United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park. NC 27711
May 1998
Air_
CPA !NTERIM
AIR QUALITY POLICY ON
WILDLAND AND PRESCRIBED FIRES
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and branches were available and dry). The effects of those fires on society and society's
management of fires have changed over time. The management response for decades has been to
suppress such fires because of the threat they posed to life and property where the wildlands and
urban communities interface, and the threat to natural resources in the wildlands. However, it
has become apparent that excluding fire from the wildlands has caused unintended negative
effects on wildland ecosystems. Therefore, the Federal land management agencies thoroughly
reviewed their fire management policies in 1995. The results of the review were presented in a
final report issued December 18, 1995, titled the Federal Wildland Fire Management Policy and
Program Review. Administrator Browner endorsed the principles, policies and recommendations
of the review in February 1996. As a result of the review, most Federal and some State, Indian
and private wildland owners and managers are allowing fire to play a more natural role in
managing their wildland ecosystems. Consequently, the acres of wildlands burned annually
increased in 1996 and 1997, and will continue to increase significantly for several years.
In the Interim Air Quality Policy on Wildland and Prescribed Fires, EPA urges State and
tribal air quality managers to collaborate with wildland owners and managers to mitigate the air
quality impacts that could be caused by the increase of fires managed to achieve resource
benefits. The EPA especially urges them to develop and implement at least basic smoke
management programs (SMP's) when conditions indicate that such fires will adversely impact
the public. The SMP's establish procedures and requirements for minimizing emissions and
managing smoke dispersion. The goals of SMP's are to mitigate the nuisance and public safety
hazards (e.g.. on roadways and at airports) posed by smoke intrusions into populated areas, to
prevent deterioration of air quality and NAAQS violations, and to address visibility impacts in
mandatory Class I Federal areas.
In exchange for States and tribes proactively implementing SMP's, EPA intends to
exercise its discretion not to redesignate an area as nonattainment if the evidence is convincing
that fires managed for resource benefits caused or significantly contributed to violations of the
daily or annual PM2 5 or PM10 standards. Rather, EPA will call on the State or tribe to review the
adequacy of the SMP in collaboration with wildland owners/managers and make appropriate
improvements to mitigate future air quality impacts.
The policy also addresses the treatment of fire emissions to meet other Clean Air Act
requirements, such as prevention of significant deterioration and conformity of Federal
activities with State implementation plans. If you have any questions during implementation of
this policy, please contact Sally L. Shaver, Director of the Air Quality Strategies and Standards
Division of the Office of Air Quality Planning and Standards. The staff contacts are Ken
Woodard at 919/541-5697 and Gary Blais at 919/541-3223.
Attachment
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cc: Air Division Director, Regions I-X
Air Programs Manager, Regions I-X
Tom Curran
Rich Ossias
John Seitz
Sally Shaver
Lydia Wegman
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TABLE OF CONTENTS
I. PURPOSE 1
II. SCOPE AND APPLICABILITY 2
III. BACKGROUND ... 3
A. Role of Fire in the Wildland 3
B. Changes in Fire Management Policy 4
C. Air Quality Considerations 5
D. Visibility Impairment . . 6
IV. DESCRIPTION OF POLICY 7
V. COLLABORATION AMONG LAND AND AIR QUALITY MANAGERS . 9
A. Land and Vegetation Management 10
1. Alternative Treatments . . . 10
a. Utilization and mechanical treatments . . . . . 10
b. Chemical treatments 11
c. Fire treatments . . . 11
2. Role of Federal Land Managers (FLM's) . 11
a. Federal land use and fire management planning 11
b. Evaluating environmental impacts .... . . . . . 13
3. Role of State and Other Public Land Managers . ... 14
4. Role of Private Land Managers . ... 14
5. Role of Indian Land Managers 15
6. Role of Air Quality Managers 15
B. Air Quality Management . 15
1. Role of State/Local Air Quality Managers 16
2. Role of Tribal Air Quality Managers 16
3. Role of Public Land Managers 16
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VI. SMOKE MANAGEMENT PROGRAMS (SMP's) 17
A. Authorization to Burn 18
B. Minimizing Air Pollutant Emissions 19
C. Smoke Management Components of Burn Plans 20
1. Actions to Minimize Emissions 20
2. Evaluate Smoke Dispersion 20
3. Public Notification and Exposure Reduction Procedures ... . 21
4. Air Quality Monitoring 22
D. Public Education and Awareness 22
E. Surveillance and Enforcement 22
F Program Evaluation 23
G. Optional Air Quality Protection 23
VII. ACCOUNTABILITY . . . .... 24
A. Role of State/Tribal Air Quality Managers .... ... 24
1. Wildfires . . . 24
2. Fires Managed for Resource Benefits ... . ... 25
B. Role of the Environmental Protection Agency . . .... . . 26
1. Impacts with a SMP .... .... 26
2. Impacts without a SMP 27
3. Interstate Transport of Smoke 27
C. Role of Wildland Owners/Managers . 28
VIII. DATA ON WILDLAND AND PRESCRIBED FIRES 28
IX. MEETING OTHER CLEAN AIR ACT REQUIREMENTS 30
A. Demonstrate Conformity of Federal Activities 30
B. Visibility/Regional Haze Requirements 31
C. Prevention of Significant Deterioration 31
DEFINITIONS 34
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LIST OF WHITE PAPERS AVAILABLE ON THE WORLD WIDE WEB
Background on the Role of Fire
What Wildland Fire Conditions Minimize Emissions and Hazardous Air Pollutants and Can
Land Management Goals Still Be Met?
Air Monitoring for Wildland Fire Operations
Emissions Inventories for SIP Development
Estimating Natural Emissions From Wildland and Prescribed Fire
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I. PURPOSE
This policy statement has been prepared in response to plans by some Federal, tribal and
State wildland owners/managers to significantly increase the use of wildland and prescribed fires
to achieve resource benefits in the wildlands.1 Many wildland ecosystems are considered to be
unhealthy as a result of past management strategies. The absence of fire effects has allowed plant
species (e.g., trees and shrubs) that would normally be eliminated by fires to proliferate,
vegetation to become dense and insect infestations to go unchecked. Wildland owners/managers
plan to significantly increase their use of fires to correct these unhealthy conditions and to reduce
the risk of wildfires to public and fