incur the
liability of a civil penalty not to exceed $25,000 per day
for each violation.48
7.3.6 Oregon
7.3.6.1 Willamette Valley - Agricultural Burns. The
Oregon Department of Agriculture (ODA) manages agricultural
open field burning. As provided in the law, direct
observation by inspectors, permit agents, and others provide
information of possible rules infractions. When an observed
violation occurs, field inspectors have authority to issue a
7-12 September 1992
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notice of investigation to the grower identifying the
possible rule(s) infractibn(s). This notice informs the
responsible party that further investigation will be
conducted. The DEQ.staff evaluate the factors involved in
the case and the director of the DEQ has the authority to
assess civil penalties according to the following schedule:
at least $20 but not more than $40 for each acre
illegally burned; or
not less than $500 nor more than $10,000 upon any
person who: (1) causes or allows open field burning
on unregistered acreage, and (2) causes or allows
open field burning without a valid permit;
not less than $300 nor more than $10,000 for failure
to extinguish a field when -prohibition conditions
are imposed or when instructed to do so by an agent
or employee of the smoke management program;
not less than $200 nor more than $10,000 for: (1)
burning under an approved alternative method
contrary to the rules or restrictions imposed by the
department, and (2) failure to monitor the field
burning radio network;
not less than $50 nor more than $10,000 for other
violations of the rules; and
the civil penalty for violation of the restrictions
on open burning and replanting of a cereal crop is
set at $25 for each acre planted contrary to the
restrictions.49
In lieu of any per-acre civil penalty, the director of
the DEQ may assess a specific civil penalty for any open
field burning violation by "service, or a written notice, of
assessment of civil penalty upon the respondent."50
During the 1990 burn season, DEQ issued 39 Notices of
Noncompliance (NON's) resulting in 11 civil penalty
referrals. In comparison, 28 NON's were issued in 1989,
with 16 referred for civil penalties. The increase was
attributed to a separation of field burning questions
(transferred to ODA) from enforcement, which remained with
DEQ. This separation of duties was indicated as allowing a
greater focus on enforcement activities. In addition, new
7-13 September 1992
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enforcement policies and procedures were adopted by EQC.
The new rules require NON's to be issued for every
documented violation, while previous policy allowed some
discretion for resolving noncompliance informally."
The majority of NON's in 1990 were issued for
unauthorized burning (10), unauthorized open field burning
(7), and improper propane flaming (6). Other serious
infractions included burning within the safety buffer zone,
late burning, and burning without adequate firefighting
equipment on site. Five informal warnings were also issued
for improper registration (i.e., registering multiple fields
as one field) .S2
X"-
7.3.6.2 Forestry Burns. All forest land prescribed
burning is to be conducted in accordance with daily smoke
management instructions. On private lands, violation of the
smoke management program directive or the daily instructions
(including updated instructions issued by the State
Forester) are subject to enforcement action by the State
Forester. Violations will be cited for burning without a
permit and burning not in compliance with the smoke
management program and directive.53
On Federal lands, violations of the smoke management
program directive or the daily instructions issued by the
State Forester are subject to State and Federal enforcement
actions under section 118 of the Clean Air Act as amended in
1977. Section 118 states that "Each agency of the Federal
Government engaged in any activity resulting in the
discharge of air pollutants must comply with all Federal,
State, interstate, and local requirements respecting the
control and abatement of air pollution in the same manner,
and to the same extent as any nongovernment entity."54
The State Forester maintains a staff of six smoke
management personnel in the State capital and a field force
of 65 foresters throughout western and central Oregon who .
participate in the smoke management program to accomplish
7-14 September 1992
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the inspection, enforcement, monitoring, and reporting tasks
of the program. In addition, the U.S. Forest Service and
the Bureau of Land Management maintain field forces of
approximately 80 supervisory personnel and professional
foresters trained in the techniques of prescribed burning
and the elements of the smoke management program. For
purposes of the law, these delegates are termed "field
administrators. "SB
It is the responsibility of private landowners under
Oregon forest laws to conduct forest prescribed burning
according to directions from these above-mentioned field
administrators and to conduct mop-up of prescribed burns
necessary to maintain air quality and visibility in
designated areas and areas sensitive to smoke.56
Oregon forestry burning rules state that if the fire
fighting apparatus or personnel, either or both, of a
district are required to respond and be used actively or on
a stand-by basis in connection with the extinguishment or
control of a fire that has been started or allowed to spread
in willful violation of ORS 478.960 (the general open
burning rules), the person responsible therefore shall be
liable to the district furnishing such apparatus or
personnel, or both, for the actual costs incurred by the
district in controlling, extinguishing, or patrolling the
fire. If the district prevails in the courts, there shall
be taxed and allowed to the district, at trial and on
appeal, a reasonable amount to be fixed by the court as
attorney fees for the prosecution of the action.57
The law also provides for the introduction of evidence
to be brought by the State dealing specifically with the
above violations, these being: (1) an itemized statement of
the actual costs incurred by the district, certified under
oath by the treasurer of the district, shall be accepted as
prima facie evidence of such costs in the action authorized
by this section; and (2) if burning results in the escape of
fire and injury or damage to the property of another, such
7-15 September 1992
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escape and damage or injury constitutes prima facie evidence
that the burning was not safe.58
7.3.7 South Carolina
The South Carolina Forestry Commission is responsible
for administering the smoke management guidelines. In doing
so, it consults and coordinates activities with the NWS and
the South Carolina Department of Health and Environmental
Control (DHEC)59, which has responsibility for air quality
regulatory violations.60 The Forestry Commission is also
responsible for the enforcement of the State's burning
notification law.61
The penalties for violations of the regulations come in
the form of administrative notices. The law provides that
this written report or warning to a person of a violation at
one site shall be considered adequate notice of the
regulation, and that subsequent observed violations at the
same or different sites will result in appropriate legal
action. Further, the authority to conduct open burning
under the regulation does not exempt or excuse the person
responsible for the burning from the consequences of, or the
damages or injuries resulting from the burning, and does not
exempt or excuse anyone from complying with other applicable
laws and with ordinances, regulations, and orders of
governmental entities having jurisdiction, even though the
burning is otherwise conducted in compliance with the
regulation.62
7.3.8 Virginia
Open burning, including forest management and
agricultural practices, is permitted under Emission
Standards for Open Burning (Rule 4-40), §§120-04-4001
through 120-04-4005. Penalties associated with open burning
are covered in the Fire Laws of Virginia. Any person
violating any provision of the forest fire law is guilty of
a class 3 misdemeanor for each separate offense. If a
7-16 September 1992
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forest fire originates as a result of any violation by any
person of a provision of this section, such person is liable
to the Commonwealth for the full amount of all expenses
incurred by the Commonwealth in suppressing the fire, in
addition to the misdemeanor penalty.63
There are additional laws dealing with intentional and
carelessly set fires. A violation of the rule for
intentionally set fires is a class 1 misdemeanor plus
liability for suppression of the fire if a person
intentionally sets fire to brush, woods, etc., and if he
intentionally allows the fire to escape to lands of another
whereby the adjoining property is damaged or jeopardized.64
Violation of the rule for carelessly set fires is a class 4
misdemeanor and the violator shall incur the liability for
costs of suppressing the fire if the person carelessly or
intentionally sets fire whereby the property of another is
jeopardized or damaged.65 Additionally, it is a class 3
misdemeanor if a person burns during a time of serious fire
hazard.66
Punishment for convictions of the above mentioned
misdemeanors is as follows:
class 1 misdemeanors, confinement in jail for not
more than 12 months and a fine of not more than
$1,000, either or both;
class 2 misdemeanors, confinement in jail for not
more than 6 months and a fine of not more than $500,
either or both;
, - class 3 misdemeanors, a fine of not more than $500;
and
class 4 misdemeanors, a fine of not more than
$100.67
7.3.9 Washington
Burn permits are required for a number of types of
prescribed burns in Washington. The Department of Natural
Resources (DNR) requires these burning permits to comply
with air quality standards established by the Department of
7-17 September 1992
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Ecology. The DNR also establishes smoke dispersal
objectives designed to minimize air pollution from smoke
from such burning and the procedures necessary to meet those
objectives.68
Outdoor fire permits issued by the Northwest Air
Pollution Authority (NWAPA) state that "any person who
violates any provisions of this permit is in violation of
NWAPA regulation - Section 501, subject to penalties of up
to $1000 and such other penalties as set forth in the NWAPA
regulations. "69
7.4 COMPLAINTS
Smoke from prescribed fires can generate large volumes
of public complaints, which occur most frequently during
smoke intrusions into populated areas. In Oregon, the
Department of Environmental Quality receives complaints for
all sources of smoke, such as slash burning, propane
flaming, forest fires, and general agricultural/industrial
burning. Whenever possible, efforts are made to distinguish
between sources. In 1990, a total of 2,959 citizen
complaints attributable to all sources were received.70 In
some air quality management districts in California,
complaints about prescribed burning have reached several
hundred.71
On the other hand, some States receive no complaints
concerning prescribed burning. For example, neither Utah
nor Wyoming have received complaints attributable to
prescribed burning.72 In Wyoming, the lack of complaints is
believed to be attributable to the acceptance of the
practice in the areas where it occurs, the fact that many
people in those areas conduct burns themselves, and the lack
of smoke intrusions from prescribed burns into urban areas
(there are few urban areas located in or near areas where
prescribed burning occurs).73
In addition to trying to reduce emissions from
prescribed burning, many of the smoke management programs
7-18 September 199-2
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have been aimed at reducing the number of smoke intrusions
into populated areas. To the extent that this is
successful, the number of complaints typically decrease. In
Washington, for example, in 1985 an effort was initiated to
reduce emissions from prescribed burning by 35 percent. In
1988, only 2 smoke intrusions were recorded and complaints
are steadily decreasing.74
The number of complaints received will not always be
indicative of how well a smoke management program is
working. One or two "bad" burns can generate a large
percentage of the total complaints in a year. Also, some
years have simply better dispersion capabilities (number of
days and "high" quality dispersion ..characteristics) that
allow burning to occur with minimum public impact.
Complaints can serve useful purposes, although relying
on them to gauge smoke accumulations is generally a poor
practice for monitoring smoke during prescribed burns. If
properly handled, complaints can identify ways to improve
the smoke management program. For example, in Montana,
follow-up on 12 complaints received during 1990 indicated
the possible need to start the Monitoring Unit earlier in
the fall and to improve communications to ensure all burns
are reviewed by the Monitoring Unit before ignition. Also,
the complaints highlighted the need for the burning crews in
the' field to use their best judgement regarding air quality
conditions and wind direction in determining if the fire
should be ignited.75
In general, all States have some procedure for handling
complaints. For example, in Montana, the Air Quality Bureau
(AQB) receives the complaints concerning prescribed burning.
When a complaint is received, the AQB obtains as much
information as possible from the complainant concerning the
location and suspected source of the burning. In response
to the complaint, the suspected organization or source is
contacted, when possible, for their response. A copy of
each complaint specifically mentioning MSAG members are
7-19 September 1992
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faxed to the Monitoring Unit of the MSAG to help with the
timeliness of the complaint reporting to the Unit.76
Many States, even those with good smoke management
programs, may benefit from reviewing their procedures for
handling complaints. For example, a 1990 report on
prescribed burning in Oregon states that "(a) more effective
centralized coordination effort needs to be established to
respond to complaints and inquiries about pollution
problems."77
Finally, in Montana's experience, most complaints often
included questions as to how open burning is controlled. In
response, the smoke management program was explained. The
complainants were also interested in being involved with
establishing further controls of burning agricultural and
slash burning.78
7.5 EFFECTIVE IMPLEMENTATION STRATEGY
7.5.1 Monitoring
The existing PM-10 monitoring network should be
evaluated for its ability to provide information on burning
conducted in and near the nonattainment area. The State
should supplement (as necessary and appropriate) their
routine PM-10 monitoring network by both routine and special
monitoring, e.g.:
a. adding additional PM-10 monitors;
b. using visual surveillance (e.g., aerial, ground)
to track smoke plumes;
c. using chemical canisters and appropriate analy-
tical techniques for their PM-10 monitors to allow
identification of dust PM-10 from smoke PM-10; and
d. installing integrating nephelometers.
The State should implement daily PM-10 monitoring
during burn days (at minimum) at locations identified by
modeling as likely maximum concentration locations.
The readings obtained by the routine and special
monitoring should be used to assess the smoke dispersion
7-20 September 1992
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evaluation methods and to identify whether burns are to be
allowed to continue. The State should use real-time air
quality monitoring of PM-10 levels to determine whether
burning needs to be stopped. For example, if PM-10 readings
above the modeled concentration' are observed, then a
decision on whether to discontinue burning should be made.
The State should implement an aggressive program to
visually assess the effectiveness of the smoke management
program. This includes, but is not limited to, determining
whether burns are to continue. Visual assessment should be
done by aerial surveillance using trained smoke observers
and ground monitors who are trained smoke observers.
Continuous aerial and ground surveillance may be necessary.
States should identify days of particular concern (e.g.,
releases are near capacity) and conduct continuous
surveillance on such days at a minimum.
Regardless of whether a "stop burning" order has been
given, burners are expected to curtail burning if, in their
opinion, they are not getting adequate smoke dispersion or
if local weather factors are such that smoke problems would
result. If more favorable local weather conditions exist, a
burner may call the local burn authority for an exception to
the "stop burning" order or to any other restriction that
may have been issued.
7.5.2 Enforcement Program
The State should implement an enforcement program that
includes, but is not limited to, spot audits for violations
of any aspect of the smoke management program, a system of
warnings and fines, and an appeals process.
The enforcement program should provide for and levy
fines against burners who violate any of the smoke
management programs mandatory requirements, including the
willful and deliberate submission of false information in
the burn request or emission inventory data reports. In
addition, the State should implement a system of fines for
7-21 September 1992
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any violation of the conditions under which a burn is
authorized to take place. Other instances for which fines
could be levied include:
burning without having submitted a burn request;
<*>
burning without verifiable authorization;
burning at unauthorized times; and
burning after a "stop burning" order was given.
The level at which fines are set should be determined
on a State-by-State basis.
7.5.3 Complaints
The State should implement a process for receiving,
processing, and following up on public complaints. This
process should include a readily available 800 number (e.g.,
listed in the local telephone book) for receiving complaints
concerning smoke from prescribed burning. The use of this
"hot line" should be explained in the public education and
awareness program.
The State should develop a standardized form for
recording complaints. The State should identify the type of
information needed when filing-a complaint (e.g., the date
of the complaint, the nature of the complaint, the time of
complaint received, the location of the prescribed fire in
question, and, if known, the person(s) conducting the
subject burn). It is recommended that the name and address
or telephone number of the person calling in the complaint
be obtained if the caller wishes to learn of how the
complaint was resolved.
The State should develop a procedure for the
disposition of each complaint. Complaints received during
no burn days should be followed up immediately.
All complaints should be summarized in an annual
report. Actions that the State has or will take to minimize
the causes that have given rise to the complaints should
also be identified in the annual report.
7-22 September 1992
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7.6 REFERENCES
1- Smoke Management Guide. Produced by: Prescribed Fire
and Fire Effects Working Team. February 1985. p. 20.
2. Reference 1,-p. 20.
3. Personal communication. Bill Leenhouts, U.S. Fish and
Wildlife Service, Boise, ID, to Ken Meardon, Pacific
Environmental Services, Inc., Durham, NC. June 6,
1991.
4. Reference 1, p. 20.
5. Reference 1, p. 20.
6. Reference 1, pp. 19, 20.
7. Reference 1, p. 20.
8. Reference 1, p. 20.
9. Reference 1, p. 20-
10. Reference 1, p. 20.
11. Peter Lahm. Smoke Management Practices Report.
Arizona Smoke Management Plan. Prepared for: Arizona
Department of Environmental Quality. 1990. pp. 26, 27.
12. Peter Lahm. Smoke Management Practices Report. Smoke
Management Programs Within The United States. Prepared
for: Arizona Department of Environmental Quality,
1990. pp. 33, 45.
13. Personal communication. Charles Tandy, U.S. Bureau of
Indian Affairs, to Ken Meardon, Pacific Environmental
Service, Inc. June 17, 1991.
14. .Colorado Smoke Management Memorandum of Understanding.
Colorado Smoke Management Plan. p. 7.
15. Reference 14, p. 7.
16. Reference 14, p. 6.
17. Reference 14, p. 6.
18. Reference 14, pp. 6, 7.
19 State of Montana Cooperative Smoke Management Plan.
(Revised: January 1988) p. 14.
20. Reference 12, p. 32.
7-23 September 1992
-------
21. Reference 19, p. 6.
22. Reference 12, p. 32.
23. Personal communication. David Jarman, North Carolina
Division of Forest Resources, and Ken Meardon, Pacific
Environmental Service, Inc.
24. Reference 12, p. 17.
25. Oregon Department of Agriculture. 1990 Annual Field
Burning Report, pp. 3 through 7.
26. Reference 25, p. 6.
27. Reference 25, p. 6.
28. Oregon Department of Agriculture. Field Burning Permit
Agentf.s Manual. Prepared forr Willamette Valley Fire
District Permit Agents. May 1990. p. 26.
29. Reference 25, p. 6.
30. Operational Guidance for the Oregon Smoke Management
Program. Directive 1-4-1-601. 12/86. p. 6.
31. Reference 30, p. 6.
32. Oregon Department of Forestry. A Report on Prescribed
Burning in Oregonr 1990. p. 38.
33. Reference 32, p. 38.
34. Reference 32, pp. 38, 39.
35. Reference 32, p. 39.
36. Reference 1, p. 4.
37. Arizona Air Pollution Control Laws, Arizona Revised
Statutes, Title 49 - The Environment; Chapter 3 - Air
Quality. §49-502.
38. Reference 37, §49-503.
39. Arizona Department of Environmental Quality, Office of
Air Quality. Open Burning Guidelines for Air Pollution
Control. p. 9.
40. California Air Pollution Control Regulations.
Subchapter 2. Agricultural "Burning Guidelines.
Article 2. Implementation Plan, 80140(d).
7-24 September 1992
-------
41. California Air Resources Board, Compliance Division.
Agricultural Burning Self-Instruction Handbook. 1990.
p. 13..-...-.
42. Northern Sierra Air Quality Management District.
Regulation III, Open Burning. Rule 301 Compliance.
43. Reference 14, p. 9.
44. Reference 14, p. 9.
45. Florida Administrative Code, Chapter 51-2. 51-2.06,
Agricultural and silvicultural fires.
46. Florida Statute 590.12.
47. Florida Statutes 590.12 and 775.082.
48. Georgia Environmental Protection Division. Burning
Restrictions (for Counties exceeding 65,000
Population).
49. Reference 28, pp. 26, 27.
50. Rules for Open Field Burning (Willamette Valley).
5/89. Civil Penalties 340-26-025(2).
51. Reference 25, p. 19.
52. Reference 25, p. 19.
53. Reference 30, p. 5.
54. Reference 30, p. 5.
55. Reference 32, p. 15.
56. Reference 32, p. 15.
57. Oregon Revised Statutes, Rule 478.965.
58. Reference 57, Rule 478.960.
59. State of South Carolina. Smoke Management Guidelines
for Vegetative Debris Burning Operations, p. 2.
60. Reference 12, p. 18.
61. Memorandum of Understanding between the South Carolina
Department of Health and Environmental Control Bureau
of Air Quality and the South Carolina Forestry
Commission.
7-25 September 1992
-------
62. South Carolina Department of Health and Environmental
Control. Air Pollution Control Regulations.
Regulation No. 2.2 Prohibition of Open Burning.
63. Forest Fire Law of Virginia. Section 10.1-1142.
Regulating the burning of woods, brush, etc.;
penalties. §10.1-1142(D).
64. Reference 63, §18.2-87.
65. Reference 63, §18.2-88.
66. Reference 63, §10.1-1158.
67. Reference 63, §18.2-11.
68. Bert L. Cole. Air Quality - Prescribed Burning Smoke
Management Program. Part I. Coordination and
Operation. June 1975 (revised-), p. 1.
69. Northwest Air Pollution Authority. Outdoor Fire Permit
Form. Revised 12/84.
70. Reference 25, p. 17.
71. Reference 12, p. 37.
72. Reference 12, p. 33. 34.
73. Personal communication. Wyoming Department of
Environmental Quality, and Ken Meardon, Pacific
Environmental Service, Inc. July 26, 1991.
74. Reference 12, pp. 44, 45.
75. Montana State Airshed Group. Annual Report, Fall
Season 1990. January 1991. pp. 24, 25.
76. Reference 75, p. 26.
77. Reference 32, p. 40.
78. Reference 75, p. 26.
7-26 September 1992
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8.0 EMISSION INVENTORY SYSTEMS
8.1 INTRODUCTION
Emission inventory systems are used by State and local
agencies for quantifying emissions within their
jurisdictions and tracking emission reduction efforts.
Depending on the purposes of the system, the information
included and the methods used to obtain the information will
vary. For example, a system designed to simply report
quantity of emissions will require less input data than, a
system designed to also track emission reduction efforts.
In this chapter, the basic components of an emission
inventory system are discussed based on a nationally
applicable inventory approach developed by the USDA Forest
Service.1 Following this discussion are brief descriptions
of the Oregon and Colorado emission inventory systems. The
Oregon system has been described as incorporating the most
precise options for inventorying emissions.2 Washington
uses a system similar to Oregon's. Colorado recently imple-
mented their emission inventory system using the USDA Forest
Service national emission inventory system as its base.3
The chapter concludes with a discussion of an effective
implementation strategy for the emission inventory systems
element available for the development of area-specific BACM
smoke management programs.
8.2 EMISSION INVENTORY APPROACH
A consistent, nationally applicable approach to
inventory PM-10 emissions from prescribed fires has been
developed by the USDA Forest Service Pacific Northwest
Research Station. This approach is described below and
forms the basis for determining the level of emission
8-1 September 1992
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inventory systems consistent with a BACM smoke management
program. The discussion on this approach is drawn from
Peterson and Sandberg, 1988.4
The basic approach is designed around determining the
tons of fuel burned (known as an "activity level") and
multiplying the activity level by an emission factor. This
is done for each burn and the results summed to obtain
estimates of PM-10 emissions from prescribed burning.
8.2.1 Activity Level
In the past, attempts to estimate emissions from
prescribed burning have focused on using acres burned as the
activity level to which an emission, factor was then applied.
Acres burned provided an acceptable activity level when
emission reduction level techniques that affected emission
generation were not being used. However, many emission
reduction techniques are now being used that affect the
amount of emissions emitted per acre burned. Therefore, an
alternative activity level is needed to account for the
effect of these emission reduction techniques.5
Such an activity level is tons of fuel burned. The
tons of fuel burned are calculated from three components:
area burned (-acres), pre-burn fuel loading (tons per acre),
and fuel consumption (percent).6 The following paragraphs
discuss each component and methods for determining each
component. These discussions are then followed by the
presentation of the Activity Level Component Accuracy-
Matrix, which was developed by the U.S. Forest Service,
Pacific Northwest Research Station. The Activity Level
Component Accuracy Matrix shows the relationship between the
methods used to. determine the three components and the
overall accuracy of the resulting estimate of tons of fuel
burned.
8-2 September 1992
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8.2.1.1 Area Burned.7 Area burned refers to the area
from which the fuels being burned are obtained. This
component is usually expressed in terms of acres.
There are two basic sources of information for
obtaining estimates of the area burned. One is to obtain
estimates from an expert who can generally estimate how many
acres are burned by prescribed fire in the State. Such
experts may be found in the State forestry or agricultural
departments, the U.S. Forest Service, growers associations,
Bureau of Land Management, BIA, and the U.S. Fish and
Wildlife Service, who burn in the State. The level of
information available from experts can vary significantly,
depending on records that are kept.,.
The second source for obtaining information on the
number of acres burned is through various burn reports
submitted by the burners. Burn reports may be in the form
of permit applications, burn permits, or smoke management
reports. In using this source of information, it is
important to determine whether the reported acres burned are
planned burns or actual burns. If planned burns, then the
estimate of acres burned could be overestimated as not all
planned burns are actually conducted to their fullest extent
(i.e., less acreage may be burned than originally planned).
One item to note regarding this component is that the
level of accuracy of the emission inventory system will
depend, in part, on the ability to disaggregate information
on acres burned according to a number of factors that affect
emissions. For example, the accuracy of the emission
inventory system can be improved if the acres burned can be
disaggregated according to fuel type (e.g., sagebrush vs.
pine). Another item would be the number of days since the
last rain. This item affects the amount of fuel consumed.
8-2.1.2 Fuel Loading.a Fuel loading is the amount of
fuel present, typically expressed as the weight of fuel per
unit area (e.g., tons per acre). The fuel loading may refer
8-3 September 1992
-------
to available fuel or total combustible fuel and is usually
reported on a dry weight basis. (Available fuel is that
portion of total combustible material that will be consumed
under given conditions during a burn.)* There are a number
of methods that can be used to estimate fuel loading.
Listed in ascending order of accuracy and cost, they are:
- Guess. In the absence of any other method, one
can always guess at the fuel loading.
- Fuel Model. Fuel models are sets of parameters
that describe a fuel-bed based on a qualitative
description of the fuel type.
- General Estimate. A general estimate is based on
repeated measurements within a population of fuel
beds. Using a general estimate requires the acres
be apportioned into general fuel types by expert
estimate.
- Statistical Profile. These differ from general
estimate by a statistical design ensuring that the
population sampled is the same as represented by
the area burned.
- Site-specific Inventory. This method relies on
measuring the fuel loading at the specific site to
be burned.
Site-specific inventories are the most accurate
estimate of fuel loading, but also require the most effort.
Two basic methods for obtaining site-specific inventories of
fuel loading are the planar intersect method and the photo-
series method. The planar intersect method involves
counting downed woody pieces that intersect vertical
sampling planes and measuring the diameters of pieces larger
than 3 inches in diameter. The piece counts and diameters
then permit calculation of tons per acre. For average
amounts of downed debris, about 5 to 6 minutes per sample
point are required for the measurements. More time is
usually spent traveling and locating sample points than in
making the measurements. The planar intersect method is
"nondestructive and avoids the time-consuming, costly, and
often impractical task of collecting and weighing large
quantities of forest debris."10
8-4 September 1992
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The photo series method relies on a series of stereo
photographs that display a range of residue loadings for
various types of forests and land activities (e.g.,
clearcutting). Each photo is accompanied by information on
measured forest residue. The photo series method requires
the user to "make a visual inventory of downed residue by
viewing the field of observable fuel and comparing it with
the photos as follows:
1. Observe each characteristic for a specific size
class of residue on the ground (for example, 3.1-
to 9-inch loading).
2. Select a photo or photos that nearly match or
bracket the observed characteristics.
X"
3. Obtain the quantitative value for the
characteristic being estimated from the data sheet
accompanying the selected photo (or interpolate a
value between the photos)."
The above steps are repeated for each fuel size class or
fuel characteristic needed.13-
Of the three methods, the linear intersect is the most
accurate, time-consuming, and costly. The planar intersect
is quicker and less costly than the linear intersect, but is
somewhat less accurate. The photo series method allows
faster, easier, and less expensive quantification than the
two intersect methods, but with less accuracy.
Although these methods vary in their accuracy, they
still allow the most accurate tracking of emission
reduction. If used, no additional information is needed
about the area burned.
Statistical profiles have been compiled and published
for a few fuel types (e.g., Pacific Coast logging slash by
owner, clear cuts west of the Cascades on national forest
lands). Their use requires some site-specific
characteristics (e.g., species/fuel type, yarding method,
age of stand at harvest, location, owner) to be reported by
the burners that will enable site-specific assignment of the
appropriate profile. This method also requires an awareness
8-5 September- 1992
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of changes in management practices indicating a significant
change in fuel loading and requiring the profile to be
updated. This method is a good estimate of actual fuel
loading and allows some degree of tracking of efforts to
reduce emissions from prescribed burning.
General estimates can be obtained from local foresters
or from general research publications. These methods may
contain some inaccuracies if the population sampled to
determine the fuel loadings are not the same as the area
being burned. Also, changes in management practices can
cause changes in fuel loadings, making these estimates
obsolete. Although experienced foresters can usually
estimate fuel loadings fairly accurately if a fuel type is
known, "this subjective sort of estimate may be prone to
bias if the forester has a professional motivation to reduce
fuel loading. If so, there could be a tendency to
underestimate this factor.""
Because they were designed to quantify fuels affecting
fire behavior rather than fuels affecting loading and
emission production, fuel models do not necessarily estimate
actual loadings accurately. For example, fuel models do not
estimate loadings for fuels larger than 3 inches in diameter
or decayed organic matter on the forest floor. These two
fuel elements can contribute the majority of emissions
produced from prescribed fires in some parts of the country.
When there is no specific information known about the
acres burned to assist in assigning a fuel loading, the only
option available is to guess. This obviously is likely to
be the least accurate of all the methods for estimating fuel
loadings. If a guess is used, it is hopeful that it is at
least based on some sort of inference where there is some
knowledge.
8.2.1.3 Fuel Consumption." Fuel consumption is the
measure of the percent of total available fuel that is
actually consumed by the prescribed fire. It is both
8-6 September 1992
-------
difficult to predict and measure. Factors that affect fuel
consumption include, but are not limited to, fuel-bed
components, moisture content of the various fuel-bed
components, and the weather at the time of the prescribed
burn.
As for fuel-bed loading, there are several methods
available for estimating fuel consumption. Listed in
ascending order of accuracy and cost, they are:
- Guess. As for fuel loadings, in the absence of
any other method, one can always guess at the fuel
consumption.
- Expert Estimate. Fuel consumption estimates can
usually be obtained from experienced burners for
typical conditions. Using an expert estimate
requires the acres burned to be apportioned into
general fuel types by expert estimate.
- General Published Observations. For a few regions
and fuel types, general observations as to typical
fuel consumption have been published. As for the
expert estimate method, using general published
observations requires the acres burned to be
apportioned into general fuel types.
- General Predictive Algorithms. These algorithms
enable consideration of some factors that affect
fuel consumption on a temporal basis. Thus, these
algorithms require some site-specific character-
istics (e.g., fuel moisture content) to be
reported or scientifically predicted.
- Specific Predictive Algorithms. These algorithms
require site-specific information about many
parameters, including fuel loading.
Site-Specific Measurement. The most accurate
method is to measure actual fuel consumption at
the site.
Site-specific measurements are the most accurate method
to quantify fuel consumption. The planar intersect method
is used to obtain fuel consumption by establishing points
and measuring fuel loadings at those points both pre-burn
and post-burn." The use of the linear intersect method to
obtain these measurements makes this fuel consumption method
exceptionally labor-intensive. Therefore, it is very
8-7 September 1992
-------
unlikely that anyone other than researchers would be
motivated to use this method. If this method is used, no
additional consumption information is needed.
Specific predictive algorithms predict fuel consumption
very accurately. They are an excellent estimate of actual
fuel consumption and allow emission reduction efforts to be
apportioned to specific practices. Unfortunately, these
algorithms are currently available for only a few fuel
types.
General predictive algorithms provide an accurate
estimate of fuel consumption and allow some degree of
tracking of efforts to reduce emissions. The algorithms are
available for prescribed burning in. only a few regions in
the country.
General published observations are available for a few
regions and fuel types. These observations may contain bias
if consumption is being managed.
As for fuel loadings, expert estimates of fuel
consumption may be biased (underestimated) if the forester fflB
has a professional motivation to reduce fuel consumption on
prescribed burns.
Also, as for fuel loadings, the only option available
in the absence of site-specific information on the area
burned is to guess. This is likely to result in the least
accurate estimate of fuel consumption.
8.2.1.4 Activity Level Matrix." In general, the
level of accuracy of the emission inventory is determined by
the methods used to estimate each of the three basic
components discussed above. To evaluate the accuracy level
of an emission inventory system, a matrix, called the
Activity Level Component Accuracy Matrix, was developed.
The matrix (see Figure 8-1) shows the relationship between
the methods to estimate acres burned (shown along the
x-axis), fuel consumption methods (the y-axis), and fuel
loading methods' [the z(diagonal)-axis].
8-8 September 1992
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FUEL
CONSUMPTION
(y-axis)
Measure
Consumption
Specific
Predictive
Algorithm
General
Predictive
Algorithm
General
Published
Observations
Expert
Estimate
Guess
FUEL
LOADING
(z-axis)
Guess
Fuel
Model
General
Estimate
Statistical
Profile
X*
Site-specific
Estimate
Not
Needed
No Expert Estimate of Percent Site Specific Characteristics for Estimating
Information of Area by Fuel Type Loadings, Consumption, and Emission
Factors as Necessary
AREA BURNED
(x-axis)
Figure 8-1. Activity Level Component Accuracy Matrix
FUEL
CONSUMPTION
(y-axis)
Measure
Consumption
Specific
Predictive
Algorithm
General
Predictive
Algorithm
General
Published
Observations
Expert
Estimate
Guess
FUEL
LOADING
(z-axis)
1
1
Guess
Fuel
Model
"
General
Estimate
Statistical
Profile *
^
Site-specific .
Estimate
s
Not
Needed
t
-
No Expert Estimate of Percent Site Specific Characteristics for Estimating
Information of Area by Fuel Type Loadings, Consumption, and Emission
Factors as Necessary
AREA BURNED
(x-axis)
Figure 8-2. Component Matrix Example
September 1992
8-9
-------
As seen in Figure 8-1, the matrix contains two sets of
double lines. These double lines divide the matrix into mjm
three general areas. Each area represents a different level
of overall emission inventory accuracy. The area in the
bottom left-hand corner of the matrix represents the least
accurate emission inventory system. The area between the
two sets of double lines represents a more accurate emission
inventory system. Finally, the area above and to the right
of the area bounded by the two sets of double lines
represents an even more accurate emission inventory system.
Crossing a set of double lines represents a change in the
level of accuracy. For example, crossing from above to
below a set of double lines indicates a loss of potential
accuracy. To illustrate, an emission inventory system
suffers a loss in potential accuracy by using "general .
predictive algorithms" rather than "general published
observations" for measuring fuel consumption (a double line
having been crossed going down towards the x-axis).
The Activity Level Component Accuracy Matrix allows one
to assess the relative accuracy of existing emission
inventories and to create emission inventories of varying
accuracy. For example, to assess the level of accuracy of
an existing emission inventory system, the matrix is used as
follows:
1. First, identify the method used to estimate acres
burned and locate this method on the x-axis. If
more than one column applies, select the column
farthest to the right (i.e., until either a
double-line is encountered or the end of matrix is
reached, whichever occurs first). For example,
assume acres burned have been estimated from burn
reports with site-specific information. This
would put you in the three boxes to the right
along the x-axis above the heading "Site Specific
Characteristics for Estimating Loadings,
Consumption, and Emission Factors as Necessary"
(see Figure 8-2). Then, move to the column
farthest to the right, which, in this case, is the
last column in the matrix.
2. Next, travel vertically in the selected column
until the fuel loading methods diagonal (z-axis)
8-10 September 1992
-------
is intersected. Is the method you come to
available to you to use? If so, use that method
to estimate fuel loading. If that method is not
available to you to use, travel down the diagonal
(i.e., towards the x-axis, y-axis intersect) until
you reach the first fuel loading method that is
available to you. Assume in the example that the
first fuel loading method available to you is
"statistical profile" (see Figure 8-2). We would
move along the z-axis until we reach the box
containing "statistical profile."
3. Once the fuel loading method available has been
identified in the matrix, travel horizontally in
that row to the y-axis, which lists the fuel
consumption methods. The method you come to, is
it available? (In our example, we come to
"general predictive algorithm.") If so, use it.
If the method you come to^ is not available to you
to use, travel down the y-axis until you come to
the first fuel consumption method that is
available to you. In the example, assume the
available fuel consumption method is "general
published observations."
Increasing the overall accuracy of an emission'
inventory system involves more than just selecting a more
accurate method for one of the components. Some increases
in the accuracy of a component may not increase the overall
accuracy of the emission inventory system unless one or both
of the other components are estimated using more accurate
methods. In other instances, it may not be possible to
increase the accuracy of one component without a
corresponding increase in the accuracy of another component.
Finally, several items in the matrix should be noted.
When fuel loading is estimated using the site-specific
method, no other loading information is needed site-
specifically, but site-specific fuel consumption and
emission factor information are still needed. When fuel
consumption is measured, no other loading or consumption
information is needed, only site-specific emission
information is needed.
8-11 September 1992
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8.2.2 Emission Factors
The most readily available source of emission factors
is provided in the U.S. Environmental Protection Agency's
publication Compilation of Air Pollutant Emission Factors,
AP-42f Fourth Edition (AP-42), September 1985, including
Supplements A, B, and C. This document contains emission
factors for open (agricultural) burning (Section 2.4 in the
AP-42) and for wildfires and prescribed burning (Section
11.1 of the AP-42).
The quality of the emission factors in the AP-42 is
highly variable and should be used with as much
understanding as possible to avoid misuse or to at least
understand the uncertainties associated with their use.
Some of the emission factors are currently being updated.
Current research on emission factors is being conducted out
of the USDA Forest Service Pacific Northwest Research
Station in Seattle, Washington, and the USDA Forest Service
Intermountain Station in Missoula, Montana.
8.3 STATE PROGRAMS
Emission inventory systems for prescribed burning in
States tend to be relatively new. The States of Oregon and
Washington have.highly developed emission inventory systems
for tracking slash burning emissions. The two systems are
nearly identical. Oregon's current system was started in
1985, with modifications made later. Washington's emission
inventory system was implemented after Oregon's.
Colorado has just recently developed and implemented an
emission inventory system. Colorado's system, although
built on the same basic components as the Oregon and
Washington systems, is much less rigorous.16 A general
outline of steps that can be taken in developing an emission
inventory system is presented in Table 8-1.
8.3.1 S'lash Burning Emission Inventory System
8-12 September 1992
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4
A-
A detailed emission inventory system, SMS_INFO, is
currently being used by the Oregon Department of Forestry to
inventory slash burning in western Oregon. As noted above,
a similar system is being used by the State of Washington.
The system was developed by the Fire and Air Resource
Management Project, Pacific Northwest Research Station.
SMS_INFO uses detailed information (over 30 data items) on
every burn.17 Figure 8-3 presents the forms (draft update)
needed to report the information used in Washington's
emission inventory system.18 The information is reported by
the burners. The system checks reported values and
calculates fuel consumption for every burn. This system
allows daily and annual tracking of. prescribed burning
emissions, identifies emission reduction efforts made by
specific fire users, and measures the success of emission
reduction efforts.19
The Oregon emission inventory system for slash burning
can be examined in terms of the Activity Level Component
Accuracy Matrix by looking at each of the three components.
*
The first component, acres burned, is reported for each
individual area; this may be considered a burner's report.20
A number of site-specific factors associated with each area
are reguested including predominant species (fuel type),
average duff level, fuel moisture (of 10-hour and 1,000-
hour fuels), days since rain, reason for burning, and
minimum harvested log diameter applied to green or noncull
material.21 These site-specific factors are important
inputs to determining fuel consumption and site-specific
emission factors. In terms of the matrix, one would be in
the column farthest to the right along the x-axis (see
Figure 8-4).
Fuel loading, the second component, is estimated
specifically for each site.22 The site-specific method is
shown as the second highest method along the diagonal axis.
Fuel consumption is calculated using specific
predictive algorithms developed for western Oregon fuel
8-13 September 1992
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TABLE 8-1
STEPS FOR DEVELOPING AN EMISSION INVENTORY SYSTEM"
Step Action
1 Develop a working group that includes representa-
tives of the individual agencies and private
organizations who use prescribed fire within the
State to develop the details of their smoke
management/emissions inventory system. All of the
future participants need to help customize the
details of the system based on their expert
knowledge of the goals, benefits, possible control
measures, and usage trends of prescribed fire in the
local area. National representatives should not be
solely relied on to provide ^this vital insight.
Persons with scientific knowledge of fuels, fire,
and atmospheric science should also be members of
the working group.
2 Describe general categories of prescribed fire use.
These categories can be defined based on National
Fire Danger Rating Fuel Models or Fire Behavior Fuel
Models, or they can be based on general categories
agreed upon by the State prescribed fire users. The
generalized fuel models are probably sufficient for
prescribed burning of natural fuel types, but it
would be best to define more specific categories for
activity fuels (debris resulting from forest or
rangeland management activities). The necessary
degree of disaggregation of types of burning is
determined by the need to accurately define unique
pre-burn fuel loadings, fuel consumption objectives,
and emission factors.
3 Determine typical pre-burn fuel loadings for each of
the categories defined in Step 2. This information
is potentially available from many sources including
scientific publications and expert knowledge.
Statistically-designed fuels inventories could also
be performed.
4 Define common fuel consumption objectives for the
fire use categories.. Local experts should be able
to provide this information. In some areas,
particularly where there is extensive use of
prescribed fire, scientific studies may have been
completed describing fuel consumption from
prescribed fire.
8-14 September 1992
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, TABLE 8-1
STEPS FOR DEVELOPING AN EMISSION INVENTORY SYSTEM
Concluded
Step _^ Action
5 Describe possible ways to manipulate the fuel
loading or fuel consumption on individual burned
areas (this defines potential control measures).
For example, changes in logged unit utilization
standards can cause changes in pre-burn fuel
loadings; changes in ignition techniques may cause
changes in fuel consumption; changes in fuel
moisture content may cause changes in fuel
consumption. Describe as many techniques to control
(reduce) fuel loading and fuel consumption as
possible. Make tracking of the use of these
techniques part of the emissions inventory system,
for example, require reporting of the ignition
technique used for each burn.
6 Develop an auditing procedure if emission reduction
incentives are built in that could lead to a
motivation for participants to overestimate progress
to receive preferred treatment. '
7 Assign emission factors to be used with the
prescribed burn categories. These are listed in an
AP-42 supplement. (See text for brief discussion
concerning the use of AP-42 emission factors.)
8 Develop a system for collecting, storing, and
processing the prescribed burning emissions
inventory data. This will be defined in part by the
temporal needs for the data. For example, some of
the information may be required prior to ignition
for smoke management permitting, but other types of
information may not be available until after the
burning is complete. The information that is not
available until after the burn is complete may need
to be known immediately, monthly, or only annually.
For PM-10 nonattainment areas, SIP emission
inventories must be provided to EPA (see U.S.
Environmental Protection Agency PM-10 Emission
Inventory Requirements, Draft Report, January 6,
1992).
* Reference 3, pp. 3, 4. For further information contact
Fire and Air Resource Management, U.S.D.A., 4043 Roosevelt
Way, N.E., Seattle, WA, 98105; telephone: (206)442-7815.
8-15 September 1992
-------
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types. These algorithms use specific characteristics of
each site.23 Figure 8-4 shows the location of this final
component.
Overall, this emission inventory system provides a good
estimate of actual emissions produced and allows tracking of
emission reduction efforts and assessment of impact from
individual burns. It is augmented by a quality control
audit that independently inventories fuel consumption on
about 1 percent of the fires permitted.24
8.3.2 Colorado Department of Health25
The Colorado Department of Health (DOH) recently
developed an emission inventory system for wildland fuels.
The Colorado DOH used the activity level component accuracy
matrix as the basis for their system.
In developing their system, the Colorado DOH selected
tons of fuel consumed as its activity level. Each Federal
and State land manager that conducts prescribed burning is
then required to submit information on acres burned (by fuel
type), fuel loading, and fuel consumption. The manner in
which these components are estimated (e.g., expert
judgement, fuel consumption model) is left to each agency's
discretion. Thus, the final emission estimates in the
inventory system will have considerable variability in
relative accuracy.
8.4 EFFECTIVE IMPLEMENTATION STRATEGY
States should develop and maintain an emissions
inventory for prescribed burning. Each State, therefore,
should also implement a procedure for collecting information
on burns after they have occurred.
States should base their emission inventory system on
estimates of tons of fuel consumed and the appropriate
emission factors. Using tons of fuel consumed is preferred
to acres burned as the activity level because it is a more
8-18 September 1992
-------
FUEL
CONSUMPTION
(y-axis)
FUEL
LOADING
(z-axis)
Measure
Consumption
Specific
Predictive
Algorithm
General
Predictive
Algorithm
General
Published
Observations
Expert
Estimate
Guess
-. *-
Guess
Fuel
Model
__
General
Estimate
Statistical
Profile
Site-specific
Estimate /
Not
Needed
/(
, ' 1
I
_J
No Expert Estimate of Percent
Information of Area by Fuel Type
Site Specific Characteristics for Estimating
Loadings, Consumption, and Emission
Factors as Necessary
AREA BURNED
(x-axis)
Figure 8-4. Activity Level Component Accuracy
Matrix for Prescribed Slash Burning in
Western Oregon
September 1992
8-19 /- ,
-------
accurate estimation of emissions produced and allows
tracking of emission reduction techniques.
The EPA's AP-42 is a ready source of emission factors
and should be used by States as the initial source. States
are encouraged to review the applicability of the AP-42
emission factors to the specific burns affecting their
nonattainment areas.
In determining tons of fuel consumed, States should use
the three basic components of: (1) acres burned, (2) fuel
loading, and (3) fuel consumption. Acres burned should be
determined on a post-burn basis to avoid likely
overestimation. Acres burned should be disaggregated by
fuel type and other factors that influence fuel consumption
and emission factors.
Fuel loadings should be determined through site-
specific estimates or statistical profiles. Less accurate
methods (e.g., general estimates, fuel models) are unlikely
to allow sufficient accuracy in the overall emission
inventory and therefore should be avoided.
Fuel consumption should be determined through specific
(preferable) or general predictive algorithms. Since it is
extremely time-consuming and costly, actual measurement of
consumption should be used as a last resort. If specific or
general predictive algorithms are unavailable, the State
should use the next best available option while pursuing
development of site-specific algorithms. Once developed,
these algorithms should be used.
The data to be collected for each of the three
components should be determined by the State air pollution
agency in conjunction with all affected parties. At
minimum, the following data should be collected on each
burn:
a. location;
b. date of burn;
c. purpose of burn;
8-20 September 1992
-------
d. actual acres burned;
e. actual pre-burn fuel loading; and
f. fuel consumed (often reported in percent)
Each State may decide whether to implement the emission
inventory system on a statewide basis or on a limited scale.
If on a limited scale, then all individual burns (except as
excluded under the source category de minimis level
exemption) that are in the nonattainment or in the "extended
area" that contribute PM-10 emissions to the nonattainment
area (as determined by modeling) should be included in the
emission inventory system. The emission inventory should
include an estimate of the collective emissions from all
v-
exempted burns.
Information for the emission inventory should be
provided by the burner. Pre-burn loading must be determined
prior to the burn. All other data should be collected by
the burner within 24 hours after each burn. The State may
specify the timeframe within which the burner has to submit
the data to the State.
Emission inventory information should be subject to
quality assurance audits to verify accuracy. These audits
should emphasize improving data accuracy and collection. A
State may use the audits to identify willful and deliberate
attempts to report false information as part of their
enforcement program.
8-21 September 1992
-------
-------
8.5 REFERENCES
1. Janice L. Peterson and David V. Sandberg. A National
PM10 Emissions Inventory Approach for Wildfires and
Prescribed Burning. Paper presented at APCA/EPA
International Specialty Conference, San Francisco, CA.
February 24-34, 1988. pp. 353 through 371.
2. David V. Sandberg. Emission Reduction for Prescribed
Forest Burning. In: Mathai, C.V.; Stonefield, David
H., eds. Transactions PM-10: Implementation of
Standards: An APCA/EPA International Specialty
Conference; February 22-25, 1988, San Francisco, pp.
628 through 645.
3. Personal communication. Janice Peterson, U.S. Forest
Service, Seattle, WA, to Ken Meardon, Pacific
Environmental Services, Inc., Durham, NC. March 6,
1991. 5 pp.
>*
4. Reference 1.
5. Reference 1, p. 354.
6. Reference 1, pp. 354, 355.
7. Reference 1, pp. 356, 357.
8. Reference 1, pp. 357, 358.
9. Smoke Management Guide. Produced by: Prescribed Fire
and Fire Effects Working Team. February 1985. pp. 22,
23.
10. James K. Brown, US Forest Service. Handbook for
Inventorying Downed Woody Material. September 1974.
pp. 1, 2.
11. Roger D. Ottman and Colin C. Hardy, U.S. Forest
Service. Stereo Photo Series for Quantifying Forest
Residues in Coastal Oregon Forests; Second-Growth
Douglas-Fir-Western Hemlock Typef Western Hemlock-Sitka
Spruce Type, and Red Alder Type. PNW-GRT-231, April
1989. pp. 2 through 5.
12. Reference 1, p. 357.
13. Reference 1, pp. 358-359.
14. Personal communication. Janice Peterson, U.S. Forest
Service, and Ken Meardon, Pacific Environmental
Services, Inc.
15. Reference 1, pp. 355, 356.
8-22 September 1992
-------
16. Reference 3, p. 2.
17. Janice L. Peterson. U.S. Forest Service. Air Quality.
Smoke Management, and Prescribed Fire. In:
Proceedings of the 1990 Pacific Northwest Range
Management Short /Course, Fire in Pacific Northwest
Ecosystems. January 23-25, 1990. p. 135.
18. Janice Peterson, U.S. Forest Service. Hows and Whys of
the Smoke Management Reporting System. Rev. 4/90.
19. Reference 17, p. 135.
20. Reference 1, p. 362.
21. Reference 16.
22. Reference 1, p. 362.
23. Reference 1, p. 362.
24. Reference 2, p. 636.
25. Written communication from Day Ely, Colorado Department
of Health, to Janice Peterson, PNW Research Station.
August 7, 1990.
8-23 September 1992
-------
9.0 EMISSION REDUCTION TECHNIQUES
9.1 INTRODUCTION
Many smoke management programs contain techniques that
improve the dispersal of smoke from prescribed burns or
reduce the amount of emissions generated or both. The
purpose of this chapter is to focus on those techniques that
reduce the amount of emissions generated. Some of these
techniques will also facilitate dispersal (e.g., rapid
ignition techniques), while some emission reduction
techniques will not (e.g., backing fires). Further, the
effect of an emission reduction technique on emissions can
vary from burn-to-burn as each burn is unique.
To assist in understanding how emission reduction
techniques "work," it is useful to have an understanding of
how particulate emissions are generated during a prescribed
burn. This is discussed first in this chapter. Following
the discussion on emission production, general emission
reduction principles and techniques are presented. This is
followed by detailed discussions of emission reduction
techniques applied to agricultural burns and to wildland
burns. Next, a presentation is made of various emission
reduction techniques that have been adopted in State laws,
smoke management programs, or memoranda of understanding.
The chapter concludes with a discussion of an effective
implementation strategy for the emission reduction "
techniques element available for the development of area-
specific BACM smoke management programs.
9-1 September 1992
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9.2 EMISSION PRODUCTION
The burning of wildland and agricultural biomass
releases a variety4of pollutants into the atmosphere. The
majority of these emissions are carbon dioxide, carbon
monoxide, hydrocarbons, and particulate matter. Because the
wood or vegetative matter contain other elements, prescribed
burning also releases other chemical compounds into the
atmosphere, though usually in significantly smaller
quantities.
9.2.1 Stages of Combustion
In a prescribed forest burn, there, are several states
(or phases) in the combustion process during the burn. The
1985 Smoke Management Guide identifies four district
phases.1 These phases (illustrated in Figure 9-1), as
described in the Guide, are:
Preignition Phase. In this phase, fuel elements
ahead of the fire are heated; this causes water vapor
to move to the surface and escape. As the fuel dries
and its internal temperatures rise, certain components
of the wood decompose, releasing a stream of
combustible organic gases and vapors. This process is
called pyrolysis. Because these gases and vapors are
very hot, they ignite when mixed with oxygen. This
brings the process to its second phase, flaming
combustion.
Flaming Phase. At the beginning of this phase,
the fuel temperature rises rapidly. Pyrolysis
accelerates and is accompanied by rapid oxidation
(flaming) of the combustible gases, which are now
increasing in greater and greater quantities. The
products of flaming combustion are predominantly carbon
dioxide (CO2) and water vapor. This water vapor is not
the result of fuel dehydration (preignition phase), but
rather a product of the combustion reaction.
Temperatures in this phase range between 600 and 2500
degrees Fahrenheit. Some of the pyrolyzed substances
cool and condense without passing through the flame
zone; others pass through the flames but are only
partially oxidized, producing a great variety of
emissions. Large-molecule organic compounds are
synthesized here. Many organic compounds of low
molecular weight remain as gases and move down wind;
some compounds with higher molecular weights cool and
9-2 September 1992
-------
WIND
PRE-IGNITION
(RADIATION & ADVECTION)
FLAMING
ft
CM
o
o
O
O
SMOLDERING GLOWING
ASH
Figure 9-1. Stages'of Combustion During a
Prescribed Forest Burn
Source: Reference 1, p. 5.
September 1992
9-3
-------
condense into tar droplets and solid soot particles as
they move away from the fire. These particles make up
the visible smoke component. The more inefficient the
burning, the more soot and tar produced.
Smoldering Phase. In this phase, the overall
reaction rate of the fire has diminished to a point at
which the concentration of combustible gases above the
fuel is too low to support a persistent flame envelope.
Consequently, the temperature drops and the gases
condense. The resulting condensates appear as visible
smoke as they escape into the atmosphere. The heat
release rate of a smoldering fire is seldom sufficient
to sustain a convective column. The smoke evolved
during this phase is virtually soot-free, consisting
mostly of tar droplets less than a micrometer in size.
Near the end of the smoldering phase the evolution of
pyrolysis products ceases, leaving the fuel as a black
char. The final phase of combustion then takes place.
Glowing Phase. In the glowing combustion phase,
all the volatile material in the fuel has been driven
off. Oxygen in the air can now reach the fuel; the of
the charcoal begins to burn with a characteristic
yellow glow. There is no visible smoke. Carbon
monoxide and carbon dioxide are the principal products
of glowing combustion. This phase continues until the
temperature drops or until only noncombustible, gray
ash remains.2
In general, agricultural burns are composed of a
flaming stage and a smoldering phase. This is due to the
nature of the primary fuels being burned (i.e., agricultural
residue). Further, for many agricultural residues, there is
a minimal smoldering phase.
9-2.2 PM-10 Emissions Generation
The amount of PM-10 released from a prescribed burn can
be viewed as a function of four factors:
1. The number of acres to be burned;
2. The pre-burn fuel loading (i.e., the total biomass
per acre);
3. The percent of the fuel consumed in each combustion
stage; and
»
4. The applicable emission factor (pounds of PM-10 per
ton of fuel consumed).
9-4 September 1992
-------
For prescribed wildland burns, the amount of PM-10
emissions will be more accurately estimated by identifying
the pre-burn fuel loading of each fuel bed component. There
are four basic fuel bed components: live fuels, which may
or may not be present, comprised of brush and herbaceous
fuels; small fuels, including woody material less than 3
inches in diameter and surface litter consisting of twigs
and foliage; large woody pieces (larger than 3 inches in
diameter); and a duff layer, or humus, which accumulate
under forest stands in cooler climates or in anaerobic
conditions.3 Figure 9-2 shows the relationship of PM-10
emission generation to the four fuel bed components, fuel
loading, and proportion of fuel consumed in flaming and
smoldering stages.
9.3 GENERAL EMISSION REDUCTION TECHNIQUES
The emission reduction techniques described in this
section outline the general categories of emission reduction
techniques that one can evaluate for each prescribed burn.
In general, one can usually find one or more specific
methods that could be applied to any given prescribed burn.
However, it must be emphasized that no two burns are alike.
The same method used for one burn may not be applicable to
another because of, for example, the slope of the land or
the resource objective of the burn.
In addition, the same method applied for one burn is
more likely than not to result in a different amount of
emission reduction (percent) when applied to another burn.
Unfortunately, because of all the variables that affect
emissions, it is impossible within the scope of this
document to try to begin to specify expected emission
reductions from each technique in each possible situation.
The sections following this one describe specific methods
applicable to agricultural burns (9.4) and wildland burns
(9.5), identifying where possible limits to their use and
potential emission reduction levels.
9-5 September 1992
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FURT.RBD
COMPONENT
UVH FUELS
(BRUSH AND
GRASS)
SMALL FUELS
(INCLUDING
SURFACE
UTTER)
LARGE FUELS
(WOODY
PIECES
>3 INCH
DIAMETER)
DUFF (HUMUS)
(DECAYED
ORGANIC
LAYER)
FUEL LOADING
(TONS PER ACRE)
CONSUMPTION
(PERCENT IN FLAMING)
(PERCENT IN SMOLDERING)
EMISSION FACTOR
(POUNDS PER TON)
Figure 9-2. Typical PM10 Emission Yields From
Prescribed Forest Burning
Source: Reference 3,- p. 639.
September 1992
9-6
-------
Emissions of PM-10 from prescribed burning can be
reduced using many different methods. These methods can be
categorized according to the four basic components that
affect the amount of PM-10 generated: (1) reduce the number
of acres burned; (2) reduce pre-burn fuel loadings; (3)
reduce fuel consumption; and (4) burn in ways that lower the
applicable emission factor, which is generally accomplished
by shifting combustion to the flaming phase. Within each of
these categories, methods may also be distinguished as
alternatives to burning versus improved burning techniques.
Finally, over all of these is the general improvement one
can gain by having all burners learn to burn properly; that
is, a poor burning technique may l^ad to greater emissions.
The following paragraphs discuss the four categories of
general emission reduction techniques.
9-3.1. Reduce the Number of Acres Burned
Perhaps the most obvious method to reducing PM-10
emissions is to simply reduce the number of acres burned.
Everything else being equal, the fewer acres burned, the
less PM-10 emitted. Specific methods that can lead to
burning fewer acres include:
legislated maximum allowable acreage;
residue/straw utilization sufficient to preclude the
need for any burning (e.g., conservation tillage
techniques);
planting of alternative crops that do not require
burning;
soil incorporation;
chemical controls;
use alternative treatment methods; and
- processing unburned sugar cane.
9-7 September 1992
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One method that could be included in this category is
less-than-annual year burning, in which a field is burned
every other year or less frequently. With this method,
PM-10 emissions would be zero every year'the field.is not
burned. This method effectively reduces the number of .acres
burned (by one-half, if alternate year burning is used). By
staggering the acres burned each year, this method can help
reduce overall emission levels.
As a note of caution, simply reducing the number of
acres burned may result in only delaying the release of the
particulate emissions, either through prescribed burns at a
later date or as the result of a wildfire. Therefore,
reducing the number of acres burned- should be accomplished
by methods that result in a true reduction of biomass that
is burned.
A. completely different set of methods may be placed in
this category. This set of methods covers techniques that
rely on burning the biomass, but not under the "open"
conditions of a prescribed burn. These methods include
mobile field sanitizers and propane flaming for agricultural
residues and air curtain destructors for forest residue.
This category basically covers methods that takes
acreage away from prescribed burning. The following three
categories incorporate general methods that manipulate one
or more of the three remaining components so as to reduce
PM-10 when the prescribed burn is conducted.
9-3.2 Reduce Pre-Burn Fuel Loadings
The basic relationship assumed here is that by reducing
the fuel loading beforehand, less fuel is consumed when the
burn is conducted. The effectiveness of this goal in
reducing PM-10 emissions depends, in part, on reducing the
loading for the particular fuel bed component(s) that will
be consumed during that particular burn, whether that
component is the target of the burn (which can and will vary
depending on the objective of the burn) or is "collateral"
9-8 September 1992
-------
fuel (i.e., all burns will consume some fuel bed component
that could otherwise not have been consumed if one could
achieve 100 percent precision).
The following is a list of methods for prescribed
forest burns that could be used to reduce the fuel loadings
associated with three of the four fuel bed components.
There is very little one can do to reduce the pre-burri
loading of the duff layer.4
Live Fuel Component
burn outside the active growing season
burn soon after timber harvest
burn frequently (e.g., 3-year frequency versus
5-year frequency)
x«-
Small Fuel Component .
whole tree harvesting (removes limbs along with
tree boles)
burn frequently
schedule underburns before litter fall
Large Fuels
harvest before burning
isolate the large fuels from the fire by burning
the small fuel in piles5
For agricultural fields, the primary method is the
increased removal of straw/stubble before conducting the
burn. For rangelands, the primary method is through
increased grazing to remove biomass in an effort to reduce
fuel loading prior to burning.6
9.3.3 Reduce Fuel Consumption
This category refers to reducing the proportion of
biomass that is actually burned. The goal is to be able to
consume only that biomass that needs to be burned or
consumed and still meet the resource objectives of the burn.
The proportion of biomass consumed is affected by
several factors, including fuel moisture, fire intensity,
and fire residence time. In general, lower fuel moisture
9-9 September 1992
-------
contributes to greater proportions of biomass being
consumed. Fire intensity and residence time are inter-
related. The higher the fire intensity for a given
residence time, the greater the proportion of biomass that
will be consumed. Similarly, the longer the residence time
for a given fire intensity, the greater the proportion of
the biomass that will be consumed.
Emission reduction techniques for reducing fuel
consumption have focused primarily on burning at times of
higher moisture contents. It is important to note that
burning during periods of high moisture content can increase
the emission factor. This is especially true for the live
fuel component. Thus, the net effect of lower fuel
consumption and higher emission factor on total emissions
may not be certain.
Fire intensity and residence time need to be considered
together in order to achieve reduced fuel consumption. The
primary method for reducing fuel consumption using these two
factors has been the use of mass ignition techniques (e.g.,
aerial ignition). Mass ignition techniques generate very
high intensity fires that burn very quickly (short residence
time). In these situations, the larger fuels do not have
the time to ignite and burn before the fire passes. This
results in lower total fuel consumption.
The following is a list of methods that can be used to
reduce fuel consumption for each of the four fuel bed
components.
Live Fuel Component
burn during period of high fuel moisture
burn during phenological stages when flammability
is low (season of low flammability, high relative
humidity)
Small Fuel Component
burn when the litter layer is moist
limit smoldering consumption by using a backing
fire
9-10 September 1992
-------
Large Fuels
burn when moisture content is very high
use mass-ignition techniques that produce a
short-duration fire
Duff Component
burn when duff is wet
reduce large fuel consumption (in conifer stands
other than pine, the amount of duff consumed is
linked to the mass of large fuel consumed)6
The appropriateness of any of these techniques will, of
course, depend on the resource management objective, which
will define the target fuel(s) and the characteristics of
the prescribed fire (e.g., fire intensity) needed to
accomplish the resource management objective.
9-3.4 Lower Applicable Emission Factor
There are ways that prescribed burns can be conducted
so as to lower the overall, applicable emission factor for a
particular burn. The emission factor can be viewed as a
composite emission factor based on emission rate generation
during each of the four phases of a burn. Most PM-10
emissions are generated during the flaming and smoldering
stages. Generally, emission rates during the smoldering
phase are higher, sometimes significantly higher, than those
during the flaming phase. Table 9-1 illustrates typical
particulate emission factors for various fuel types and fire
behavior (flaming and smoldering components.) Thus, for
many types of burns, employing techniques that shift the
proportion of the burn from the smoldering phase to the
flaming phase will lead to an overall reduction in the
composite emission factor. Two primary techniques are (1)
shifting from broadcast to pile burns and (2) employing
backfiring techniques. It should be noted that for many
types of prescribed burns, backfiring techniques, in
particular, will also result in a greater proportion of the
bioraass being consumed. The net effect on emissions (lower
9-11 September 1992
-------
emission factor versus more biomass consumed) may thus be
ambiguous and should" be evaluated on a site-by-site basis.
9.4 EMISSION REDUCTION TECHNIQUES - AGRICULTURAL BURNING
Major alternatives to replace agricultural burning
considered to date include the mobile field sanitizer,
alternative crops, mechanical residue removal, and residue
incorporation including winter composting. The viability of
these and other alternatives depend on several factors.
First, the viability of any single alternative depends, in
part, on its ability to meet the same resource objectives
being accomplished by the prescribed fire. If the
alternative cannot by itself meet the same resource
objectives, then its viability depends on the development of
other alternatives such that a combination of methods can
provide the same resource objectives being accomplished by
the prescribed fire. Second, free adoption of alternative
methods by farmers depends on economic competitiveness. For
example, open field burning in almost all cases has shown to
be the most cost-effective practice. Third, the alternative
must also be agronomically feasible. Any alternative that
significantly reduces crop yields is not likely to be
accepted by farmers or growers. Discussions of each
alternative to agricultural burning follows.
9.4.1 Reduction in Acres Open Burned
Extensive efforts have been made to find alternatives
to open field burning, especially in the Willamette Valley
where 200,000 acres of grasses and field crops are burned on
average every year. These alternatives can be grouped into
two major categories: (1) techniques that replace, either
in total or in part, open field burning with alternative
burning techniques, and (2) alternatives that do not rely on
any type of burning at all.
Each of the techniques discussed below directly reduce
the number of acres that are open burned every year. Not
9-12 September 1992
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TABLE 9-1. EMISSION FACTORS FOR PARTICULATE MATTER
AS A FUNCTION OF FIRE BEHAVIOR
General
Fuel Type
Fire Behavior
Participate
Emission Factor
Grass
Understory
Vegetation
and Litter
Broadcast
Slash
Piled and
Windrowed
Slash
Brush Fuels
All Fuels
Flaming dominates
Flaming w/light smoldering1
Flaming w/moderate smoldering4
Flaming w/moderate smoldering5 ^
Flaming dominates
Flaming w/smoldering component
Flaming dominates'
Flaming w/moderate smoldering
Flaming w/heavy smoldering7
Flaming dominates
Flaming w/moderate smoldering
Burning where smoldering dominates
Lbs/Ton'
15
25
50
75
20
40
25
50
75
25
50
150
1 These emission factors are generalized estimates based on research data, combustion fundamentals, and scientiGc
judgment. They should be modified as needed in regional supplements to this guide in accordance with the latest
information on fuels, firing techniques, smoke particle size, etc. Further consultation can be obtained on western fuel types
by calling or writing Darold E. Ward, Intennountain Fotest and Range Experiment Station and Charles K. McMahon at the
Southern Forest Fire Laboratory on eastern fuel types.
2 Lbs/ton of fuel burned. 1.0 Ib/ton = 0.5 g/kg (dry weight basis).
3 i.e., backing fires or heading fires in light fuels without duff involvement.
4 i.e., heading fires in litter fuels with heavy loading.
5 i.e., fires in litter fuels with substantial duff consumption.
* i.e., soil free and very dry.
7 i.e., heavy mineral soil component and/or high fuel moisture.
SOURCE: Reference 1, p. 9.
September 1992
9-13
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all of the techniques, however, reduce particulate
emissions. In addition, the technique in which a field is
open burned on a less-than-annual basis does not reduce
emissions every year from a particular field, although the
average emissions over 2 or more years will be less than if
the field was open-burned annually. (On the years that the
field is not burned, the residue is mechanically removed and
disposed of, so that there is not an accumulation of
residue.) Further, as noted earlier, staggering the fields
that are open-burned will reduce overall annual emissions
from all open field burning in an area.
The following paragraphs discuss the various techniques
that have been tried or are currently being used to reduce
the number of acres open-burned. Alternative burning
techniques, including less-than-annual burning, are
presented first. Then, no burn alternatives are presented.
9.4.1.1 Mobile Field Sanitizers. When alternatives to
agricultural burning were first considered, the mobile field
sanitizer received much attention and research effort. A
mobile field sanitizer is a machine designed to burn
agricultural residues in place, and serves as a method of
both straw removal and field sanitation.
Several designs of field sanitizers were developed
beginning in 1969 and field tested, through most of the
1970's, in California and Oregon. In California, the field
sanitizers were tested on rice fields during the early
1970's. Results of these tests indicated that while carbon
monoxide and hydrocarbon emissions were reduced, particulate
emissions were increased over those emissions from open
burning. In addition, the mobile field sanitizer was found
to be of limited durability, maneuverability, and fire
control value.7 Finally, the forward speed of the machine
had to be very slow due to large amounts of rice straw and
the sheer weight made its use "practically impossible"
during much of the normal burning months in California due
9-14 September 1992
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to poor (e.g., wet, rutted) field conditions.8 As a result,
research was discontinued in California with the approval of
all concerned.
In Oregon, research and testing on the mobile field
sanitizer on perennial grass crops continued until 1978.
The research indicated that the field sanitizer was capable
of thorough removal of residue around and on the plant crown
over a moderate range of field conditions without serious
injury to the plant. Temperatures of more than 1/000°F at
the soil surface for short periods were recorded without
seriously affecting plant survival and seed yield in the
following year. Agronomists found that the most effective
burn treatments were made during the midsummer season when
the cool-season perennial plants are dormant. Use of the
field sanitizer later in the year (after the plant's
regrowth had been initiated) increased plant mortality and
reduced regrowth and seed production as did late open field
burning.9
In 1978, the FMC Corporation prepared a report,
commissioned by the Oregon Department of Environmental
Quality, evaluating the technical and economic feasibility
of the field sanitizers. The report concluded that the
field sanitizer was not an economic alternative to open
field burning because of problems with short machine life,
high operating costs, energy use, effective emission
control, and slow operating speed. The report stated that
though:
... a machine can be made which can effectively
accomplish the sanitation function, achievement of
significant emission reductions was unlikely.
Reductions in costs of construction and machine
maintenance did not appear likely in the future
and considerable annual subsidy was expected to be
necessary to enable growers to realize the same
net profit using the sanitizers as they would with
open field burning. In addition, none of the
machines which had been built to date were
considered to have been adequately tested or ready
for production.10
9-15 September 1992
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Based on these conclusions, the State of Oregon elected to
discontinue the development and testing of mobile field
sanitizers.
While the State of Oregon discontinued development of a
mobile field sanitizer, there has been private development
of mobile field sanitizers. In particular, there is one
farmer in the Willamette Valley that is successfully using a
privately-developed mobile field sanitizer. This particular
farmer is growing high-value, proprietary varieties of
grasses. The value of these crops has enabled the farmer to
fund the development of the sanitizer. The cost of
development has precluded others from seeking to develop a
mobile field sanitizer.11
In summary, the mobile field sanitizer is a viable
alternative to open field burning. Its applicability
appears limited primarily by the cost of development and the
economics of using it compared to open burning.
9.4.1.2 Propane Flaming. In the mid-1970's, Oregon
began examining the use of propane flamers, originally built
for use on mint fields, as an alternative to open field
burning. Propane flaming with residue removal as a
companion practice is being used by an increasing number of
growers, especially in the Willamette Valley's North Valley.
An estimated 56,000 acres were sanitized by propane flaming
in 1988."
Agronomic studies and field tests showed that thermal
sanitation achieved by propane flaming could be similar to
open burning without major seed yield loss, but only if most
of the straw residue were removed prior to propane
flaming.13 However, studies in annual ryegrass showed that
the temperature and duration of propane flaming was not able
to destroy many of the weed seeds, whose survival was
reflected by an increase in weed infestation."
Higher residue levels left on the ground provided a
greater combustible mass during dry weather thereby
9-16 September 1992
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permitting faster field operation, but generating greater
emissions near ground levels. (Emissions from propane
flaming tend to stay close to the ground, thereby creating a
higher potential impact downwind. For an equivalent field
size, propane flaming can take up to five times longer than
open burning). Thus, residue removal, except for the
stubble, and slow field operation are necessary for good
results. This means that to be effective, the large volume
of residue, some 2 to 4 tons per acre, has to be removed as
a companion process to propane flaming, with subsequent use
or disposal of the residue.15
Cost of propane flaming is influenced by speed of
operation and has been shown to range between $32.00 per
acre at l mph and $8.00 acre at 4 mph. Increasing the
amount of residue allows for faster operating speeds but
results in increased emissions. More complete stubble
removal in advance of propane flaming requires slowing
operating speed to achieve good sanitation.16
Due to the increase in the use of propane flaming, an
air quality study was funded by Oregon's DEQ to examine
emissions from propane flaming. Eighteen propane flaming
operations were sampled. Results showed a particulate
emission factor of 0.051 for propane flaming. This is
approximately 2.5 times higher than the emission factor of
0.20 for open field burning, given an equal fuel load.
Since the fuel loads on fields that are propane flamed are
approximately 10 percent of the fuel loads on fields that
are open burned, emissions per unit of area burned are about
66 kilograms per hectare (kg/ha) for propane flaming and 180
kg/ha for open field burning.17
9.4.1.3 Bale/Stack Burning. In Oregon, some growers
in the Willamette Valley are burning straw bales or stacks
of unmarketable crop residues. This practice has increased
with the increase in the use of propane flaming (which
requires straw removal). The State of Oregon is continuing
9-17 September 1992
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to monitor the practice of bale burning to assess its
potential smoke impact."
A recent air quality study on emissions from straw
stack burning/ in which eight stack burns were included,
found an emission factor of 0.013. This compares to an
emission factor of 0.020 for open field burning.19
9.4.1.4 Less-Than-Annual Year Burning. This practice
involves alternating open field burning with various methods
of mechanical removal techniques. The periods may involve
burning every other year or every third year.
Less-than-annual year burning has been found in Oregon
to reduce seed yield when comparedxto annual burning for
perennial ryegrass by about 7 percent over a 5-year period.
This same reduction was seen for both crew cut and flail
chopped techniques were used for straw removal. No
deleterious effects, however, on seed yield were reported
for fine fescue or bluegrass in Oregon when averaged over 4
years.20
9.4.1.5 Soil Incorporation and Conservation Tillage.
The potential for the incorporation of crop residues into
the soil to replace open field burning is limited primarily
by economics, lack of adequate pest and disease control, and
decomposition rate. An additional factor may be residue
loading, as heavy loadings make incorporation of all of the
residue very difficult, possibly resulting in straw being
returned to the surface. If straw returns to the surface,
difficulties in reestablishment of grass stands in
subsequent years may occur.21 Finally, farmer attitudes
toward changing practices may slow acceptance of this
practice and limit its potential to replace burning.
The importance of the above factors in limiting the
potential use of soil incorporation varies with the type of
crop and the geographic location. For example, rice straw wB
can be returned to the soil in the southern rice belt due to
9-18 September 1992
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into rapid decomposition there, whereas in California straw
decomposition is not as rapid. Even within California, the
potential for plowing rice straw back into the ground varies
as straw decomposition rates have been found to vary
substantially among the soil series on which rice is grown.
Also, in California research has shown that although soil
incorporation of residues is a technically-acceptable
alternative to burning, it is more expensive, and where stem
rot disease is a problem, continued plowing under results in
substantial yield reductions.22
In Oregon, the incorporation of straw from annuals is a
highly variable option. The many soil variations in the
Willamette Valley make soil incorporation a viable option
for some areas, but not others. In the Willamette Valley,
the water table is close to the surface in certain
locations. In these areas, the bacteria that would
otherwise aerobically decompose the straw are inactive.
Improvements in straw choppers have resulted in finer straw
that is easier to incorporate.23
A number of research projects have been conducted in
Oregon on the feasibility of soil incorporation or
conservation tillage. In one project, soil incorporation
was found to be technically feasible only for the annual
ryegrass, although high straw yields, dense clay soils, and
wet environment are not conducive to straw decomposition.24
In a set of agronomic trials in 1984, seed yield from open
burning and annual incorporation of straw were shown to be
comparable when 80 pounds of nitrogen per acre was applied
in the spring. However, the plow-down treatment in these
trials represented a definite increase in production cost.
Further, the soil incorporation of weed seed in the residue
compounded weed management problems, increased cost for weed
control, and increased the risk of lower product quality in
the marketplace.25 In another study on minimum tillage
plots in 1985, a stand of both red clover and meadowfoam was
planted directly into ryegrass stubble. Initially, the red
9-19 September 1992
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clover established in flail-chipped area showed somewhat
less vigorous and less uniform growth than those established
in burned areas, although by mid-1986 no visible differences
were apparent between the two. The meadowfoam crop matured
uniformly across burned and flail-chopped areas. Weed
control treatments for both red clover and meadowfoam stands
were also fairly successful.26
A relatively recent development in Oregon is the winter
composting of straw. Straw is removed from the field to a
nearby field. There, the straw is aerobically composted
during the winter. The composting typically takes between
45 to 60 days. The composted straw is then available for
incorporation into the soil of a nearby field. One drawback
to date has been problems with mud for getting into the
field during winter, which is the wet season.27
In Nebraska, conservation tillage has become more
widely used since 1975. Previously, nearly every wheat
field was burned after harvest. In 1983, only an estimated
1 in 20 wheat fields was being burned. This change in
practice was attributed to the "reeducation" of the farmer
concerning the relative desirability of the two practices.
Where burning still occurs, it is attributed to reluctance
of the longtime farmer to change from the practice he has
always used.28
9.4.1.6 Alternative Crops. One alternative to
agricultural burning is to replace crops whose residues are
typically burned with crops whose residues need not be
burned. The feasibility of this alternative depends upon
the relative economic and agronomic capabilities of the
alternative crop to the current crop. Where crop patterns
have developed over time in accordance with agronomic
conditions and market demands, there is a limited potential
for major crop shifts.29
Most research in the use of alternative crops has taken
place in Oregon. Experience in the Willamette Valley has
9-20 September 1992
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shown that alternative crops with the best agronomic
viability have not been economically competitive with
perennial grass seed production in the valley. The Oregon
Department of Environmental Quality notes that in the
Willamette Valley, "the poor quality soils on much of the
valley floor effectively limit the kinds of crops which can
be grown, and the economic risks to the grower of making
major cropping changes has been prohibitive" and that at
present "there are currently no economical crop substitutes
available to grass seed growers in most areas of the
Willamette Valley."30
Since 1980, research has continued in the Willamette
Valley on three potential alternative crops: meadowfoam,
rapeseed, and Pyrethrum. Meadowfoam is a potentially viable
option, especially for a large portion of the annual
ryegrass acreage. Meadowfoam is well suited to the poor
soil conditions in the Valley, its residue easily decomposes
on the ground, and it requires essentially the same
equipment and cultural practices as grass farming.31
Meadowfoam was identified as a potential crop with
preliminary plot trials initiated in the mid-1970's. Since
that time, studies of yield increase, seed dormancy,
production, and economic feasibility and market development
analyses have been done. Oil extracted from meadowfoam
appears to have potential for industrial and cosmetic trade
utilization. Two principle factors limit its use at this
point. The first is low yield. A major effort is being
made to improve seed yield and to reduce production costs
enough to compete with oils currently used in the market.
The second factor is that no industrial utilization research
yet has been conducted to ascertain the qualities and
properties of meadowfoam and hence potential role(s) in
industrial and cosmetic markets. Research has been
initiated in this area. Potential technical viability of
meadowfoam as an alternative crop for adoption is estimated
to be 5 to 10 years away from consideration. Whether it
9-21 September 1992
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will be an economically viable choice at that time is
questionable. Its potential scope is unknown, but appears
to be limited. Currently, some 20 to 25 growers produce
less than 200 acres annually with excess inventory of oil on
hand.32
Rapeseed can be grown on a variety of soils, although
it is not tolerant of prolonged wet conditions. Likewise,
Pyrethrum does not do well on poorly drained soils, but the
demand for natural pyrethrin remains strong and preliminary
commercial development is currently privately under way.33
A number of crops have been grown on grass seed lands
in the Willamette Valley. They include small grains, grass
pasture for livestock, alsike clover, and vetch. Each of
these crops are less intensive in nature and hence less
profitable than grass seed on a per acre basis.34
In California, rice farmers have been reluctant to stop
farming rice because of the unsuitability of the high clay
soils for growing other crops. In the Sacramento Valley of
California, approximately half the rice acreage can be
switched to or related with other crops, although the extent
to which this is feasible needs to be determined.35
9.4.1.7 Mechanical Residue Removal. Several
mechanical residue removal practices, involving the removal
of straw alone or both straw and stubble in grass fields and
rice, alfalfa and other field crops where residue may be
classified as straw and stubble, have been tried. These
methods include:
raking the straw (leaving remaining stubble intact);
flail-chop removal of a major portion of the straw
and stubble; and
close clip removal of most stubble and organic
material on the soil surface (also known as "crew
cutting").
Research in Oregon has indicated that mechanical residue
removal provides adequate field sanitation under certain
9-22 September 1992
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conditions. A protype crew-cutting machine was found to be
an effective treatment for approximating the physiological
response (plant growth and seed yield) of burning.
The major concern of mechanical residue removal in
Oregon field crops appears to be the effect on seed yields,
although this effect will vary with species, variety, and
thoroughness of removal. In general, it appears that the
greater the degree the removal of residue, the higher the
seed yield. In an evaluation of six grass species, seed
yield was lowered by an average of 48 percent when no straw
was removed. Raking of the straw was little better than
leaving the straw. Flail-chopping to remove additional
straw was somewhat better than raking.36
Seed yields from crew-cutting can approach or equal -
those that occur when burning is used. Through 3 years of
testing, crew-cutting was found to maintain seed yield equal
to burning on fine fescue and Kentucky bluegrass. On the
other hand, crew-cutting and flail-chopping were found on
average to both reduce seed yields by about 15 percent over
4 years when used on perennial ryegrass.37
Although crew-cutting tends to be the best overall
method of the mechanical removal treatments, it involves
special equipment not yet commercially available. In order
to use crew-cutting machines, straw residue must be removed
first, and the fields must be smooth and free of ridges to
be satisfactorily treated. Rocks can pose a problem when
struck by the cutting blades. Crew-cutting releases soil
and chaff particles into the air. The residue removed from
the field must be disposed.38
Long-term use of mechanical residue removal may result
in adverse pest, weed, and disease control. For example,
weed control problems increase in fields of perennial
ryegrass when they were not burned.39 Thus, mechanical
residue removal methods may require use of chemical control
agents in order to fully replace open field burning.
9-23 September 1992
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Finally, the economic feasibility of mechanical residue
removal and other methods already discussed (field
sanitizers, propane flaming, less-than-annual year burning)
may depend on finding a market for the residue. From a
technical standpoint, straw can be used as a raw material to
make a wide range of products for fiber (paper,
particleboard, fuel logs, hydromulch, comported fertilizer,
etc.), chemical products (oil, gasoline, plastics, microbial
protein, etc.), and livestock feed.
Historically, it has been difficult for grass straw to
compete in existing markets as a raw material source. Low
bulk density of the straw, which requires costly
densification, high cost transportation, uncertainty of
long-term supply, and low volume of supply in fiber markets,
have usually made straw noncompetitive with other raw
materials. The traditional base for making pulp and paper
in the Pacific Northwest is wood chips which are cheap,
adequate in continuing supply and volume with manufacturing
technology adapted to that source and require no storage
from rainy weather. Converting to straw would involve major
retooling in the wood fiber industry.40
As a feedstuff for livestock, untreated straw is of
poor quality because of low protein and high fiber content.
With appropriate treatment, such as ammoniation, the
digestibility and palatability of straw can be increased
substantially making straw a potential component of
maintenance diets for ruminant livestock. Costs of physical
and chemical treatment have made the process marginal in an
economic sense.41
In general, therefore, residue use in most markets
faces a large economic handicap: most residues are
dispersed over large areas, requiring costly collection; or
far from markets, requiring costly transportation; limited
in quantity, quality, or dependability, resulting in lower
value to the buyer. In the Pacific Northwest, however, the
economics of fiber residue is changing significantly. Straw
9-24 September 1992
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from grass seeds are very similar in structure (short
fibers) to hardwoods. With a shortage of hardwood being
projected, grass straw is becoming more economically
attractive. Further, pressure on reducing'timber harvest
(because of conflicts with endangered species) as a biomass
fuel source could create a demand for grass straw as a fuel.
Some work is also being conducted on digesting straw at
sewage treatment plants, with the residue being applied to
non-food crop fields.42 In Oregon, most of the negatives
have been overcome in the sale of grass straw to Japan as
supplemental livestock feed. While Japan currently imports
125,000 to 150,000 tons of straw annually and this market is
expected to grow at the rate of 5 percent per year, perhaps
20 percent of all straw removal in the Willamette Valley is
marketed.43
The viability of alternative uses varies substantially
among types of crop residues. For example, there are more
potential uses for the residues from field crops such as
wheat, barley, and corn than from rice. Farmer attitudes
may play a very important part in the ultimate feasibility
of any alternative use. In a report prepared by the
Department of Agricultural Engineering, University of
California, Davis, examining the use of agricultural
residues for energy productions, a survey of rice growers
and fruit and nut growers found that "attempts to utilize
the straw which require added expense or extra work for the
grower will be resisted unless a stimulus exists that
encourages them to accept the change."44
9-4.1.8 Harvesting of Unburned Sugar Cane. Tests were
conducted in Hawaii45 and Texas46 on the feasibility of
processing unburned versus burned sugar cane, and in
Louisiana on the removal of trash, by a wholestalk cane
cleaner.47 Results of the Hawaiian tests indicated that,
when processing unburned cane, there is:
9-25 September 1992
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1. a substantial increase in harvesting and hauling
requirements in terms of both men and equipment;
2. a moderate-to-substantial reduction in factory
operating rates with existing facilities;
3. nearly equal extraction at the reduced grinding '
rates but a slight reduction in boiling house
recovery, with overall recovery being slightly
less;
4. a small but significant improvement in yield of
sugar/acre, apparently a result of smaller losses
in the cleaning plant; and
5. substantially poorer sugar refinability in terms of
both color and filterability.48
The Hawaiian Sugar Planters' Association estimated that
harvesting unburned sugar cane would result in an estimated
annual loss of $73 million to Hawaiian sugar cane growers,
assuming a production of 1.1 million tons of sugar per year
and a break-even sugar price of $400 per ton.
Results from the Texas tests showed that harvesting
green cane resulted in (1) a 7.41 percent sugar recovery
loss and increased production costs 9.2 percent by reducing
harvester, in field transport, trucking and milling
efficiencies, and (2) 2.37 times more vegetative material
left after harvesting than left in burned fields.49
Finally, results from the Louisiana tests during the
1970 and 1971 seasons showed somewhat favorable cleaning
efficiency results and potentially favorable economics. As
of 1972, the status of the feasibility of wholestalk cane
cleaner had not been established.50
9.4.2 Factors Affecting Pre-Burn Fuel Loading. Fuel
Consumptionr and Emission Factors
There are a number of factors that can be manipulated
to reduce emissions when a field is burned. These factors
include: amount of green regrowth, fuel distribution,
firing techniques, and fuel moisture content.
9-26 September 1992
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9.4.2.1 Amount of Green Regrowth. Fuel loading
affects the amount of pollutants released during an
agricultural burn the greater the amount of residue, the
greater the emissions. Quantities of emissions generated,
therefore, will vary directly with the amount of green
regrowth after harvest and before the burn.
9-4.2.2 Fuel Distribution. Studies show that the
method of piling residue in the field may affect the amount
of emissions. One study (laboratory and field tests) on
wheat and barley straw showed emissions from straw piles to
be about one-third on those from spread straw burned with a
headfire. In laboratory simulations, the effect of fuel
distribution was significant for simulated headfires only.51
In a study for Oregon, straw stacks were found to have a
lower emission rate than regular open field burning. In
Oregon, a technique known as "fluffing" has been shown to
have considerable value in enhancing the plume rise
characteristics of a burn and reducing the associated low
level of smoke.52
. 9.4.2.3 Firing Techniques. Significant reduction in
the impact from burning of grass straw and stubble fields
can be attained through rapid burning. Thus, the type of
firing technique can be an important tool towards reducing
emissions. Agricultural fields are burned using several
firing techniques. The major techniques are:
Headfiring: a single flame front advances with the
surface wind direction;
Backfiring: a single flame front advances into the
surface wind direction;
Into-the-Wind Strip Lighting: backfiring with
additional flame fronts advancing into the surface
wind direction; and
Perimeter Lighting: all sides of the field are
ignited.
9-27 September 1992
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Headfiring is the traditional firing technique; It
generally produces the most emissions, a rapid burn, and
good plume loft.
Backfiring was the first alternative firing technique
to be studied. Backfiring has been shown to substantially
reduce emissions in comparison to headfiring and produces
the lowest amount of emission among these four burning
techniques. (However, since backing fires tend to consume
more biomass than heading fires, not all burns may
experience lower emissions. Each burn needs to be evaluated
individually.) In tests on 80 rice fields, backfires were
found to emit about one-half the amount of particulates as a
headfire at the same fuel moisture^content. However, for
wheat and barley straw, the results from 50 field tests
showed no significant differences in particulate emissions
between headfires and backfires.53 Surface smoke impact can
be greater with this firing technique than with the others.
In addition, backfiring gives the slowest burn, covering the
field up to 20 times slower than headfiring.54
Into-the-wind-stripfiring reduces the burn time
associated with backfiring, produces emissions equivalent or
greater than backfiring but less than headfiring, and
produces a plume loft between that produced by backfiring
and headfiring. Perimeter burning provides maximum plume
loft and minimizes the amount of ground-level smoke.
However, this technique may produce the greatest fire
danger.5S
9.4.2.4 Fuel Moisture. Fuel moisture content is an
important factor in the generation of emissions from
agricultural burning. The higher the fuel moisture content,
the poorer the combustion and the greater the release of
particulates, hydrocarbons, and carbon monoxide.
In a study of 80 field tests, a reduction in the
moisture content of rice residue from 25 to 10 percent
showed a reduction in emissions from 18 to 5 kilograms per
9-28 September 1992
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. . .
megagram of residue burned for headfires. On the other
hand, no significant differences were found for wheat and
barley straw. This is because wheat and barley are
harvested- in the summer, when the plants are senescent and
drying conditions are excellent. The resulting straw
residue thus already has a very low moisture content (4-5
percent) compared to rice straw, which rarely dries to 10
percent moisture.56
9.5 EMISSION REDUCTION TECHNIQUES - WILDLAND BURNS
In this section, emission reduction techniques
applicable to prescribed wildland burns are discussed in
more detail. The applicability of ^a. particular technique to
a particular burn will depend, in part, on the objective(s)
of that burn. For example, where the objective of a
particular burn is to open the forest crown to allow
sunlight to reach the forest floor to create open space for
wildlife (wildlife improvement), a backing fire, although
producing less emissions than other firing techniques, may
not produce sufficient fire characteristics to achieve the
objective.
Objectives of wildland burns were identified in
Chapter 2. Objectives of most prescribed wildland burns can
be grouped into three major categories: hazard reduction,
silvicultural objectives, and wildlife improvement. In
general, hazard reduction focuses on removing the fine fuel
from the forest area. The fine fuel is easily ignited and
is the fuel source that allows the wildfire to spread. Fine
fuels may be natural or the result of an activity (e.g.,
timber harvest). Silvicultural objectives are usually for
site preparation and regeneration after an area has been
logged. The objective is primarily accomplished through
slash removal. Disease control is another silvicultural
objective. Wildlife objectives usually focus on either
removing competing vegetative growth to promote brush and
forage vegetation or to open areas underneath the forest
9-29 , September 1992
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crown. Specific objectives grouped here include wildlife
habitat improvement, range (forage) improvement, endangered
species, and ecosystem maintenance.
Table 9-2 presents the general level of applicability
of various emission reduction techniques for various
resource objectives of prescribed wildland burns. It is
important to note that these are general levels of
applicability; the actual level of applicability can vary
from burn-to-burn. Each burn has a unique combination of
characteristics that affect the applicability of an emission
reduction technique. Thus, each burn should be evaluated on
a burn-specific basis.
The following paragraphs discuss in detail emission
reduction techniques, including their general applicability
to each of the major objectives of prescribed wildlands
burning.
9.5.1 Methods to Reduce Acres Burned
There are several alternatives to reducing the number
of acres burned. These are:
no burn,
manual/hand labor,
chemical treatments,
alternate mechanical treatment,
air curtain destructor.
Several of these methods may also be used to reduce
fuel loading prior to a prescribed burn rather than as a
total replacement of prescribed burning. Air curtain
destructors are included here as a replacement of prescribed
burning although the slash is disposed of through
combustion.
9-5.1.1 No Burn. One method to reduce the number of
acres burned is to not to burn the site at all, but allow
the natural process of degradation to occur. This method
has very limited applicability to the resource objectives of
wildland burns.
. 9-30 September 1992
-------
TABLE 9-2. GENERAL APPLICABILITY OF EMISSION REDUCTION
TECHNIQUES TO WILDLANDS BURN OBJECTIVES
EMISSION
REDUCTION
TECHNIQUE
General
Technique
Reduce
Number of
Acres Burned
Reduce
PreburnFiiel
Loading
Reduce Fuel
Consumption .
Alternatives
nobuia
manual/band
labor
chemical
mechanical
air curtain
destructor
improve
utilization
(e.g, whole
tree
harvesting)
burn before
growing
season (live
fuels)
bun
frequently
(live and
small fuels)
bum small
fuel in piles
(large fuels)
bum live
fuels during
season of low
Oammability
reduce large
fuel
consumed
bura when
litterlaverts
moist
burn wheat
fuel moisture
of large fuels
is very high
bum when
duff is wet
burn when
spring-like*
condition
exist
BURN OBJECTIVE
Hazard
Reduction
Natural
Fuels
1
2
0
2
0
2
4
5
1
3
3
3
5
5
2
Activity
Fids
1
3
0
2
4
5
4
1
3
3
3
3
3
5
3
SUe
Prejura*
So.
1
2
2
4
1
3
I
1
2
1
1
0
2
1
1
Wildlife
Habitat
Improvement
1
1
1
2
0
0
4
4
0
3
0
3
1
2
2
Range
Improvement '
1
1
2
3
0
.0
4
4
0
3
2
4
0
4
1
Disease
Control
1
1
2
0
0
1
0
1
0
2
0
3
3
3
1
Endangered
Species
1
1
0
0
0
0
3
2
0
2
0
2
3
3
2
Ecosystem
Maintenance
1
0
0
0
0
0
3
2
0
2
0
2
3
3
2
9-31
September 1992
-------
TABLE 9-2. GENERAL APPLICABILITY OF EMISSION REDUCTION
TECHNIQUES TO WILDLANDS BURN OBJECTIVES
(concluded)
EMISSION
SEDUCTION
TECHNIQUE
OoKnl
Tcciiiqie
RcdKeFwd
Coajwptiom
(coatiiud)
Emiaio.
Rile/Factor
Maaipdatioa
Alternatives
avoid boning
at times o{
naipial
Oaaoubility
aerial
{gBitX»
placement of *
residne(bnra
piles ra tier
On
broadcast)
bus tuiag
nuller piles
Grits
tecaikpw
(usebacaiog
Cientacr
tkaakead
Cre)
cnate a ktgk
blenilyGre
rendKalaMp*
Up /^iaf^rro
ptOpOCIKMi
comaKd
during
smaldaat)
BURN OBJECTIVE
Hazard
RedcctioK
Natural
Fads
5
4
I
1
3
2
4
Activity
Fids
5
4
4
3
3
5
S
Site
Piepan-
tio*
S
4
2
1
3
4
5
Wildlife
Habitat
Improvement
S
4
0
0
3
3
3
Raage
Improvement
S
4
0
0
4
3
3
Disease
Control
5
2
0
0
3
3
3
Species
S
4
0
0
3
3
3
Ecosystesi
Malalemaice
5
4
0
0
3
3
3
KEY: 0 = not applicable
1 = lowest relative level of applicability
S = highest relative level of applicability
9-32
September 1992
-------
The advantage of no treatment is its lower costs, as
long as successful regeneration occurs. The success of
regeneration depends on the site, competing brush, and the
amount of slash.57 The natural process of degradation,
however, is very slow, even when microorganisms are used to
hasten the' decomposition process. One disadvantage of no
treatment is increased wildfire hazard. An increased number
of fire protection personnel may reduce wildfire damage in
areas where no slash treatment is performed. However, if
there is heavy, contiguous slash build-up, even an increased
number of fire fighting personnel may not provide sufficient
protection to reduce the wildfire hazard.38 Increased
competition from brush and grasses jmay lead to loss of trees
and growth. Other disadvantages include higher planting
costs and increased unfavorable animal and insect habitat.59
9.5.1.2 Manual/Hand Labor.60 In this alternative,
planting spots are created and piling of slash is done by
hand. In addition, release objectives are accomplished
using power saws or other equipment. This method is
generally more applicable to silvicultural and hazard
reduction objectives than it is to wildlife objectives.
The advantage of hand methods is their specificity and
low impact on the soil surface. Site-specific areas can be
targeted. In riparian areas, and sites with sensitive
plants, hand methods assure that only target species are
treated.
The major disadvantages of manual methods are their
lower production rates, higher costs, and resprouting. In "
addition, manual methods require extensive human exposure to
potentially dangerous working conditions. Manual methods
have been very ineffective in the most productive sites and
with certain brush species, due to resprouting and high
costs.
Adverse health effects of manual methods include
working on steep slopes with poor footing, in dense or tall
9-33 September 1992
-------
bush, and exposure to exhaust and gas vapors. Chain saws
are dangerous if used unsafely. Workers also face a greater
exposure to the risk of being cut and the exposure to
poisonous plants, snakes, and insects.
9.5.1.3 Chemical Treatments. This alternative
involves the use of herbicides to control vegetation for
site preparation and release. Herbicides can be used in a
variety of areas to control competing and unwanted
vegetation. All herbicides must be registered by the U.S.
Environmental Protection Agency.61 Treatments are made
within the manufacturer's label restrictions. This
alternative can be used to meet certain silvicultural and
wildlife objectives, but is generally not applicable to
hazard reduction. In fact, the use of herbicides creates
more available fuels and increases wildfire risks.62
Four different techniques are used to apply herbicides:
aerial application (helicopter or fixed wing
aircraft);
mechanical equipment, using truck-mounted wand or
boon sprayer?
backpack equipment; and
hand application (injection, daubing, and ground
application of granular formulation).63
Herbicides have been effective for brushland
conversions, conifer thinnings, and conifer release
treatments. However, they have provided at best only
partial treatment of slash. Vegetation control is
temporary, usually less than 2 to 3 years and slash
concentrations are not reduced. Herbicides used in
combination with mechanical alternatives are more effective
in slash treatment and can reduce the soil disturbance and
other environmental effects associated with mechanical
techniques. Two to three periodic herbicide applications
are usually required after mechanical site preparation to
ensure the establishment of new conifer seedlings.64
9-34 September 1992
-------
Advantages of herbicide application is the ability to
target vegetation growth patterns (periods when the target
species are susceptible and the crop species is not), and
the low impact to soil surfaces. In addition, aerial
applications can be very cost-efficient, through treatment
of large acreage in a short time period.6S
Disadvantages of herbicide treatment include:
planting can be more expensive amid chemically
killed brush;
does not expose mineral soil necessary for natural
or artificial seeding;
herbicides may not be acceptable near sensitive
areas;
x-
. animals move about freely under sprayed brush where
they are protected from predators;
increased monitoring for drift and impact on water;
the possibility of a chemical spill; and
herbicides do little to control wildfire risk, they
do not reduce fuel loadings.66
Human health effects in conjunction with the application of
herbicides deal with the amount of exposure the workers have
in mixing and applying the herbicide and for the public in
the chance that they might be exposed during a herbicide
application. The amount of adverse health effect that
either of these two groups could experience would depend
upon the toxicity of herbicide, concentration, and length of
exposure. Generally, the human health risk is very low when
herbicides are properly used.67
Chemicals for site preparation and release have not
been an alternative that has been available for Federal
agencies since 1983 due to a District Court injunction.
This has lead to a much greater dependency on other
alternatives.68
9-35 September 1992
-------
9.5.1.4 Alternate Mechanical Treatment. Mechanical
techniques for treating slash and for brushland conversion
are technically feasible and versatile. These techniques do
not eliminate slash materials, but may sufficiently
rearrange and change the size and shape of the slash
components to satisfy forestry and environmental
considerations. Slash materials can be mechanically treated
by mastication (shredding), chipping, piling, scarification,
or burying.69
9.5.1.4.1 Mastication. On-site crushing or shredding
machines may be used to treat small diameter, concentrated
slash. These machines use slash pieces less than 6 inches
in diameter and produce a scattered layer of shredded
residue is left on the ground.70 The rate of decomposition
of this layer will depend on the climate zone - rapid in
warm, moist areas and very slow in cool, dry areas.71 This
level of treatment is generally considered to be sufficient
for silvicultural objectives, but may not significantly
reduce the wildfire hazard. The tractor support needed by
these devices restricts their use to terrain with slopes
less than 30 percent. Present applications have been
limited to small thinning slash and brushland conversion.
Application in heavy logging slash may be feasible in
conjunction with the utilization or piling of large
material.72
9.5.1.4.2 Chipping. On-site chipping may be used to
treat small concentrations of slash, whole trees, or in
conjunction with PUM (piling unmerchantable material) or YUM
(yarding unmerchantable material) operations. PUM and YUM
are techniques used to concentrate slash material into piles
or windrows. PUM is accomplished by tractor (wheeled dozer)
or hand. YUM is done using "high-lead" or other cable '
logging machinery on slopes inaccessible to tractors. Small
mobile or tractor-mounted chippers are adequate to treat
9-36 September 1992
-------
. <- <
small volumes of concentrated slash materials up to 6 inches
in diameter, but are limited to terrain of less than 30
percent slope. Larger materials require PUM or YUM support
operations in conjunction with larger timber or whole-tree-
type chippers that are limited to roadside or landing
operations. Present slash chipping operations are limited
to roadside treatments of thinning slash. However, on-site
chipping applications are expected to increase in
conjunction with increasing slash fiber utilization.73
9.5.1.4.3 Piling and scarification. YUM and PUM, as
described earlier, may be used to pile or windrow slash
without further treatment. Scarification techniques, the
exposure of mineral soil for regeneration planting, and
breaking continuity of slash fuels are used in conjunction
with PUM and YUM, but are again limited by terrain and soil
conditions. Sacrification techniques are used in
conjunction with piling or windrowing to better satisfy
silvicultural considerations.7*
9.5.1.4.4 Burying. On-site pits can accommodate most
piled or tractor-scarified materials. However, large slash
components and heavy material concentrations are difficult
to treat. Necessary tractor support limits this technique
to relatively flat rockless terrain.75 Burying can also be
used in conjunction with road construction for disposal of
right-of-way residues. (Debris is placed outside the road
prism but adjacent to the toe of the engineered fill.)76
Potential short- and "long-term environmental effects
may be of concern here. Burial sites may not support trees
until slash materials are decomposed and there are
indications that wood decay is inhibited under anaerobic
burial conditions. These anaerobic conditions may also
produce wood pollutants that may show in-ground water.
Under acid conditions, these may further degrade water
quality by dissociating heavy metals from the deep soil.77
9-37 September 1992
-------
9.5.1.4.5 Disking, plowingr harrowing. For treatment
of brush and rangeland residues, disk tillers can be used,
particularly for site conversion work. These machines can
cut brush and small trees up to 8 feet high, and have been
used extensively in the past for construction of brushland
fuel breaks as the residual vegetation is plowed back into
the soil.78
9.5.1.5 Air Curtain Destructor. An air curtain
destructor combusts forest residue in a pit (see Figure
9-3). It offers four advantages over open burning:
increased amounts of oxygen are added to the fire;
particulate matter and smoke are confined within the
pit;
particles are held in suspension in the incoming air
stream long enough for essentially complete
combustion; and
only a small land area is affected by heat
(important for later reforestation).79
Air curtain desctructors also have some potential
disadvantages, including:
limited practicality in steep terrain;
high handling cost of hauling materials to pit site;
and
limited availability of roads for hauling material
to site.80
Based on tests in 1971 and 1972 at four sites to
evaluate the efficiency and economy of an air curtain
destructor used for slash disposal, particulate emissions
were found to be "too low to measure." The report states,
however, that "low emission readings may be attributed
partly to the large quantities of dilution air blown into
the flume by the fan."81
Fuels burned in the four tests included eucalyptus,
orange, palm, pine, Douglas fir, cedar, hemlock, larch,
lodgepole, and other. Maximum burn rates ranged from
9-38 September 1992
-------
O
4J
O
4J
0]
0)
Q
J-l
3
O
tn
H
-------
7.5 tons of fuel per hour to 21 tons per hour. Overall, the
unburned residue in these tests was much less than 1 percent
of the fuel loaded into the pit.82
9.5.2 Reduction in Pre-Burn Fuel Loading
As noted in Section 9.3.2, there are a number of
techniques available to reduce pre-burn fuel loadings on
wildlands. These include burning outside of the active
growing season (live fuels); burning frequently (live and
small fuels); removal of the larger woody residue allows the
remaining, smaller residue to be more completely consumed by
the fires; and utilizing as much of the biomass (small and
large fuels) as possible. These techniques can be used to
some extent for all three major objectives. The following
paragraphs discuss the utilization of activity-generated
slash, which has its greatest impact- on hazard reduction and
site preparation.
In utilizing the logging residue (which is considered
unmerchantable material), it is frequently collected into
various piles of different size (or yarding) specifications.
The size specifications may range, for example, from «a
minimum of 4 feet by 4 inches up to whole tree. Use of YUM
includes firewood, chips for hog fuel, chipped for co-
generation plants, or debarked and chipped for clean
chips.83
Factors that affect the extent to which a unit is YUM
yarded are current market conditions and/or the land
managers objectives for the .amount of logging debris that
should be left to meet reforestation objectives. If the
objective is to reforest without burning, the specifications
would have to be set on the predicted amount of slash that
will accumulate on the unit. If a determination is made
that YUM yarding cannot be accomplished to the extent that
reforestation is possible, the objective could be to YUM
enough to reduce the amount of duff that might be consumed
when burning, thus reducing emissions. Past studies show
9-40 September 1992
-------
; ;*; ?
that woody fuel consumption averaged 24 percent less on
units yarded to 6 inches x 6 feet, and 44 percent less on
units yarded to 4 inches x 4 feet when compared to units
yarded to 8 inches x 10 feet.84
Increased utilization of logging residues has been
reported to be the primary reason for reduced emissions in
the Pacific Northwest in 1984. Utilization was cited the
primary reason for a 16-percent reduction in emissions in
Oregon and 20 percent in Washington since the baseline
period of 1976-1979. Sandberg notes that:
Preliminary results from current research seem to
confirm that 38 percent less large woody residue
(greater than 3-inch diameter) was left after
timber harvesting in 1984. Most of the increased
utilization removes the largest residue pieces, so
the remaining residue is smaller and more
completely consumed by fire. Consumption of large
woody residues is thought to have decreased by 25
percent, smaller residues (less than 3-inch
diameter) by 32 percent, and the duff layer
(organic soil) by 27 percent.
The area treated by prescribed fire has not
been decreasing in the Northwest. In fact, total
area burned in the two States in 1984 was higher
than any year in history. Burned area decreased
by 4 percent in western Oregon but increased by 12
percent in .Western Washington between the baseline
period (1976-1979) and 1984. The proportion of
fire use on private lands has increased greatly.85
Sandberg points out that the shift in fire use to
private lands has had the net effect of reducing emissions
by 7 percent in Oregon and 14 percent in Washington because
less slash is typically left after harvest on private land.
An average 29 percent less large woody residue per acre on
private land than on the national forests has been
measured .**
The advantages of intensive yarding would be to
decrease the amount of burning and increase the amount of
planting spots. In addition, depending on the chip market
or co-generation plants, a return could be made on the
biomass.87
9-41 September 1992
-------
Disadvantages to this type of system are the increased
landing 'sizes and road systems needed to support this
operation and the increased expense of yarding. In
addition, unstable chip prices make it difficult to predict
if the increased utilization could make it pay for itself.
The hog fuel and co-generation markets tend to be driven by
the price of other existing energy sources. Intensive
utilization on human health effects is basically increased
exposure of logging.1
38
9-5.3 Reduction in Fuel Consumption
Section 6.3.3 discusses the various methods available
to reduce fuel loadings for the various fuel components that
are typical to wildland burns. The two primary methods
discussed here are: (l) burn under conditions of increased
fuel moisture and (2) use of aerial ignition techniques.
Burning under conditions of increased fuel moisture is
applicable, in varying degrees, to all of the major
objectives of prescribed wildland objectives. With the
exception of disease control, aerial ignition should have a
high degree of applicability for all other resource
management objectives. The following paragraphs discuss
briefly 'the emission reductions that might be expected for
the application of these two primary techniques for reducing
fuel consumption.
9-5-3.1 Increased Fuel Moisture. In most cases, it is
the intent of the land manager to eliminate fine fuels to
create an adequate number of seedling spots. There is
little value in reducing the amount of larger fuels (greater
than 3 inches in diameter) on the site. Successful burns,
in these areas, eliminate lighter fuels, but do not burn the
larger logs or the duff layer of twigs, needles, and leaves
found on the forest floor. As a result, burning under
increased fuel moisture reduces the amount of fuel consumed
and, therefore, emissions.89
9-42 September 1992
-------
Burning under increased fuel moisture conditions in the
Pacific Northwest have been reported to reduce emissions by
about 30 percent.90 In 'a series of 40 clearcut units
located in the Pacific Northwest, seven trials were
conducted to determine the effect if burning under wet,
spring-like conditions on large fuel and duff consumption.
These tests showed that consumption of large fuel residue
averaged 57 percent less on the wet units and duff
consumption 63 percent less. Overall, emissions were
reduced by an average of 54 percent.
91
9.5.3.2 Aerial Ignition. Use of helitorch (or aerial)
ignition can help minimize emissions by as much as 20
x»-
percent if a mass fire situation is achieved with an overall
reduction in fuel consumption.92' 93
Current aerial ignition techniques can be separated
into two major types: the PAID (Delayed Aerial Ignition
Device) or ping-pong ball system, and the helitorch. The
ping-pong ball system utilizes small plastic spheres
containing potassium permanganate. The balls are injected
with ethylene glycol and immediately thrown out before the
chemicals react thermally to produce a flame that consumes
the ball. The dispensing machine can be mounted in small
airplanes or helicopters. The ping-pong ball system works
best in continuous fuels or in areas where a mosaic burn
pattern is desired.94
The helitorch is a special aerial firing device,
resembling a large drip-torch, suspended by cable under a
helicopter. It dispenses a jellied gas for'fuel ignition
and is used to ignite forest brush or rangeland fuels on
steep, difficult terrain. It has also been used for
backfiring on wildfires and for prescribed burning in slash
and brushland site conversion. The helitorch has excellent
ignition capabilities where fast and extensive prescribed
fire coverage is needed, or where controlled fire is desired
to create large mosaic patterns. In many situations, the
9-43 September 1992
-------
prescribed fire manager can rely upon humidity recovery in
the afternoon or early evening to check the speed of the
burn.
Both types of aerial ignition dramatically reduce the
time needed for an area to burn out. Although roughly the
same amount of smoke is produced, it is emitted over a
shorter period and more of it is entrained in the convection
column. Thus, the impact of any adverse air quality effects
is much reduced.95
The following are factors associated with general
aerial ignition, DAID, and helitorch.
General Aerial Ignition96
rapid firing and burnout al-lows use of a much
smaller prescription window (times that are right
for burning);
requires an experienced burning boss to make
ignition grid adjustments and to determine when to
halt ignition due to conditions;
large acreage can be safely burned in a single
burning period;
many widely dispersed tracts can be burned during a
single day; and
a contingency plan is essential in the event the
aircraft is reassigned or equipment breaks down
during operation.
The PAID System97
best suited for continuous fuels or where a mosaic
pattern is desired; and
ignition spacing within and-between flight lines can
be easily adjusted.
The Helitorch System98
not as safe as the DAID system, but less expensive;
if the torch and fuel tanks are slung under rather
than attached to the helicopter, a larger crew will
be required;
creates disposal problems;
9-44 September 1992
-------
very difficult to regulate spacing within a flight
line;
fuel-mixing viscosity is sometimes inconsistent due
to temperature changes which, in turn, further
aggravate in-line spacing of ignition spots; and
the most efficient firing technique for large,
cleared areas with discontinuous fuels, including
piled or windrowed debris.
9.5.4 Methods to Lower the Applicable Emission Factor
There are several factors that the burner can
manipulate that have a direct effect on the overall
applicable emission factor. These are: (l) placement of
residue to be burned (i.e., broadcast, windrowed, piled);
(2) firing technique; and (3) residual mop-up. Each of
these factors affect overall emissions by changing the
relative amount of emissions generated during the "cleaner"
flaming phase versus the "dirtier" smoldering phase. These
factors are discussed below.
9.5.4.1 Placement ofResidue. It is generally
recognized that burning of slash placed in piles has a lower
emission rate than the same amount of slash burned either
broadcast or windrowed.
The slash needs to be piled correctly in order to
realize greatest benefit (i.e., lowest emission rate). If
the piling of slash is not done properly, a considerable
amount of soil can be left in the pile. If this occurs,
there will be an increase in emissions. Also, the large
volumes of fuel in the pile will occasionally contain a lot
of moisture. This, coupled with a lack of oxygen for good
combustion, is responsible for a high percentage of all
smoke incidents." Consequently, correct piling techniques
should include the following.
keep piles small and minimize the amount of soil in
them so surface water can pan through, and the
debris can dry quickly;
9-45 September 1992
-------
always pile when the ground surface is dry (less
soil compaction will take place, and considerably
less soil will end up in the piles);
allow fresh logging debris to cure first and to dry
after rain, then "shake" the debris while piling to
remove as much soil as possible;
if material is piled while green or wet, the centers
of the piles take an exceedingly long time to dry;
piles that contain little soil and are constructed
to allow some air movement will result in a burn
that consumes significantly more of the debris and
produces less smoke; and
more efficient burning and greater heat output will
lift smoke higher, reducing smoke concentrations
near the ground."
Techniques used in burning piled debris are somewhat
fixed because of the character and placement of fuel.
Traditionally, each pile is ignited along its perimeter, but
burnout can be speeded up considerably by igniting the pile
center. A helitorch is often used because burning globs of
gelled gasoline penetrate deep into piled fuels and provide
a "large" heat source. Tractor-mounted ignition devices
that help burning fuel penetrate down toward the center of a
pile have also been built and are being tested.100
9.5.4.2 Firing Techniques. Various firing techniques
can be used to accomplish a burn objective. The techniques
chosen must be correlated closely with burning objectives,
fuels, topography, and weather factors to prevent damage to
forest resources. The proper technique to use can change as
these factors change.101
Based on behavior and spread, fires either move with
the wind (heading fire), against the wind (backing fire), or
at right angles to the wind (flanking fire). The movement
of any fire can be described by these terms. For example, a
spot fire would exhibit all three'types (spot fires will be
discussed in detail later). Heading fire is' the most
intense because of its faster spread rate, wider flaming
9-46 September 1992
-------
li a .t
zone, and longer flames. Backing fire is the least intense,
having a slow spread rate regardless of windspeed. This
type of fire has a narrow flaming zone, and short flames.
Flanking-fire intensity is intermediate. The slope of the
land has an effect on rate of spread similar to that of
wind.102 Each of these fire types is used by the prescribed
fire manager to keep smoke to a minimum.
9.5.4.2.1 Backing fire.103 A backing fire, which
generally consumes more forest floor fuels than a heading
fire, is started along a baseline (anchor point) such as a
road, plow line, stream or other barrier, and -allowed to
back into the wind or downhill. Variations in windspeed
would have little effect on the rate of spread. Backing
fire is the easiest and safest type of prescribed fire to
use, provided windspeed and direction are steady. It
produces minimum scorch in the forest and lends itself to
use in heavy fuels and young pine stands. Major
disadvantages in forest management are the slow progress of
the fire and the increased potential for feeder-root damage
with increased exposure to heat if the lower litter is not
moist enough. When a large area is to be burned, it often
must be divided into smaller blocks with interior plow lines
and all blocks must be ignited at about the same time to
complete the burn in a timely manner. These conditions
dissipate the smoke and prevent heat from rising directly
into tree crowns. (It has been found that smoke temperature
returns to ambient levels at relatively small distances from
the flames thus preventing damage to tree crowns.)
When the relative humidity is low, a steady wind is
blowing, and fuels are continuous, an excellent burn can be
anticipated once the fire backs away from the downwind
control line. Under such conditions, however, extra care
must be taken to make sure the initial fire doesn't spot
across the line (slopover). The following is a list of
factors to be considered about backing fires.
9-47 . September 1992
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must be ignited along the downwind control line;
use in heavy roughs;
use in young forest stands;
normally results in little scorch of trees;
costs are relatively high because of additional
interior plow lines and extended burning period
resulting from slower movement of the fire;
not flexible to changes in wind direction once
interior lines are plowed;
requires steady in-stand winds;
requires good fuel continuity to carry well; and
a single torch person can progressively ignite
lines.
9.5.4.2.2 Strip-headfiring.104 in strip-headfiring, a
series of lines of fire are set progressively upwind of a
fuel break in such a manner that no individual line of fire
can develop to a high energy level before it reaches either
a firebreak or another line of fire. A backing fire is
generally used to secure the base line and the remainder of
the area is then treated with strip-heading fires. Strips
are typically set 1 to 3 chains apart (66 to 198 feet).
This distance can be varied within a fire to adjust for
slight changes in topography; stand density; weather; or the
type, amount, or distribution of fuel. Compensation for
minor wind direction changes can be made by altering the
angle of strip fire with the base line. An effective method
of reducing fire intensity is to use a series of spots or
short l-to-2-foot-long strips instead of a solid line of
fire. An added advantage of these short strips or spots is
that driptorches will not have to be filled as often.
Strip-heading fires permit quick ignition and burnout, and
provide for smoke dispersal under optimum conditions.
However, higher intensities will occur wherever lines of
9-48 September 1992
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fire burn together, increasing the likelihood of crown
scorch.
Occasionally, on areas with light and even fuel
distribution, a heading fire may be allowed to move over the
entire area without stripping to better accomplish the '
objective(s). This method reduces the number of areas of
increased fire intensity that occur each time two fires burn
together. Factors associated with strip-heading fires are
as follows:
secure the downwind base line before igniting a
heading fire;
do not use in heavy roughs;
winter use is best; x~
use in medium-to-large sawtimber;
can be used in "flat" fuels such as hardwood leaves;
is a good method for brownspot control in pine'
forests;
because fire movement is fast, large blocks can be
burned;
can be used with high relative humidity and high
actual fine-fuel moisture;
needs just enough wind to give the fire direction;
cost is lower than other line-firing techniques
because fire progress is rapid and few plow lines
are required;
the technique can accommodate wind shifts up to
about 45 degrees;
flame length increase whenever heading fire
converges with a backing fire, thereby increasing
the possibility of crown scorch; and
a single torch person can progressively ignite
strips.
9.5.4.2.3 Flanking fire.105 The flanking-fire
technique consists of treating an area with lines of fire
9-49 September 1992
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set directly into the wind. The lines spread at right
angles to the wind. This technique requires considerable
knowledge of fire behavior, particularly if used by itself.
It is used quite often to secure the flanks of a strip-
heading fire or backing fire as it progresses. " It is
sometimes used to supplement a backing fire in areas of
light fuel or under more humid weather conditions and is
useful on a small area or to facilitate burning a large area
in a relatively short time when a line-heading fire would be
too intense.
This method of firing can stand little variation in
wind direction and requires expert crew coordination and
timing. For safety, all lines of flank fire should be
ignited simultaneously and all torch people should keep
abreast of one another. If only one or two torch people are
available, this technique is usually altered to set the
ignition lines 45 degrees into the wind. Factors associated
with flanking fires:
always secure downwind base line first;
fuel loading should be light to medium - less than 8
tons per acre;
wind direction must be steady;
best used in medium-to-large sawtimber;
allows fast area ignition;
needs few control lines;
in areas with a high understory, multiple torch
people are needed and coordination is very
important; and
useful in securing flanks of other fire types.
9.5.4.2.4 Point source firing.106 When properly
executed, a grid of spot ignitions will produce a fire with
an intensity much greater than that of a line-backing fire,
but somewhat less than that of a line-heading fire. Timing
9-50 September 1992
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and spacing of the individual ignition spots are the keys to
the successful application of this method.
Factors associated with point source fires are as
follows:
assume much of the area will be burned by heading
and flanking fires and very little by backing fires;
if conditions are ideal for traditional line-backing
fires, point source fires may be too intense;
preferred burning conditions include low in-stand
windspeeds, wind directions can be variable;
when underburning, start with square grid ignition;
always secure the downwind base line first;
severe crown scorch of trees is likely if fuel is
too dry;
the usual changes in weather during a typical winter
day may require modification of ignition patterns
throughout the day; and
costs are low because firing is rapid and no
interior control lines need to be constructed.
9.5.4.2.5 Center and circular fringl firing.107 The
technique of center and circular (ring) firing is useful on
cut-over areas where a hot fire is needed to reduce or
eliminate logging debris prior to seeding or planting. It
works best when winds, if any, are light and variable. This
procedure should never be used for understory burning
because of the likelihood of severe tree damage as the flame
fronts merge.
As with other burning techniques, the downwind control
line is the first line to be ignited. Once the base line is
secured, the entire perimeter of the area is ignited and the
flame fronts allowed to converge but one or more spot fires
are often ignited near the center of the area and allowed to
develop before the perimeter of the block is ignited. The
connection generated by these interior fires creates .
indrafts that help pull the outer circle of fire toward the
9-51 September 1992
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center. This firing method can generally be used in any
season, and weather conditions are not as critical.
However, caution is in order, particularly when the
atmosphere is unstable. This type of fire tends to develop
a strong convection column, which can cause spotting or
slopover a considerable distance downwind.
9.5.4.3 Residual Mop-Up. As noted earlier, the
emission factor for a prescribed wildland burn is a
composite factor made up of the emissions that occur during
the flaming phase and those that occur during the smoldering
phase. Rapid mop-up of residual smoke following the flaming
phase can significantly reduce emissions from the smoldering
phase. Standard techniques (water trucks and hand labor)
can be augmented by using aerial tankers and chemical
retardants on large burn blocks. In addition, pretreatment
removal of larger slash materials, which typically prolong
the burn and are difficult to snuff out, will significantly
enhance the efficiency of mop-up activities.108
Emissions from the smoldering phase of the fire has
been estimated to be about 40 percent of the total
emissions. Under typical conditions, mop-up within 8 hours
reduces overall emissions by about 10 percent.109
'9.6 INCORPORATION OF EMISSION REDUCTION TECHNIQUES IN
STATE LAWS, SMOKE MANAGEMENT GUIDELINES, AND
MEMORANDA OF UNDERSTANDING
Many of the emission reduction techniques discussed
above have already been incorporated by the States into
their State laws, smoke management guidelines, and memoranda
of understanding. Whether these emission reduction
techniques are used by the burners depends, in part, on
whether the techniques are part of an enforceable tool
(e.g., legislation) or part of a voluntary smoke management
program.
The purpose of this section is two-fold. One purpose
is to illustrate the methods used to convey the requirement
9-52 September 1992
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..
to use techniques that reduce emissions from prescribed
burns. The second purpose is to identify emission reduction
techniques that the States have adopted so far. It is not
the intent of this section to identify what represents "best
available" emission reduction techniques for any group of
burns. Indeed, as pointed out in Colorado's smoke
management plan (see 9.6.3), each burn is unique, such that
each burn needs to be evaluated on an individual basis to
determine which emission reduction techniques constitute the
"best available" ones for that burn.110
9.6.1 Alabama111
Alabama's "Smoke Management Guidelines for Forestry"
identifies a long list of "Rules of Thumb" that, if
followed, will decrease the amount of smoke produced,
increase smoke dispersion, and reduce any possible adverse
effects from the smoke. Those that deal with decreasing the
amount of smoke include:
minimize amount of logging debris by increased
utilization;
favor small piles over windrows;
pile debris when dry and shake out dirt;
burn debris when dry;
take steps to keep stumps and snags from burning;
check moisture of fine fuel and lower litter,by
feeling;
burn when.fine fuel moisture is low;
favor backing fires; and
« mop-up for residual smoke as well as control of
fire.
In the case of smoke-sensitive areas, the guidelines note
that mop-up becomes even more important and that residual
smoke can be reduced by putting out stumps and snags and
9-53 September 1992
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that heavy fuel concentrations (e.g., tops) can be scattered
so the fire will burn out instead of smoldering overnight.
9.6.2 California
California Agricultural Burning Guidelines identify
specific requirements for the burning of several types of
agricultural crops in the Sacramento Valley Air Basin and
portions of Place County (of the Mountain Counties Air
Basin). These requirements are as follows:
(1) Require all rice harvesting to employ a
mechanical straw spreader to ensure even
distribution of the straw with the following
exception:
(A) Rice straw may bexleft in rows provided it
meets drying time criteria prior to a burn
as described in subdivision (d)(2) below.
(2) Require that after harvest:
(A) No spread rice straw shall be burned prior
to a 3-day drying period.
(B) No rowed rice straw shall be burned prior
to a 10-day drying period.
(C) Subdivisions (d)(2)(A) and (d)(2)(B) above
do not apply if the rice straw makes an
audible crackle when t.ested just prior to
burning with the testing method described
in subdivision (d)(2)(D) of these
provisions.
(D) When checking the field for moisture, a
composite sample of straw from under the
mat, in the center of the mat and from
different areas of the field shall be taken
to insure a representative sample. A
handful of straw from each area will give a
good indication. Rice straw is dry enough
to burn if a handful of straw selected as
described above crackles when it is bent
sharply.
(E) After a rain exceeding 0.15 inch (fifteen
hundredths of an inch), notwithstanding
subdivisions (d)(2)(A) and (B) above, rice
straw shall not be burned unless the straw
makes an audible crackle when tested just
9-54 September 1992
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prior to burning "with the testing method
described in subdivision (d)(2)(.D), above.
(3) Require rice, barley, oat and wheat straw to be
ignited only by stripfiring into-the-wind or by
backfiring except under a special permit of the
district issued when and where extreme fire
hazards are declared by a public fire protection
agency to exist, or where crops are determined
not to lend themselves to these, techniques.
(4) Require burning hours to be set so that no field
crop burning shall commence before 10:00 a.m. nor
after 5:00 p.m. of any day.112
California also specifies certain requirements for
rangeland improvement burns, forest management burning, and
wildland vegetation management burning. For rangeland
\>-
improvement burns, these requirements include:
igniting the burns as rapidly as practicable within
fire control restrictions;
treat brush (mechanically or chemically) at least
6 months prior to burn if economically and
technically feasible; and
unwanted trees over 6 inches in diameter are to be
felled and dried prior to the burn.1"
For forest management burns, these requirements
include:
igniting the burn as rapidly as practicable within
fire control restrictions;
the waste is to be dried for minimum periods (to be
specified by the designated agency);
the waste is to be free of tires, rubbish, tar
paper, and construction debris;
the waste to be burned is to be windrowed or piled,
where possible, unless good silvicultural practice
dictates otherwise;
the piled waste is to be prepared so that it will
burn with a minimum of smoke; and
the piled waste is to be reasonably free of dirt and
soil.1"
For wildland vegetation management burns, these
requirements include:
9-55 September 1992
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the vegetation to be burned is to be free of tires,
rubbish, tar paper, or construction debris, and
reasonably free of dirt and soil; and
the vegetation is to be in a condition that
facilitates combustion and minimizes the amount of
smoke entitled during combustion.115
9.6.3 Colorado116
Colorado's smoke management plan explicitly states that
"each land management agency signatory shall apply the best
smoke management techniques." The plan goes on to point out
that "no two fires are alike in terms of smoke emissions and
impacts" and, therefore, no "two fires are alike in smoke
management options available." Itxis incumbent on the land
manager to select the appropriate smoke management
techniques on a case-by-case basis. Colorado's smoke
management plan requires that piled material be "reasonably
dry and free of dirt" and allows use of auxiliary fuels if
needed to induce proper ignition.
9.6.4 Florida
In Florida, general open burning is allowed if, in
part, the moisture content and composition of material to be
burned is favorable to good burning which will minimize air
pollution. Green or wet materials may not be burned.117
While no emission reduction techniques are mentioned in
51-2.06 for agricultural and silvicultural burning, burning
in sensitive areas may be authorized under three conditions,
one of which is an air curtain pit burner is used.118
9.6.5 Montana119
Major open burning sources in Montana must utilize best
available control technology (BACT), which is defined, in
part, as:
"...those techniques and methods of controlling
emission of pollutants from an existing or
proposed open burning source which limit those
emissions to the maximum degree which the
9-56 September 1992
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department determines, on a case-by-case basis, is
achievable for that source, taking into account
impacts on energy use, the environment, and the
economy, and any other costs, including costs to
the source."
The definition of BACT identifies "techniques and
methods" to include the following:
scheduling of burning during periods and seasons of
good ventilation, applying dispersion forecasts;
utilizing predictive modeling results performed by
and available from the department to minimize smoke
impacts;
limiting the amount of burning to be performed
during any one period of time, using ignition and
burning techniques which minimize smoke production;
X"
selecting fuel preparation methods that will
minimize dirt and moisture content;
promoting fuel configurations which create an
adequate air to fuel ratio;
prioritizing burns as to air quality impact and
assigning control techniques accordingly; and
promoting alternative treatments and uses of
materials to be burned.
9.6.6 New Jersey120
New Jersey's smoke management plan provides guidelines
to be used in conjunction with fire weather forecasts during
prescribed burning operations. In this plan are several
"acceptable burning criteria", including:
utilization of back and flank fires rather than head
fire;
fuels should be reasonably dry (approximately 1 to 4
days after a 1/4 inch of rain); and
reduce residual smoke by mopping up stumps and snags
quickly.
9-57 September 1992
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9.6.7 Oregon
In Oregon, the rules for open burning of all perennial
and annual grass seed and cereal grain crops or associated
residue within the Willamette .Valley, state that:
Each responsible person open field burning shall make
every reasonable effort to expedite and promote
efficient burning and prevent excessive emissions of
smoke by:
(a) Ensuring that field residues are evenly
distributed and in generally good burning
condition;
(b) Utilizing ignition devices, fire control
equipment and water supplies which meet the
requirements of the State Fire Marshall...; and
(c) Employing rapid ignition techniques on all
acreage where there are no imminent fire hazards
or public safety concerns.121
Propane flaming, mobile field sanitizers, and stack
burning are acceptable alternatives to the open burning of
fields if they are used under certain conditions. For
example, for propane flaming and mobile field sanitizers,
the field must have previously been open burned and the
appropriate fees paid; or the remaining field stubble must
be flail-chopped, mowed, or otherwise cut close to the
ground and the loose straw removed to the extent
practicable.122
In addition, when using propane flaming, every effort
shall be made to conduct propane flaming in a manner which
minimizes smoke emissions. Finally, the presence of any
regrowth in the field between 6 and 12 inches in height
shall be mowed or cut close to the ground and removed
providing mechanical removal of the resultant fields residue
is practicable. Any regrowth exceeding 12 inches in height
shall be mowed or cut close to the ground and removed.123
Requirements for stack burning include: all residue to
be burned must be dry to the extent practicable and free of
all other combustible and noncombustible material. Covering
9-58 September 1992
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the stacks is advised when,necessary and practicable to
protect the material from moisture.124
If preparatory burning is used, it must be conducted
using a backfiring technique.125
For forestry burns in Oregon, the Operational Guidance
for the Oregon Smoke Management Program provides the
following guidance for reduction emissions:
3. Reduction of Emissions. The Department of Forestry
will encourage private forest landowners to burn
only those units that must be burned to achieve the
landowners' objectives. Forest Practices Foresters,
through the administration of the Forest Practices
Act, will encourage utilization of residue, fuel
reduction measures, and alternate treatment
practices that are consistent with the purposes of
the Forest Practices Act. xThe Department of
Forestry supports efforts to reduce prescribed
burning emissions and will strive to achieve
emissions reduction goals established within the
Oregon Visibility Protection Plan.
Burning during time periods when 1000-hours and
larger fuels (3 inches in diameter of larger fuels)
have relatively high fuel moisture, such as during
spring, will be promoted where such burning is
within the prescription necessary to achieve the
objectives of the landowner.
Mass ignition methods will be encouraged to help
reduce emissions where such techniques are
economical and practical.
To minimize impacts from residual smoke, mop-up will
be initiated on all units consistent with
atmospheric and wind conditions. Within this
context, during periods of observed or forecast low-
level transport toward the designated areas, mop-up
shall begin immediately.126
9.6.8
In Utah, the memorandum of understanding (MOU) between
the Utah Air Conservation Committee, the BLM, and the U.S.
Forest Service addresses techniques to be used by the BLM
and the U.S. Forest Service in conducting their prescribed
fires. Specifically, the MOU states that the BLM and Forest
Service agree to:
9-59 September 1992
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b. Conduct prescribed burning in accordance with
. appropriate technology which may include the
techniques and guidelines outlined in the
Prescribed Fire Smoke Management Guide
(Interagency) NFES 1279 and to manage smoke
emissions to meet the requirements of Utah's
State Implementation Plan. Appropriate smoke
emission management techniques to minimize the
visibility impacts on mandatory Class I areas
could include:
(1) Area avoidance strategy.
(2) Smoke dilution strategy.
(3) Smoke emission-reduction procedures, such as:
(a) Smoldering phase mop-up.
\*-
(b) Enhance flaming combustion.
(c) Increased fuel utilization (firewood).
(d) Optimum fuel moisture.
(4) Peak visitor or user avoidance strategy.
9.6.9 Virginia128
In their "Voluntary Smoke Management Plan for Forestry
Prescribed Burning Operations," the State of Virginia makes
11 recommendations to reduce smoke impact from all forestry
burns. Those that are pertinent to reducing the amount of
emissions generated include:
use of backing fires when possible;
minimize residual smoke caused by fuels that may
smolder for hours or days after the burn by
extinguishing the fire as soon as it burns down
enough to be practical; and
» use of aerial ignition (more complete combustion is
accomplished with a more intense burn).
9.6.10 Washington129
Washington's smoke management program requires the
application of several air quality firing considerations
during all slash burning operations. These considerations
9-60 September 1992
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pertain to time of ignition, condition of slash, and rate of
burning. The primary purpose of these considerations is to
facilitate smoke dispersion. The condition of the slash
affects the amount of smoke generated. Under this
consideration, burning of cured material is favored because,
in part, "cured material produces less smoke per unit volume
of slash than green material." Burning cured material also
allows taller convective columns to develop because of the
higher heat energy released and more effectively burns
medium and large sized fuels (thereby smoke effectively
lowering fire hazard).
9.7 EFFECTIVE IMPLEMENTATION STRATEGY
States should encourage alternatives to burning when
resource management objectives can still be met. For
agricultural burning, this means encouraging utilization of
crop/straw residues, alternative crops, and alternative
burning techniques that result in less particulate emissions
than open field burning. The viability and acceptance by
the growers of these alternatives will vary depending upon
geographic location, type of crop, and market opportunities.
For wildland burning, this means primarily encouraging
the utilization of slash, which will depend on the
availability of markets for the slash. In addition, air
curtain destructors should be encouraged, where feasible, as
these devices allow for potentially substantial reduction in
emissions.
A State may find that it is necessary to set acreage
limitations on the amount of burning that can occur in order
to meet the NAAQS for PM-10. Several States already limit
the amount of burning (e.g., Oregon sets the maximum acreage
that can be burned in the Willamette Valley at 250,000 acres
per year).
States may implement a fee structure [e.g., the use of
registration fees ($/acre burned) or emission fees ($/tons
emitted)] to encourage alternatives to burning and the use
9-61 September 1992
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of emission reduction techniques. A State may either use
their general permit fee system or supplement it with a fee
program specific to prescribed burning. In addition, the
State may implement a fee structure sensitive to the
objectives of the burn and the availability of technically
feasible alternatives to burning.
The State should require each burn in a rionattainment
area and those burns in extended areas to use the most
effective available emission reduction techniques for
reducing emissions from that burn.
The State should identify those emission reduction
techniques that should be used for each type of burn
conducted in the nonattainment area or in the extended area
v-
impacting the nonattainment area. Since a State may
currently lack the expertise, the State should coordinate an
effort among all knowledgeable parties to identify these
techniques.
Selecting the emission reduction techniques should be
based on the consideration of the following factors that
affect emissions:
a. fuel load reductions;
b. burning only those fuels that need to be
burned to meet the resource objectives;
c. shifts in biomass consumption from the
smoldering phase to the flaming phase; and
d. residual smoke reduction (e.g., through mop-
up).
The particular set of emission reduction techniques
that are effective for prescribed burns will vary from burn
to burn. As presented earlier in this chapter, Table 9-2
outlines various emission reduction techniques that should
be considered by the State as potential best emission
reduction techniques for wildland burns. Table 9-2 also
shows the relative applicability of each technique to the
major objectives of forestry burns. It is important to
remember that the applicability of any one technique can
9-62 September 1992
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vary from site-to-site, and the resulting emission reduction
will vary. Therefore, it is important for the State to
obtain as much information about each burn to estimate
expected emission reductions, and to evaluate whether
appropriate emission reduction techniques are being used.
Most of the emission reduction techniques discussed for
agricultural burns are generally more applicable across the
various types of crops then may be the case for wildland
burns as the range of objectives of agricultural burns is
narrower (i.e., either residue removal alone or residue
removal with accompanying sanitation of the field). As for
wildland burns, the effectiveness of the techniques will
vary from burn to burn. -
The State should implement procedures that would allow
a burner to demonstrate that a new burning procedure is an
effective emission reduction technique.
In conjunction with emission reduction techniques, a
State may elect to restrict the time of year when burning
can be conducted or prohibit certain types of burns during
historical seasons of nonattainment. A State may also
consider techniques that improve dispersion. In other
words, dispersion techniques that effectively reduce the
impact of PM-10 emissions (as do techniques that actually
reduce the amount of PM-10 emitted) can also be considered
by the State in identifying emission reduction techniques.
9-63 September 1992
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-------
9.8 REFERENCES
1. Smoke Management Guide. Produced by: Prescribed Fire
and Fire Effects Working Team. February 1985. pp. 5,
6.
2. Reference 1, p.6.
3. David V. Sandberg. USDA Forest Service. Emission
Reduction for Prescribed Forest Burning. In: C.V.
Mathai, D.H. Stonefield, eds. TransactionPM-10:
Implementation of Standards: An APCA/EPA International
Specialty Conference. San Francisco. February 22-25,
1988. p. 632.
4. Reference 3, p. 634.
5. Reference 3, p. 633.
x^
6. Reference 3, pp. 633, 634.
7. George E. Miller. Jr., and John R. Goss. Study of
Abatement Methods and Meteorological Conditions for
Optimum Dispersion of Particulates from Field Burning
of Rice Straw. Rice Straw Incinerator Evaluation.
California Air Resources Board Project No. 1-102-1.
1973. 37 pp.
8. Agricultural Residue Management: A Focus on Rice
Straw. A Report of the Residue Management Task Force,
University of California. 1981. 164 pp.
9. Oregon State University Extension Service. Burning
Grass Seed Fields in Oregon7s Willamette Valley; The
Search for Solutions. Extension Miscellaneous 8397.
Reprinted February 1989. p. 18.
10. Oregon Department of Environmental Quality, Air Quality
Division. 1979 Annual Report to the Legislative
Committee Economic Development. Volume 16. January
1980. 67 pp.
11. Telephone communication. Chuck Craig. Oregon
Department of Agriculture, with Ken Meardon. Pacific
Environmental Services, Inc. June 24, 1991.
12. Reference 9, pp. 18, 19.
13. Reference 9, p. 2., .
14. Reference 9, p. 18.
15. Reference 9, p. 2.
9-64 September 1992
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16. Reference 9, p. 19.
17. Oregon Department of Agriculture. 1990 Annual Field
Burning Report, p. 25.
18. Reference 17, p. 23.
19. Reference 17, p. 25.
20. Reference 9, p.21.
21. D.O. Chilcote and H.W. Youngberg. Non-burning
Techniques of Grass Seed Residue Removal. Agricultural
Experiment Station, Oregon State University, Progress
Report EXT/ACS 9. 1975. 8 pp.
22. Reference 8.
23. Personal communication. Chuck^Craig, Oregon Department
of Agriculture, with Ken Meardon, Pacific Environmental
Service, Inc., June 24, 1991.
24. Advisory Committee on Environmental Science and
Technology. "Solid Wastes Management." Reprinted in
Environmental Quality in Oregon 1971; A Summary of
Current and Future Problems. 1971 4 pp.
25. Reference 9, pp. 20, 21.
«
26. Reference 17, p. 26.
27. Reference 23.
28. M.T. McAdams, K.R. Meardon, and D.P. Kent. Pacific
Environmental Service, Inc. Assessment for Future
Environmental Problems - Agricultural Residues.
Prepared for: U.S. Environmental Protection Agency,
Office of Research and Development. 1983. pp. 67, 68.
29. Reference 28, pp. 64, 65.
30. Reference 10.
31. Reference 10.
32. Reference 9, p. 4.
33. Reference 10.
34. Reference 9, p. 43.
o
35. Reference 10.
36. Reference 9, p. 19.
9-65 September 1992
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37. Reference 9, p. 20.
38. Reference 9, p. 20..
39. Reference 9, p. 19.
40. Reference 9, pp. 4, 5.
41. Reference 9, p. 5.
42. Reference 23.
43. Reference 9, p. 5.
44. Brian C. Horsefield, Clarence Becker, and Bryan M.
Jenkins. Agricultural Residues as an Alternative
Source of Energy for the Pacific Gas and Electric
Company. Department of Agricultural Engineering
Research Report, University of. California, Davis,
California. 1977. 293 pp.
45. G.E. Sloane and L.J. Rhoades. A Comparison of the
Processing of Burned and Unburned Sugarcane.
Experiment Station, Hawaiian Sugar Planter's
Association. Hawaiian Planter's Record. Volume 58, No.
14. 1972. 10 pp.
46. Norman Rozeff and H.R. Crawford, Jr. Green Cane vs.
Burned Cane Harvest Comparisonsr 1978-79. In
Proceedings XVII Congress, International Society of
Sugarcane Technologists. Volume I. Manila,
Philippines. 1980. pp. 916-931.
47. Darrell L. Roberts. Status of the Development of a
Whole Cane Cleaner. Louisiana Agricultural Experiment
Station. 1972. 3 pp.
48. Reference 45.
49. Reference 46.
50. Reference 47.
51. John J. Carroll, G.E. Miller, and J.F. Thompson. "The
Dependence of Open Field Burning Emissions and Plume
Concentrations on Meteorology, Field Conditions, and
Ignition Technique," Atmospheric Environment, Vol. 11,
1977. p. 1039.
52. Oregon Department of Environmental Quality. 1980
Annual Report on Field Burning. Presented to the Joint
Legislative Committee on Trade and Economic
Development. 8 pp.
9-66 September 1992
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53. Reference 51, p. 1039.
54. George E. Miller et al. "A Program to Minimize the
Effects of Agricultural Burning in California."
Submitted to Journal of the Air Pollution Control
Association. March 1976. 26 pp.
55. Reference 28, p. 61.
56. Reference 51, p. 1039.
57. Oregon Department of Forestry. A Report on Prescribed
Burning in Oregon. 1990. Prepared for the Joint,
Interim Environment, Energy and Hazardous.Material
Committee of the Oregon Legislature. pp. 34, 35.
58. U.S. Environmental Protection Agency, Region 10.
Impact of Forestry Burning Upon Air Quality: A State-
of-the-Knowledcre Characterization in Washington and
Oregon. EPA 910/9-78-052. pp. 142, 143.
59. Reference 57, p. 35.
60. Reference 57, p. 34.
61. Reference 57, p. 33.
62. Personal communication. Bill Leenhouts, U.S. Fish and
Wildlife Service, to Ken Meardon, Pacific Environmental
Services, Inc. 1991.
63. Reference 57, p. 33.
64. Reference 58,. pp. 128, 132.
65. Reference 57, p. 33.
66. Reference 57, p. 33.
67. Reference 57, p. 33.
68. Reference 57, p. 33.
69. Reference 58, p. 123.
70. Reference 58, p. 123.
71. U.S. Forest Service. National Forest Landscape
Management. Volume 2, Chapter 6 r Fire. Agriculture
Handbook No. 608. April 1985. p. 49.
72. Reference 58, p. 123.
73. Reference 58, pp. 123, 124.
9-67 September 1992
-------
74. Reference 58, p. 124.
75. Reference 58, p. 125.
76. Reference 71, p. 48. .
77. Reference 58, pp. 125, 126.
78. Reference 71, p. 49.
79. Michael Lambert, U.S. Forest Service. Efficiency and
Economy of an Air Curtain Destructor Used for Slash
Disposal in the Northwest. Paper No. 72-672 for
Presentation at 1972 Winter Meeting, American Society
of Agricultural Engineers, Chicago, Illinois. December
11-15, 1972. p. 1.
80. Telephone communication. Larry Mahaffey, Boise
Interagency Fire Center, with-Chris Stoneman, U.S.
Environmental Protection Agency. August 20, 1992.
81. Reference 79, p. 12.
82. Reference 79, pp. 5, 11, 17.
83. Reference 57, pp. 31, 32.
84. Reference 57, p. 32.
85. David V. Sandberg, U.S. Forest Service. Progress in
Reducing Emissions from Prescribed Forest Burning in
Western Washington and Western Oregon. Paper presented
at the 23rd Annual Meeting of the Air Pollution Control
Association, Pacific Northwest International Section,
Eugene, Oregon. November 19-21, 1986.
86. Reference 84, p. 5.
87. Reference 53, p. 32.
88. Reference 53, p. 32.
89. Personal communication. John Core, Oregon Department
of Environmental Quality, to Ken Meardon, Pacific
Environmental Service, Inc.
90. David V. Sandberg, U.S. Forest Service. "Research
Leads to Less Smoke from Prescribed Fires." November
1983.
9-68 September 1992
-------
91. Roger D. Ottmar, U.S. Forest Service. Reducing Smoke
from Prescribed Fires; Research Solution to a
Management Problem. Presented at the Annual Meeting,
Northwest Forest Fire Council, Olympia, Washington.
November 18-19, 1986. p. 10.
92. Reference 88.
&3. Personal communication. Janice Peterson, U.S. Forest
Service, to Ken Meardon, Pacific Environmental Service,
Inc. July 31, 1991.
94. U.S. Forest Service, Southern Region. A Guide for
Prescribed Fire in Southern Forests. Technical
Publication R8-TP-11. February 1989. p. 25.
95. Reference 93, p. 25.
96. Reference 93, p. 25. ^
97. Reference 93, p. 26.
98. Reference 93, p. 26.
99. Reference 93, pp. 27, 28.
100. Reference 93, p. 28.
101. Reference 93, p. 20.
102. Reference 93, p. 20.
103. Reference 93, p. 21.
104. Reference 93, p. 22.
105. Reference 93, p. 23.
106. Reference 93, pp. 24, 25.
107. Reference 93, p. 27.
108. Reference 58, p. 120.
109. Reference 88.
110. Colorado Smoke Management Memorandum of Understanding.
Colorado Smoke Management Plan. II.F.2. Smoke
Management, p. 8.
111. Hugh E. Mobley, Alabama Forestry Commission. Voluntary
Smoke Management Guidelines. 1989. pp. 4, 5.
9-69 September 1992
-------
112. California Air Pollution Control Regulations Subchapter
2. Agricultural Burning Guidelines. Article 2.
Implementation Plan. Section 80150. Open Burning in
Agricultural Operations in the Growing of Crops or
Raising of Fowl or Animals.
113. Reference 111, Section 80160. Range Improvement
Burning.
114. Reference 111, Section 80170. Forest Management
Burning.
115. Reference ill, Section 80175. Wildland Vegetation
Management Burning.
116. Reference 109, p. 8.
117. Florida Forest Fire Laws and Open Burning Regulations.
17-5.09 - Open Burning Allowed..
118. Florida Burning Authorization Categories. January
1987.
119. Montana. Air Quality. Subchapter 13, Open Burning.
16.81301 Definitions, (1).
120. New Jersey Department of Environmental Protection,
Bureau of Fire Management. Circular #A52-1. Subject:
Prescribed Burning in the New Jersey Pine Region.
Smoke Management Plan for Prescribed Burning. July
1986.
121. Oregon. Division 26, Rules for Open Field Burning
(Willamette Valley). General Requirements, 340-26-
010(a).
122. Reference 120, Approved Alternatives Methods of Burning
(Propane Flaming), 340-26-045(1)(a).
123. Reference 120, Approved Alternative Methods of Burning
(Propane Flaming), 340-26-045(1)(b).
124. Reference 120, Stack Burning, 340-26-055.
125. Reference 120, Preparatory Burning, 340-26-033(3).
126. Oregon. Operational .Guidance for the Oregon Smoke
Management Program. Directive 1-4-1-601. 12/86. nr>.
9, 10.
127. Memorandum of Understanding Between State of Utah, Air
Conservation Committee, and the U.S. Department of
Interior, Bureau of Land Management, and the U.S.
9-70 September 1992
-------
Department of Agriculture, Forest Service. June 14,
1988. p. 3.
128. Virginia Department of Forestry. A Voluntary Smoke
Management Plan for Forestry Prescribed Burning
Operations for the Commonwealth of Virginia. July
1989. pp. 8 through 10.
129. Bert L. Cole. Air Quality - Prescribed Burning Smoke
Management Program. Part II, Smoke Management Plan.
pp. 12, 13.
9-71 September 1992
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10.0 STATE OVERSIGHT
10.1 INTRODUCTION
Many State agencies given the responsibility for
administering the State's smoke management program have
delegated some of that responsibility to other State
agencies. State oversight refers to the ability of that
State agency to step in and enforce those delegated portions
of the smoke management program if ,.the State agency to which
that delegated portion fails to adequately administer and
enforce the smoke management program.
In this chapter, a brief review of the various
relationships and delegation of smoke management programs
between State agencies and others is given. The purpose of
this review is to illustrate the current variety of
relationships. Next, methods used to designate the
responsibilities of the agencies and other affected parties
are noted. A presentation of one method, memoranda of
understanding, is given in more detail. The chapter
concludes with a discussion of an effective implementation
strategy for the State oversight element available for the
development of area-specific BACH smoke management programs.
10.2 SMOKE MANAGEMENT IMPLEMENTATION RESPONSIBILITIES
Responsibility for implementing smoke management
programs vary among the States. In some States, the primary
responsibility is statutorily delegated to the State's
Department of Environmental Quality (DEQ) (or equivalent).
In California, for example, the California Air Resources
Board is responsible for implementing the smoke management
program for prescribed burning, which is found in CCR Title
17. In Colorado, the Colorado Department of Health is
10-1 September 1992
-------
responsible for controlling open burning in the State
(Regulation #1, Section II. C, Open Burning).
In other States, two State agencies may be statutorily
responsible for a smoke management program.. For example, in
Oregon, the DEQ is responsible for administering the
Willamette Valley field burning program, while the
Department of Forestry is responsible for administering the
forestry smoke management program.1 A similar arrangement
exists in Washington, where the Department of Ecology
administers the regulatory program for the burning of grass
seeds and fields, while the Department of Natural Resources
manages the smoke management program for silvicultural
burns.2
>,*
In some States, the State agency administers a
voluntary smoke management program, relying on the
cooperation of the burners in the State. For example, in
Montana, the smoke management program is a voluntary,
cooperative effort3 between the Montana Department of Health
and Environmental Sciences and the Federal land managers,
State land managers, and timber companies.4
Another variation is found in North Carolina in which
there exists both statutory responsibility (for the
management of burning windrowed or piled materials in
eighteen coastal counties) and a voluntary program between
the Division of Forest Resources and the Forestry
Community,s
Some State agencies delegate varying levels of
responsibilities for implementing the smoke management
program. For example, in California, each air quality
management district (AQMD) is responsible for developing and
implementing a plan consistent with the agricultural burning
guidelines found in Title 17. These implementation plans
must be approved by the State board, which has delegated
this responsibility to the executive officer of the State
board. Implementation plans (or modifications to them) may
be approved, modified and approved, or rejected. The State
10-2 September 1992
-------
board is required to adopt an alternative plan if the plan
(or modification thereto) is rejected, or if no timely plan
is submitted, or if the plan is economically or technically
not. feasible. A public hearing in the affected basin is
required before the State board can adopt an alternative
plan.6 '
In Oregon, the DEQ has delegated the responsibility of
conducting the smoke management program to the Oregon
Department of Agriculture.7
In Washington, the DEQ is allowed to delegate authority
for issuance and enforcement of some forms of agricultural
burning permits:
Whenever the department of ecology shall find that any
county which is outside the jurisdictional boundaries
of an activated air pollution control authority is
capable of effectively administering the issuance and
enforcement of permits for any or all of the kinds of
burning identified in RCW 70.94.650 (1) and (3) and
desirous of doing so, the department of ecology may
delegate all powers necessary for the issuance and
enforcement of permits to the county: Provided, that
such delegation may be withdrawn by the Department of
Ecology upon a finding that the county is not
effectively administering the permit program.8
10.3 COORDINATION OF RESPONSIBILITIES
Various methods are used to coordinate the agencies and
others affected by smoke management plans. The methods used
vary to some extent on the parties involved and the nature
of the legislated responsibilities. For example, the
relationship between two State agencies may be laid out in
State law. This is the case in Oregon. There, the smoke
management program administered by the Division of Forestry
is jointly approved by the DEQ.9 In Washington, the
Department of Ecology is required to establish critical or
"designated" areas for the Department of Natural Resources
(DNR) in its administration of the prescribed forestry smoke
management program. In turn, the DNR requires the burning
permits it issues to comply with air quality standards
established by the Department of Ecology.10
10-3 September 1992
-------
In many States, the State agency responsible for
administering the smoke management program has used the
memorandum of understanding (MOU) (or agreement) as an
effective tool for promoting and facilitate cooperation
among-the State and Federal agencies. The MOU has also been
used in States with voluntary smoke management programs to
enlist the support and cooperation of Federal and State
agencies and the private burn community.
In Colorado, the Colorado Department of Health recently
signed an MOU with the U.S. Forest Service, the BLM, the
U.S. National Park Service, and the U.S. Fish and Wildlife
Service regarding the management of prescribed burning.
This is a very recently developed MpU. A copy of this
memorandum is shown in Figure 10-1. To meet the objectives
of the memorandum, the signatories developed a smoke
management plan. The responsibilities of each party are
detailed in the smoke management plan. Each signatory
agrees to abide by that plan. Any signatory that withdraws
from the MOU is still responsible for complying with all
Federal law and Colorado statutes and regulations.
In California, some of the AQMD's are MOU's between the
district and Federal agencies, such as the U.S. Forest
Service. A copy of the MOU between the Northern Sierra AQMD
and the U.S. Forest Service is shown in Figure 10-2. The
responsibilities between the Northern Sierra AQMD and the
U.S. Forest Service are listed in the MOU.
As noted earlier, the smoke management program in
Montana is a voluntary, cooperative effort between the
Montana Department of Health and Environmental Sciences
(DHES) and Federal land managers, including the Bureau of
Indian Affairs, State land managers (including the
10-4 September 1992
-------
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Department of State lands, which administers the program and
determines compliance), and timber companies. These
constituents with the DHES maintain a memorandum of
agreement (see Figure 10-3). Each member agrees to abide by
the cooperative smoke management plan for Montana, in which
the respective responsibilities and working relationships
are identified. The State retains legal enforcement powers.
A fourth example MOU is presented in Figure 10-4.
This MOU is between the Idaho Department of Health and
Welfare, Division of Environment, and the U.S. Forest
Service. It lays out the specific responsibilities and
working relationships between the Division of Environment
and the U.S. Forest Service.
x.^
The primary purpose of an MOU is to clearly specify the
working relationships between the affected parties. MOU's
may be between State agencies, between Federal and State
agencies, and between State agencies, Federal agencies, and
private companies.
In general, MOU's will have several parts as follows:
1. Statement identifying parties participating in the
MOU and effective date of the MOU. At least two
styles have been used:
Example 1
"This Memorandum of Understanding (MOU) has been
entered into this day of ^ , 19 , by and
between the Idaho Department of Health and Welfare,
Division of Environment, and the United States
Department of Agriculture, Forest Service, through
the Regional Foresters for the Northern,
Intermountain and Pacific Northwest Regions,
hereinafter called the Forest Service."
Example 2
"This Agreement is .entered into effective July 31,
1978. The agencies and companies which are
signatories to this Agreement hereby agree to abide
by the Cooperative Smoke Management Plan for
Montana attached hereto.'«
10-9 September 1992
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2. Statement of Authority! identifying legal basis.
For example:
Example 1
"The District has adopted Regulations governing the
management of smoke from all sources of smoke from
all sources of open burning (Regulation 111),
including prescribed burning."
Example 2
"WHEREAS, the Department of Health and Welfare,
hereinafter called the Department, has been created
under Title 39 of the Idaho Code to provide public
health and environmental protection by supervision
and administration of a system to safeguard air and
water quality of the State of Idaho."
Example 3
"WHEREAS, the Forest Service under the Clean Air
Act as amended is directed, as Federal Land
Manager, to meet Federal, State, interstate, and
local substantive requirements respecting control
and abatement of air pollution, and to provide for
the management and protection of air quality
related values."
3. Statements of Purposes, Goals, or Objectives are
usually included. For example:
Example 1
1. To minimize the generation and/or impacts of
smoke in Colorado when prescribed burning is
necessary for the conduct of accepted range and
forest practices. Alternative treatments will
be encouraged and used where environmentally
acceptable, technologically feasible, and
economically reasonable.
2. To assure that no Colorado ambient air quality
standards are exceeded. (The determination of
such exceedance shall be the responsibility of
the Colorado Air Pollution Control Division.)
3. To minimize visibility impacts from smoke in
smoke-sensitive areas and in important views in
Class I areas, especially during times of
significant visitor use.
4. To develop and implement a system.to inventory
emissions from prescribed fires and wildfires.
10-15 September 1992
-------
Example 2
1. To comply with the Clean Air Act and the State
of Idaho Air Quality Implementation Plan and
IDAPA Sections 16.01-1000 et seq. (Rules and
Regulations for the Control of Air Pollution in
Idaho); and
2. To develop and document procedures to minimize
duplication of effort and facilitate
complementary air pollution monitoring,
control, and abatement programs; and
3. To develop air pollution control, monitoring,
and abatement programs for Class I and II
airsheds in Idaho, recognizing the need for
both environmental protection and resource use,
and conduct activities which will meet short-
and long-term local, S.tate, Regional, and
National needs; and
4. To improve air resource management coordination
and cooperation between the Air Quality Bureau
and the three Forest Service Regions within the
State of Idaho.
Example 3
1. To minimize or prevent the accumulation of '
smoke in Montana to such degree as is necessary
to protect State and Federal ambient air
quality standards when prescribed burning is
necessary for the conduct of accepted forest
practices such as hazard reduction,
regeneration and wildlife habitat improvement.
The development of alternative methods shall be
encouraged when such methods are practical.
Statements Specifying the Responsibilities of Each
Party to the MOU. Some States, such as Colorado
and Montana, specify these responsibilities through
a smoke management plan attached to the MOU,
incorporating it by reference.
Example 1
In order to meet these objectives, the signatories
have developed and hereby agree to abide with the
Colorado Smoke Management Plan attached hereto.
10-16 September 1992
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Example 2
2. To develop a smoke management plan for
reporting and coordinating burning operations
on all forest and range lands in the State.
Guidelines in the plan will be based upon the
principles of and technical information
currently available on smoke dispersion and on
State and federal air quality regulations. A
copy of the Smoke Management Plan is attached
and incorporated herein by reference. The
Smoke Management Plan shall be reviewed
periodically and changes may be made with the
approval of all signatories or their designated
representative. Such approval shall be given
in writing.
Other MOU's will spell out the specific responsi-
bilities of each party in the MOU itself. Examples
of these MOU's are shown in Figures 10-2 and 10-4.
5. Miscellaneous Clauses. Most MOU's have a number of
additional items relating to the nights that are of
each party agreed to by the parties. These
include:
relationship of the MOU to other legal
responsibilities;
right to withdraw from the agreement;
nondiscrimination clause; and
no benefit clause.
Some MOU's address such items as cooperative air
quality monitoring activities and the development
and application of best available air pollution
control technologies for activities and uses of
forests of rangelands.
10.4 EFFECTIVE IMPLEMENTATION STRATEGY
Generally, the State air quality agency should
coordinate frequently and closely (e.g., at the local level)
with the managers of the smoke management program to ensure
that the program is being administered in a manner
consistent with air quality goals.
10-17 September 1992
-------
The exact relationship of the State air pollution
agency to other State agencies to which management of the
smoke management program may have been delegated will need
to be determined on a State-by-State basis. However, the
State air regulatory agency must have the authority to step
in and enforce the smoke management program if necessary.
State rules and regulations should be enacted in such a
manner that all provisions of the smoke management program
are enforceable by the State through its State
implementation plan. The State SIP must be federally
enforceable.
Generally, MOU's should be utilized to clearly specify
working relationships among agencie.3. The MOU must reflect
the BACM program.
Oversight ensures that the SIP is being administered in
a manner consistent with air quality goals. Elements of an
oversight program might include tracking of:
a. exceedances of standards
b. intrusions of smoke
c. complaint level
d. dollar spent per unit of emission reduction
e. frequency of real-time audits
f. program spot checks
g. reaction time to cases of noncorapliance
10-18 September 1992
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10.5 REFERENCES
1. Memorandum. Fred Hansen, Director, Department of
Environmental Quality, to Gail Achterman, Governor's
Office. Subject: Smoke Management "White Paper." May
5, 1988. p. 2.
2. Peter Lahm. Smoke Management Practices Report.
Appendix B. Smoke Management Programs Within the United
States. Prepared for: Arizona Department of
Environmental Quality. 1990. p. 43.
3. Aaron L. Zimmerman. Smoke Management in the State of
Montana. (no date). 3 pages. p. 2.
4. Montana Smoke Management, Memorandum of Understanding.
January 1988 (revised).
5. Briefing Paper for Governor Ja.mes G. Martin. Subject:
Forestry Smoke Management Program. January 15, 1988.
2 pages, p. l.
6. California State Air Laws. Title 17. Subchapter 2.
Agricultural Burning Guidelines. Article 2.
Implementation Plan. 80140. General.
7. Oregon Department of Agriculture. 1990 Annual Field
Burning Report. p. 3.
8. Chapter 70.94 RCW, Washington Clean Air Act. RCW
70.94, Delegation of permit issuance and enforcement to
counties.
9. Oregon Revised Statutes 477.515(3)(a).
10. Bert L. Cole. Air Quality - Prescribed Burning Smoke
Management Program. Part I. Coordination and
Operation. June 1975 (revised), pp. l, 3.
10-19 September 1992
-------
-------
11.0 COSTS OF AVAILABLE SMOKE MANAGEMENT PROGRAM
FOR PRESCRIBED BURNING
11.1 INTRODUCTION
The purpose of this chapter is to discuss a methodology
that can be used to estimate the costs of implementing the
smoke management program available for prescribed burning
BACM. Two groups will be impacted by the smoke management
program recommended in this document in terms of cost: the
burners themselves and the State implementing the program.
As such, the methodology identifies cost elements that may
be incurred by the burner or the State for the eight
specific components available for BACM smoke management
programs.
To estimate costs for the elements, in-house reference
sources were consulted to determine if information on these
cost elements was available. Depending upon the type of
information, an assessment was made to determine if such
data could be found, if in-house data were not available.
11.2 GENERAL COST ASSESSMENT OF PRESCRIBED BURNING
Two separate items were considered to comprise the cost
of each component of the available smoke management program.
They are the costs incurred by the burn community and by the
administrative agency (i.e., the State). -The data-gathering
effort emphasized obtaining cost estimates to the burn
community, which are largely incurred through use of
emission reduction techniques, with somewhat less emphasis
placed on obtaining precise cost estimates to the State.
Typically, the cost incurred by the burner will vary a
great deal depending upon harvest characteristics, fuel
characteristics, and land ownership (e.g., private vs.
11-1 September 1992
-------
Federal). As a general rule, the cost of forestry
prescribed burning is lower for private lands due to
relative ease of land clearing and pre-burn practices.1'2'3
However, the cost of site preparation will vary for either
private or Federal land depending on such factors as
terrain, weather patterns, vegetation project logistics, and
local smoke management regulations. In fact, the relative
standard deviation of unit-to-unit costs is as high as 98
percent for western Oregon and the State of Washington.4
Given this, it is important to recognize that the cost
estimates presented below are generally highly dependent on
specific site conditions and cannot be precisely estimated
for a given burn.
x--
Some difficulty has been experienced in obtaining data
for specific cost items incurred by the State. This is due
to the fact that it is difficult to quantify cost parameters
for some of these items, and also because the budget data
from the State frequently do not contain such specific line
items.
11.3 BACM COMPONENTS AND COST
Table 11-1 lists the eight smoke management components
described below and identifies the relevant costs and also
indicates whether these costs are borne by the burner, the
State, or both.
The sections below describe costs for each of the
elements of the eight prescribed burning components and
discuss the cost data available.
11.3.1 Smoke Dispersion Evaluation
For this component, three BACM elements with costs were
identified: (1) the smoke management program (SMP) is
required to use local meteorological data and forecasts (vs.
national weather source data for RACM); (2) smoke dispersion
computer modeling analysis is used in conjunction with local
met data to determine "burn days," "no burn days," and
11-2 September 1992
-------
TABLE 11-1. SMOKE MANAGEMENT COMPONENTS AND COST ELEMENTS
'BACH
Component
Smoke Dispersion Evaluation
Burn Planning, Administra-
tion, and Authorization
Public Education and Aware-
ness
Burner Qualifications
Surveillance and Monitoring
Emission Inventory
Emission Reduction
Techniques
State Oversight
Cost Elements1'11
1. Use of local data
2. Use of computer model ing
3. Frequent start and stop burns
4. Cost to reschedule burns
5. Smoke dispersion evaluation during burns
1. Requires verifiable authorization to burn
2. Information needed for dispersion model
3. Review of emission reduction techniques
4. Development of burn prJoritization
5. Appeals process
1. Comprehensive program
1. Requirement of training/ certification
1. Use of special purpose monitors
2. Aggressive (vs. periodic) visual
assessment
3. Greater use of routine monitors
1. Emission inventory preparation
2. QA audits of data
3. Tracking of RFP
1. Implementation of fee structure
2. Identify ERT for each burn type
3. Use of ERT's
4. Determine equivalency
1. Coordination between managers of SMP and
the State
Costs
for
Burners
X
X
X
X
X
X
X
X
X
X
X
Costs
for
State
X
X
X
X
X
X
X
x
X
x
X
X
x
X
x
X
X
x
X
'Cost elements have been identified by analysis of eight components of the smoke
management program available for the development of area-specific BACM strategies.
Federal and other large burners may have cost estimates for all of the elements listed.
11-3
September 1992
-------
locations where burning is allowable; and (3) smoke
evaluation during burns is required.
This component may result in increased costs to the
burner and to the State. The burner might incur the cost of
more frequent starts and restarts of burns and the cost of
rescheduling burns due to more "no burn days." Both of
these costs are attributed to the use of local rather than
national meteorological data. The State might incur the
cost of gathering the local meteorological data, the cost to
select and implement the model, and the cost to implement
daily smoke dispersion evaluations during the burn itself.
11.3.2 Costs to Burner
It is difficult to accurately estimate the costs to the
burner for start/stops of burns. This cost is largely
influenced by the amount of labor necessary to stop a burn
once it has started and to clear the area and restart the
burn when appropriate. An appropriate estimate for these
charges has not been found at present.
Any estimate of the cost of rescheduling a burn is
likely to be heavily influenced by the proportion of the
burning opportunity lost as this determines the additional
effort to burn the material over the remaining burn days.
This concentration of effort will likely lead to greater
management problems, a potential lack of available labor,
and increased labor costs to the burner. A cost methodology
has been developed for this situation which is based on
current planned cost, planned burning days, burning days
lost due to SMP decisions, the number of burns to be
rescheduled, and wage rates.5 The formula given below
yields cost due to rescheduling on a "burn unit" basis
rather than on an acre basis. A "burn unit" basis is
defined to mean the total area of a specific planned burn.
The cost per rescheduled burn is estimated using the formula
below. Table 11-2 provides information on parameter values
for variables fx through f7:
11-4 September 1992
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Cost = Nu X Cp X [(fx X (1 + (f2/f3) X (!-£,) )-X ((f3 +
(1^/Np) X f 4 X (fs-l) + f 6 X (f3 .4- f 4 X f7 X
(Nx/Np)) - (1 + Ni/Np) X (f .-I)) - (fs X (1 + (f7
X NJ/Np))]
where :
'.*
Cp = current planned cost per burn unit
Nu = number of burn units to be rescheduled
N! = current planned burning days lost due to
rescheduling requirement
Np = current planned burning days
It is recognized that this formula may look somewhat
intimidating, however, its use is relatively straight-
forward once the parameter values have been established.
To assist the reader in the correct use of this
formula, consider the following example.
Assume the current planned burning days (i.e., Np )
equals 20 , and that 10 of these burn days have been lost due
to rescheduling (i.e., N,. ) . Further, assume the number of
burn units to be rescheduled equals 10 (i.e., Nu ) , and the
cost of each burn unit equals $10,000 (i.e., Cp =$10,000).
Let the parameter values equal the following:
fi = 1.0
f2 = 1.15
f3 = 0.5
f4 = 1.0
fs = 1.50 ,
f6 = 0.04
f7 = 0.10
The cost of rescheduling is then estimated as:
Cost = 10 x ($10,000) x [(1 x (1 + (1.15/0.5) x (1 -
0.5)) X ((0.5 + (10/20) X 1.0 X (1.5 - 1)) +
0.04 X (0.5 + 1.0 X 0.10 X (10/20)) - (1 +
(10/20) X (1.5 - 1)) - 0.04 X (1 + ((0.1 x
Cost = 10 X ($10,000) X [2.15 X (0.75 + 0.022) - 1.25 -
0.042]
Cost = $36,780.00
11-5 September 1992
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TABLE 11-2. PARAMETER VALUES FOR RESCHEDULING A BURNa
Factor
Default
value
Range of
values
f2:
f3:
f4:
f5:
f6:
f7:
ratio of new current real
wage rate 1.00
ratio of new labor costs to
current labor costs 1.15
ratio of new to current
planned days
ratio of new to current
lost days
overtime ratio factor 1.50
ratio of planning to labor
costs per unit 0.04
additional work factor for
burner due to lost days 0.10
0.95-1.05
1.00-1.25
0.50-1.00
0.50-1.00
1.00-2.00
0.00-0.10
0.00-0.20
* Source: Reference 5.
11-6
September 1992
-------
For this example then, the cost of rescheduling the
burns would equal $36,780.00 Note that this cost is an
additional cost that must be added to the $100,000 (i.e., 10
x $10,000) in burn costs.
Table 11-3 contains a summary of the cost elements for
this component. The cost elements are listed down the left
column and cost data are to be inserted into the spaces
provided for either the burner or the State. These data are
then simply totaled to obtain the costs to the burner or to
the State for this component.
11.3.3 Costs to the State
The cost to obtain and analyze local weather data will
likely vary from area to area, but cost data obtained from
the State of Oregon indicated an annual cost of
approximately $6,800.6 This cost included costs of
obtaining the data, the cost of computer modeling software,
the cost of computer training, and system repair and
servicing. The cost to implement daily smoke dispersion
evaluations will vary with the level of effort (e.g.,
increased labor, aerial reconnaissance), but cost data for
these components should be readily obtainable by the State.
11.3.4 Burn Planningr Authorization, and Administration
For this component, a total of five elements have been
identified. First, all approved burns should be provided
with verifiable authorization from the State prior to burn.
For this element, the costs will be borne by the State,
since it is the State's responsibility to notify burners
concerning their authorization. Second, more information
will need to be supplied to the State to run the selected
computer model, meaning additional costs to both the burner
and the State. Third, the State will incur some incremental
costs to review proposed emission reduction techniques.
11-7 September 1992
-------
TABLE 11-3. COSTS FOR SMOKE DISPERSION EVALUATION
1.
2.
3.
4.
5.
Cost Element Burner Cost
Use of local weather data N/A
Use of computer modeling N/A
More freauent start and $
stops of burns
Cost to reschedule burns $
Costs to implement smoke N/A
dispersion evaluation
Total Cost $
State Cost
$
$
$
$
N/A
N/A
N/A: Not applicable to this cost element
11-8 September 1992
-------
Fourth, costs will be incurred by the State to develop a
more complex prioritization scheme to organize burn
requests. Fifth, both the burner and the State will likely
incur costs due to the appeals -process.
Cost estimates for these items are difficult to obtain,
since most of these items are difficult to quantify for both
burners and the State. For example, it is difficult to
estimate the amount of time necessary to develop in-house
expertise in emission reduction techniques and to develop a
more complex burn request prioritization scheme. It is
believed that it will be difficult to defend any cost
estimates for this measure due to lack of quantifiable
parameters.
Table 11-4 provides a summary of the cost elements for
this measure. Each cost element is listed down the left
column and cost data are to be inserted into the spaces
provided for either the burner or the State. These data are
then totaled to obtain the costs for this measure.
11.3.5 Public Education and Awareness Program
The increment for this component is limited to
recommending a more comprehensive public awareness and
education program than suggested under RACM.
At present, no cost data for public education and
awareness (PE&A) programs for prescribed burning have been
found. However, it is believed that such a program would
not significantly differ from a similar program for
residential wood combustion (RWC). Cost data obtained from
such programs vary significantly, depending on the mediatype
(i.e., newspapers, radio, television) used, and area
population. Because of this, it was difficult to summarize
the data so that.it could be used to estimate costs for a
prescribed burning program. Therefore, no definitive cost
data are presented for this measure.
11-9 September 1992
-------
TABLE 11-4. COSTS FOR BURN PLANNING,
AUTHORIZATION, AND ADMINISTRATION
Cost Element Burner Cost State Cost
1. Require verifiable
authorization to burn . N/A $
2. Obtain additional
information for dispersion $ $
model
3. Review of Emission N/A
Reduction Techniques
4. Development of burn
prioritization N/A
x^
5. Appeals process N/A
Total Cost $
N/A: Not applicable to this cost element.
11-10 September 1992
-------
Table 11-5 provides a summary of the incremental cost
elements for a BACM PE&A program. The cost elements are
listed down the left column and cost data are to be inserted
into the spaces provided for the State. These data are then
totaled to obtain the BACM incremental costs for this
measure.
11.3.6 Burner Qualifications
The cost element for this component is the
recommendation of burner training and certification. The
costs to burners will vary depending on proficiency. The
cost to the State would include program development and
operations.
At present, cost data for a burner training and
certification program have not been obtained. Several
individuals familiar with training and certification courses
have been contacted, but these individuals were unaware of
any cost data for a burner qualification program.7
Table 11-6 contains a summary of the cost elements
associated with this measure. These elements are listed in
the left hand column and cost data are to be inserted into
the spaces provided for either the burner or the State.
These data are then simply totaled to obtain the costs for
this measure.
11.3.7 Surveillance and Monitoring
The cost element includes a comprehensive program for
surveillance monitoring of burns. Specific elements include
special purpose monitors, aggressive visual assessment, and
greater supplementation using routine monitors. The cost to
burners is assumed to be stop/start of burns, while the
costs to the State include the purchase and use of special
purpose monitors, frequent visual assessment, and the use of
PM-10 monitors.
11-11 September 1992
-------
TABLE 11-5. INCREMENTAL BACM COSTS FOR PUBLIC
EDUCATION AND AWARENESS PROGRAM
Cost Element State Cost
Media Type
a. Print $_
b. Broadcast $
c. Public contact/education $
Total Costs $
TABLE 11-6. COSTS FOR BURNER QUALIFICATIONS
Cost Element Burner Costs State Costs
Requirement of burner $ $
qualification through
training/certification
11-12 September 1992
-------
A comprehensive surveillance and monitoring program
includes cost of special purpose monitors, visual observance
of the burn, and use of routine monitors. These are all
costs borne by the State and cost estimates for these items
should be readily available to the State. Costs to the
burner are assumed to be start/stop of burns. As stated
earlier, it is difficult to quantify these costs, and no
cost data for these elements have been found.
Table 11-7 contains a summary of the costs for this
measure. Each cost element is listed in the left column and
cost data are to be inserted into the spaces provided for
the burner and the state. These data are then totaled to
obtain the costs for this measure. x.
11.3.8 Emission Inventory
The costs to the burner include preparation of the
emission inventory while the cost to the State includes the
cost of auditing emission inventories and the tracking of
reasonable further progress. To date, a quantification of
burner and State costs has not been found, primarily due to
the difficulty in quantifying cost parameters.
Table 11-8 provides a summary of the costs for an
emission inventory. The cost elements are listed down the
left column and cost data are to be inserted into
the spaces provided for the State. These data are then
totaled to obtain the costs for this measure.
11.3.9 Emission Reduction Techniques
There are four specific cost elements for this
component. They include an implementation of a fee
structure, an identification of emission reduction
techniques for each burn type, the use of such techniques,
and, when appropriate, the determination of an appropriate
equivalency measure.
The cost to burners includes the use of emission
reduction techniques, the fee to the State, and the
"11-13 September 1992
-------
TABLE 11-7. COSTS FOR
SURVEILLANCE AND MONITORING
Cost Element
Burner Costs
State Costs
1. Use of special purpose
monitors N/A
2. Aggressive visual
assessment
3.
Greater use of routine
monitors
Total Costs
s
s
$
$
N/A: Not applicable to this cost element.
TABLE 11-8. COSTS FOR EMISSION INVENTORY
Cost Element Burner Costs State Costs
1.
2.
3.
Emission inventory
preparation S
QA audit of data N/A
Tracking of RFP N/A
Total Costs $
$
$
$
N/A
N/A: Not applicable to this cost element.
11-14
September 1992
-------
development of a methodology for showing equivalency. The
cost to the State includes the creation, implementation, and
use of a fee structure; an identification of emission
reduction techniques; and development of a methodology to
determine equivalency. At present, no data on the costs
incurred by using the emission reduction technique have been
found. In addition, no potential cost data for determining
equivalency have been found. A basic assumption for the
cost of this measure is that under RACM, burners will not
.use the best ERT's, while under BACM such use is required.
It should be noted that this assumption may not be realistic
because almost all programs require techniques that minimize
smoke. This means that the BACM cqst estimates may be
conservatively high in some cases.
Emission reduction techniques can be divided into two
categories: techniques to reduce emissions from prescribed
burns and alternatives to prescribed burning. Both methods
are described in more detail below.
Techniques to reduce emissions from prescribed burning
are discussed below. These techniques are divided into two
sections. The first discusses emission reduction techniques
associated with agricultural burning, while the second
discusses techniques associated with forestry burns.
The costs given for the emission reduction techniques
described below quantify, where available, the costs
incurred by the burner when using these techniques. It must
be remembered, however, that specific costs to the burner
will vary due to site-specific conditions.
11.3.10 Emission Reduction Techniques - Agricultural
Burning
In general, the cost for the various techniques are
estimated on an $/acre basis except when another cost unit
such as $/ton residue is more appropriate. Emission
reductions from these techniques are difficult to quantify
and, therefore, only costs are discussed in this
methodology. The techniques described below are applicable
11-15 September 1992
-------
to agricultural burns such as a rice stubble burn and a seed
grass burn.
11.3.10.1 Mobile Field Sanitizers. As described in
Chapter 9, this technique uses thermal treatment of soil to
burn agricultural residues. Research and development funds
in the 1960's lead to field testing in the 1970's. A
technical and economic evaluation concluded that short
machine life, high operating costs, energy consumption,
problems with emission controls, and slow operating speed
made this technique an unsuitable alternative to open-field
burning.* Consequently, no cost data were obtained for this
technique. ^ i -
11.3.10.2 PropaneFlaming. Propane flaming is often
used in conjunction with residue removal as an alternative
to open field burning. The cost of this technique depends
on speed of operation and removal of straw and stubble as
discussed in Chapter 9. The cost estimates for propane
flaming range from $8/acre at a speed of 4 mph to $32/acre
at a speed of 1 mph for propane flaming itself, $37.50/acre
for straw removal, and $0.50/acre for stack burning, for a
total of $42/acre to $70/acre.9
11.3.10.3 Bale/Stack Burning. In Oregon, some growers
in the Willamette Valley are burning straw bales or stacks
of unmarketable crop residues. This practice has increased
with an increase in propane flaming. The cost of bailing
and bale/stack burning has been estimated at $20 to $30 per
ton of residue for bailing and a cost of $0.50/ton for
burning the residue/
10
11.3.10.4 Less-Than-Annual Burning. The costs of this
technique (i.e., alternating open field burning with
mechanical straw removal) will vary depending upon straw
removal costs, stack burn costs, reduced seed yields, and
11-16 September 1992
-------
amortized field costs. These costs include $30/acre for
field amortization, $37.50/acre for straw removal,
$0.50/acre for stack burning, and $68/acre for reduced seed
yield, for a total cost of $136/acre.i:L
11.3.10.5 Soil Incorporation of Straw in Annual
Ryecrrass. This technique has shown similar seed yields to
open burning when the straw is chopped previous to plowing
it into the soil. However, soil incorporation of weed seed
will increase weed management problems, leading to higher
costs. The costs for this technique include $24/acre for
straw removal, $10/acre for chopping the straw stubble,
$30/acre for application of herbicide, and $35/acre for
A*-
annual fillage, for a total cost of $99/acre.12
11.3.10.6 Alternative Crops. An alternative to
agricultural burning is the replacement of crops whose
residues are typically burned with crops whose residues need
not be burned such as meadowfoam, rapeseed, and Pyrethreum.
The costs for such conversion will clearly depend heavily on
relative crop yields and values, making it difficult to
quantify these costs without prior knowledge of these
parameters.. An estimate of costs for this method has
therefore not been attempted.
11.3.10.7 Mechanical Straw Removal. This technique
typically utilizes one of two methods: flail chop removal
or close clip removal of stubble on the soil surface. The
costs for the flail chop method include $37.50/acre for
straw removal, $27.55 for the flail chop, and $0.50/acre for
stack burning for a total $65.55/acre.13
The costs for close clip removal of stubble include
$37.50/acre for straw removal, $36/acre for cut and vacuum
of stubble, and $0.50/acre for stack burning for a total of
$74/acre."
11-17 September 1992
-------
11.3.10.8 Chemical Treatment. This treatment has met
with some resistance due to EPA requirements and concern
about chemical seepage into groundwater and surface water.
Results will tend to vary based on agricultural species and
weather conditions. The costs for chemical treatment have
been estimated at $33/acre for chemicals and application,
$37.50/acre for straw removal, $0.50/acre for stack burn,
for a total of $71/acre.ls
11.3.10.9 Harvesting of Unburned Sugar Cane. Tests on
the feasibility of processing unburned versus burned sugar
cane were conducted in Texas and Hawaii. The results of the
Hawaiian tests indicated that harvesting unburned sugar cane
would result in an estimated annual loss of $73 million
assuming a production of 1.1 million tons of sugar per year
and a break-even sugar price of $400 per ton. This .
translates into a loss of $66/ton for the sugar cane
growers.
11.3.11 Factors Affecting Pre-Burn Fuel Loading. Fuel
Consumption and Emission Factors
11.3.11.1 Amount of Green Regrowth. The amount of
green regrowth occurring after harvest and before the burn
will directly affect emissions. Reducing the amount of
green regrowth prior to burn will likely increase labor
costs associated with the burn, but a quantification of
either emissions or costs from this factor has not been
found.
11.3.11.2 Fuel Distribution. The method of piling
residue in the field may affect the emissions generated
during the burn. One study16 on wheat and barley straw
showed emissions from straw piles to be about one third of
those when spread straw is burned with a headfire. Specific
emission reductions for a given burn will likely tend to
vary significantly depending on type of straw, weather
conditions, and other factors, making it difficult to
11-18 September 1992
-------
accurately assess emission reductions. The cost of piling
field residue has not been found, however, the cost of
bailing straw has been estimated at $20 to $30 per ton of
straw residue.17
11.3.11.3 Firing Techniques. A significant decrease
in emissions may occur through the use of firing techniques.
Specifically, the use of backfiring and into-the-wind
stripfiring will reduce emissions from straw burning. Tests
on rice fields found backfire burning to emit about one-half
the particulates as a headfire burn assuming the same
moisture content. However field tests for wheat and barley
straw showed no significant differences in particulate
emissions between the two burn types.18 Given these
differences in test results, it does not appear likely that
an accurate quantification of emission reductions from this
technique can be obtained. Moreover, no cost data
associated with employing different firing techniques have
been found.
11.3.11.4 Fuel Moisture. The fuel moisture content
significantly affects the generation of emissions from
agricultural burning. The higher the fuel moisture content,
the poorer the combustion and the greater the emissions of
PM-10. Field studies have shown that a reduction in the
fuel moisture content of rice residues from 25 to 10 percent
will reduce emissions from 18 to 5 kilograms per megagram of
rice residue burned when using the headfire technique. For
wheat and barley straw, no significant differences in
emissions were found.19 The results of these tests indicate
that quantifying an emission factor for fuel moisture
content is specific to straw type and field conditions.
Therefore, it will likely be difficult to obtain a general
estimate for this factor. To date, no cost data associated
with changing the fuel content has been found, but costs
11-19 September 1992
-------
will likely be strongly related to drying times prior to
burning.
Table 11-9 contains a summary of emission reduction
techniques for agricultural burning. Each technique is
listed in the left column, along with corresponding cost
data, if known. Specific costs should be inserted into the
spaces provided.
11.3.12 Emission Reduction Techniques - Forestry Burning
Several alternatives to reducing the number of acres
burned exist. These include: no treatment, manual/hand
labor, chemical, alternative mechanical, and an air curtain
destructor. Each alternative is briefly discussed below.
Emission reductions are difficult to quantify and,
therefore, only cost methodologies are discussed below. The
techniques described below are applicable to such burns as
an understory burn, a piled slash burn, a broadcast forest
burn, and a windrowed slash burn.
11.3.12.1 No Treatment. This method allows for the
natural process of degradation to occur. An advantage to
this technique is minimal costs; however, the natural
process of degradation is very slow, even when
microorganisms are used to accelerate the decomposition
process. In addition, no treatment will lead to an
increased wildfire hazard. The costs from this technique
have not been obtained but are likely to be very low, since
a minimal amount of effort is employed. However, increased
costs will occur with regeneration of the site and planting.
No PM-10 emissions will occur from this process.
11.3.12.2 Manual Removal. This includes use of chain
saws, hand removal, and soil scalping using hand tools. In
general, manual methods are more costly than prescribed
burning and "can be dangerous to workers.20
11-20 September 1992
-------
TABLE 11-9. COSTS FOR AGRICULTURAL BURNING
EMISSION REDUCTION TECHNIQUES
1.
2.
3.
4.
Technique
Propane flaming
Bale/stack burning
Less-than-annual
burning
Soil incorporation of
Cost Data
$70/acre
$20.50-
$30.50/ton
$136/acre
$99/acre
$
$
$.
$
Cost to
Burner
8.
9.
10
Straw
Mechanical straw
removal
a. Flail chop
b. Close clip removal
Harvesting of unburned
sugar cane
Amount of green
regrowth
Fuel distribution
Firing techniques
Fuel moisture
Total
$65.55/acre
$74/acre
$20-$30/ton
$.
$.
$.
$.
$.
$_
$.
$.
11-21
September 1992
-------
However, manual removal methods can be highly selective
and have a low impact on the soil surface which may be
advantageous for some applications. Unfortunately, a high
production rate is often not possible, and resprouting may
occur. The average costs for a single treatment have been
found as $206/acre for site preparation and $166/acre for
conifer release.21 However, costs will vary greatly for a
given area and multiple treatments may be needed.
11.3.12.3 Chemical Treatment. This technique is used
to kill unwanted vegetation and allow room for growth of new
seedlings. Herbicides may be applied in four different ways
including: aerial (i.e., helicopter or fixed wing
aircraft), mechanical equipment using trucks with mounted
wands or boom sprayers, backpack equipment use by
individuals, and hand application by injection. Costs for
aerial and backpack application have been estimated at $50-
$60/acre and $70/acre, respectively.22 Costs for mechanical
equipment application have not been found but are likely
comparable to the costs of using trucks for other
applications (i.e., excavation), which have been estimated
at $135/acre.23 Costs for hand application have not been
found.
11.3.12.4 Mechanical Methods. This method of removal
includes the use of tractors or trucks to pile slash
materials for later use as boiler fuel or as piling for a
later burn, the use of crawlers equipped with a circular
blade to tear through slash residues to mineral soil and
scalping systems that scrape wood debris into piles creating
strips of mineral soil.2* The costs of such methods have
been estimated to average $135/acre but will vary depending
on type of equipment. A bulldozer with a blade will average
$80~$100/acre, ripping and piling will average $75-160/acre,
disking will average $70-$80/acre, and a Track-Mac will
average $150-$250/acre.2S
11-22 September 1992
-------
11.3.12.5 Explosives. These are used to clear
planting sites or to remove excess vegetation that would
shade out new seedlings. This technique is perceived to be
inherently dangerous and considerable resistance to its use
exists.26 However, explosives appear to be a technique
which has high usefulness in limited situations. For
example, it shows some promise for use on steep slopes where
burning is not advised. Two types of explosives commonly
used by the forest industry are four- or seven-line
explosive cords and water gel cord. The use of explosive
material in land preparation has proven to be more effective
in tall grass and small diameter brush (generally less than
2-inches diameter). There are two ^approaches that can be
used in site preparation: line clearing and spot clearing.
The costs for site preparation using explosives are given in
Table 11-10.
11.3.12.6 Air Curtain Destructor. This method
combusts forest residue in a pit. It offers several
advantages over open burning, including essentially complete
combustion, confining smoke and particulate matter to the
pit, and only a small land area is affected by heat, which
assists in later reforestation. Tests performed in 1971 and
1972 utilizing eucalyptus, orange, palm, pine, Douglas fir,
adar, hemlock, larch, and lodgepole fuels found emissions
too low to measure.27 Cost data have been obtained for this
technique on a $/ton basis, but these data are taken from a
1978 report, so it is uncertain how these costs have changed
in succeeding years. The data indicate costs for this
technique vary between $8-$30/ton residue burned.28
11.3.12.7 Reduction in Pre-Burn Fuel Loading.
Utilization of as much of forest residue as possible reduces
the amount of fuel available to be burned and removal of
larger residue allows for more complete consumption of
smaller residue.
11-23 September 1992
-------
TABLE 11-10. COSTS FOR USE OF EXPLOSIVES3
Cost Item
Cost
Line Clearing
Material costs (water gel) $2/000/acre
Labor costs can equal or exceed
material costs
Total costs
Spot Clearing
Material costs (water gel)
Total costs
Fuel Air Explosives
Packets costs
Prima cord & other
Labor costs
Total costs
$2,000-
$4,000/acre
$l,250/acre
$1,800-
$3,000/acre
$300-
$400/acre
$100-
$200/acre
$200-
$2,000/acre
$600-
$2,600/acre
Source: Reference 26.
11-24
September 1992
-------
Utilization of residue is frequently done by collecting
it into piles of various sizes called yarding unmerchantable
materials (YUM). The use of this material includes firewood
and chips for hog fuel or cogeneration plants.
Emission reductions achieved using "this technique will
directly depend on the quantity of fuel reduced, making it
difficult to estimate emission reductions from this measure.
The costs associated with this measure are divided into two
components: costs to process and utilize the forest
residue, and burning costs avoided through use of this
technique. Depending on the relative values of these
components, a cost savings may be realized by the burner. A
reduction in fuel consumption may be obtained through
Xv
increased residue utilization. Studies have indicated that
a removal of approximately 16 tons of fuel per acre removed
would eliminate the need to burn about half of the area
scheduled for pile burning. The net avoided cost incurred
from this technique is estimated at $290 per acre not
burned.29 This avoided cost is associated with the fire
trail preparation ($40/acre) and the elimination of burning
(the burning cost for acres not burned is reduced to zero).
11.3.12.8 Reduction in Fuel Consumption. Two methods
are available to reduce the fuel consumption: burning under
increased fuel moisture conditions and use of aerial
ignition techniques.
11.3.12.9 Increased Fuel Moisture. For forestry
burning, increasing the fuel moisture content will decrease
emissions by decreasing the fuel burned. An increased fuel
moisture content tends to decrease the amount of heavy fuels
and duff which burn, thus decreasing the overall amount of
fuel burned as discussed in Chapter 9. Note that this is
the opposite effect that occurs in agricultural burning
where increased fuel moisture produces greater emissions.
11-25 September 1992
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TABLE 11-11,
COSTS OF INCREASING THE FUEL MOISTURE CONTENT
FOR FORESTRY BURNS"
Private Land
USFS Land
Acreage
Affected
Percent of
Total Annual
Acreage
SMP
Adaptability
Cost Due to
Rescheduling
Work Plan
Changes
Annual Delay
(Carry-over)
& Alternative
14,135
24.1%
Partial
Full
3,300
8.8%
Partial
Full
$347,000 $347,-000 $131,300 $131,300
Treatment
Avoided Cost
Total Costs
Cost/Acre
$1,140,000
$184,000
$1,671,000
$118
$0
$184,000
$531,000
$38
$323,000
$76,000
$530,300
$161
$0
$76,000
$207,300
$63
Reference 32,
11-26
September 1992
-------
Increasing the fuel moisture content is usually obtained by
removing lighter and drier fuels from the burn area.
Emission reductions up to 30 percent have been found using
this method although reductions for a given burn may vary
significantly from this value.30
The costs given in Table 11-11 are calculated for full
and partial smoke management program (SMP) adaptability and
result from removing the lighter fuels from the burn so that
the moisture content is at least 32 percent.
These data show a cost ranging from $38/acre for a full
SMP adaptable plan with no carryover or alternative
treatment required, to $16/acre for a partial SMP adaptable
plan with associated carryover and ^alternative treatment
costs.
11.3.12.10 Aerial Ignition. Use of aerial ignition
can reduce emissions by up to 20 percent.31 This is done by
achieving mass burn fire behavior which reduces fuel
consumption and emissions. There are two types of aerial
ignition: the DAID (Delayed Aerial Ignition Device) and
helitorch ignition.
The DAID method uses small plastic spheres dispensed
from a machine mounted to a small airplane or helicopter.
This technique is often used in areas having continuous
fuels or when a mosaic pattern is desired. Helitorch
ignition dispenses jellied gas dropped from a helicopter to
ignite forest brush or range fuels in steep or difficult
terrain.
Costs for helitorch ignition have been obtained while
costs for the DAID method have not been found. It is
expected however, that the cost differential between the two
techniques will not be large due to common components such
as helicopter or airplane rental and ground crew support.
The costs of helitorch ignition vary considerably with the
acreage on a given day and materials used. The costs
11-27 September 1992
-------
TABLE 11-12. COSTS OF HELITORCH IGNITION3
Cost Item
Helicopter & Crewb
Ground Crew0
Equipment0'*
Ignition Materials
Total cost
Cost/Acre
25 acres '
$1,500
1,320
300
110
$3,230
$120
50 acres
$1,500
1,700
420
220
$3,840
$77
100 acres
$1,500
2,280
590
4,810
$4,810
$48
* Source: Reference 33.
N--
b Typical reported cost for helicopter is $400 to $600 per
hour (minimum 3 hours) and includes the support crew of 2
or 3 people.
0 Ground support for fire control is typically 10 to 25
people. The size depends on area (perimeter), fuel
conditions, topography, surrounding vegetation, etc.
There is usually a "fire boss" crew of several people for
fire management and overview. Since perimeter fire
control is a primary function and concern of the ground
support crew, the crew size tend to increase accordingly.
Thus a multiplier of 1.4 is applied in all doubling of
acreage calculations.
d Cost of gasoline is assumed at $1.25/gallon; alum-gel
costs $2.25 per pound and requires 0.2 pounds/gallon of
gasoline. The aluma gel/gasoline mixture costs
approximately $1.70 per gallon. Typical ignition dosage
is 2 to 3 gallons per acre for broadcast burns, and $50-
$800/acre for piled burns averaging about $175/acre.
11-28 September 1992
-------
incurred from using helitorch ignition for three different
acreage conditions are given iii Table 11-12.
The cost per acre does decrease as the number of acres
increases but does not vary linearly due to fixed costs
incurred. A relationship between cost per acre and acres
ignited was derived based on trial and error and is given
below:
Cost/acre =86.5 exp (-0.0367 x total acres) +
42.5
This formula may be used to interpolate costs between the
three data points. For example, the cost per acre for
igniting 60 acres equals $52/acre as shown:
$52 = 86.5 exp (-0.0367 X 60) + 42.5 11.3.12.11
*\v
11.3.12.11 Methods Affecting the Emission Factor.
Several methods may be used that directly affect the
emission factor from forestry burns. These include:
placement of residue (i.e., broadcast, windrowed, or piled
burn); firing technique; and residual mop up.
11.3.12.11.1 Placement of Residue. Burning of residue
in piles will generally result in lower emissions than
burning in a broadcast or windrowed burn. However, emission
reductions from these three methods have not been
quantified. Cost data on broadcast versus pile burn§ have
been obtained on a $/acre basis, but, cost data for a
windrowed burn have not been found. However, the reader
must be cautioned that these cost data are taken from a 1978
US EPA report, and it is uncertain as to how these costs
have varied in succeeding years. The data indicate a cost
ranging from $50-$560/acre averaging about $l30/acre for
broadcast burns.
11.3.12.11.2 Firing Technique. Three firing
techniques for forestry burning are generally used. These
include: (l) a heading fire (fire moving with the wind),
11-29 - September 1992
-------
(2) a backing'fire (fire moving against the wind), and (3) a
flanking fire (fire moving at right angles to the wind)« An
additional technique called a spotfire exhibits all three
fire techniques. Emission reductions from firing techniques
have not been quantified and will likely vary significantly
depending on specific burn conditions. At present, no cost
data relating to these fire types has been found.
11.3.12.11.3 Rapid MOP-UP. Rapid mop-up of residual
smoke following the active phase of a fire can also reduce
emissions. Mop-up is typically conducted to minimize the
risk of new fires from smoldering fuels and to eliminate
smoldering emissions that may be carried down slope into
valley floors. Under typical conditions, mop-up within 8
hours can reduce emissions by about 10 percent, while mop-up
within 4 hours can reduce emissions by about 17 percent.34
The cost of mop-up will depend upon the time needed.
This in turn, will vary depending upon the amount of
suppression necessary, the potential for the fire to
smolder, and the type of burn (i.e., private vs. Federal).
The cost of rapid mop-up has been estimated based on the
above factors.
The cost of reducing mop-up time is primarily dependent
upon whether the burn is classified as having a high-smolder
potential. For these burn types, the costs are higher,
given that more effort is required to mop-up the burn in a
fixed amount of time. Table 11-13 contains cost data for
reducing mop-up times. Reductions in mop-up time were
assumed to be achieved through increased labor and equipment
rather than methods of improved productivity. Table 11-14
contains a summary of emission reduction techniques for
forestry burning. Each technique is listed in the left
column, along with corresponding cost data, if known.
Specific costs are then inserted into the spaces provided.
11-30 September 1992
-------
11.3.13 State Oversight
The cost element for this measure includes an increase
in coordination of effort between the State air quality
agency and the SMP administrators. The incremental costs to
the burner are assumed to be zero, while the costs to the
State include the costs of increasing the coordination of
effort between the respective agencies.
Costs have not been quantified for this measure. Table
11-15 contains a summary of the costs incurred for this
measure. The cost element is given in the left column and
cost data are to be inserted into the space provided.
11-31 September 1992
-------
TABLE 11-13. COST OF REDUCING MOP-UP TIMES
Estimated Additional
Cost of Rapid Mop-Up
($/acre)
% Reduction
in
Mop-Up Time
Mop-Up
Cost
($/acre)
USFS
Private
USFS
Private
All Units
0%
25%
50%
$102
$140
$202
$51
$72
$98
$0
$38
$100
$0
$21
$47
High Smolder-Potential Units
0%
25%
50%
$198
$234
$274
$135
$165
$200
$0
$36
$76
$0
$30
$65
Source;
Reference 34
11-32
September 1992
-------
TABLE 11-14. EMISSION REDUCTION TECHNIQUES FOR
FORESTRY BURNING
1.
'2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
Technique
No treatment
Manual removal
Chemical treatment
Mechanical methods
Explosives
Air curtain destructor
Reduction in pre-burn
fuel loading
Increased fuel moisture
Aerial ignition
Placement of residue
Rapid mop-up
Total
Cost Date
$206/acre (site
prep)
$166/acre (conifer
release)
$50-$60/acre
(aerial)
$70/acre
(backpack)
$135/acre
see text
$8-$30/ton
$290/acre
see text
see text
see text
see text
Cost to
Burner
$
$
$
$
$
$
$
$
S
$
$
$
TABLE 11-15. COSTS FOR STATE OVERSIGHT
Cost Element
Increase of coordination of effort
between agencies
State Cost
$
11-33
September 1992
-------
-------
11.4 REFERENCES
1. Cost/Benefit Analysis of Impact Reduction Alternatives
for Prescribed Burning in Western Oregon. Oregon
Department of Environmental Quality, Portland, OR.
1986. p. 1-3.
2. A Report on Prescribed Burning in Oregon, Oregon
Department of Forestry. 1990. p. 26.
3. Telephone conversation. Michael Sink, Pacific
Environmental Services, Inc. with John Core, Oregon DEQ
Salem, Oregon. May 30, 1991.
4. Direct Costs of Silvicultural Treatments on National
Forests, 1975-1978. USDA Forest Service Research Paper
WO-40. 1985.
5. Reference 1, p. 4-9.
v-
6. Telephone conversation. Michael Sink, Pacific
Environmental Services, Inc., with Jim Britton, Oregon
Department of Agriculture, Salem, OR. June 5, 1991.
7. Telephone conversations. Michael Sink, Pacific
Environmental Services, Inc., with John Russell, Bureau
of Land Management, Boise, ID, and Phil Range, Division
of Training, Boise Air Agency Fire Center.
8. Burning Grass Seed Fields in Oregon's" Willamette
Valley. The Search for Solutions. Oregon State
University Extension Service. Reprinted February 1989.
p. 18.
9. Reference 8, p. 67.
10. Reference 8, p. 67.
11. Reference 8, p. 67.
12. Reference 8, p. 67.
13. Reference 8, p. 67.
14. Reference 8, p. 67.
15. Reference 8, p. 68.
16. John J. Carroll, G.E. Miller, and J. F. Thompson. "The
Dependence of Open Field Burning Emissions and Plume
Concentrations on Meteorology, Field Conditions, and
Ignition Technique," Atmospheric Environment, Vol. 11,
1977. p. 1039.
11-34 September 1992
-------
17. Reference 8, p. 30.
18. Reference 16, p. 1039.
19. Reference 16, p. 1039.
20. Reference 2, p. 34.
21. Reference 2, p. 34.
22. Reference 2, p. 34.
23. Reference 2, p. 29.
24. Managing Completing and Unwanted Vegetation: Final
Environmental Impact Statement Characterizing
Management of Risk. USDA Forest Service. Pacific
Northwest Region. November 1988.
X"
25. Reference 2, p. 29.
26. Reference 1, p. 6-34.
27. Michael Lambert,. U. S. Forest Service. Efficiency and
Economy of an Air Curtain Destructor Used for Slash
Disposal in the Northwest. Paper N. 72-672 for
Presentation of 1972 Winter Meeting, America Society of
Agricultural Engineers, Chicago, IL. December 11-15,
1972. p. 1.
28. U.S. Environmental Protection Agency. Impact of
Forestry Burning Upon Air Quality. A State of the
Knowledge Characterization in Washington and Oregon.
EPA 910/9-78-052. October 1978. p 147. .
29. Reference 1, p. 1-9.
30. Reference 1, p. 6-8.
31. Reference 1, p. 6-24.
32. Reference 1, p. 6-15.
33. Reference 28, p. 145.
34. Reference 1, p. 6-50.
11-35 September 1992
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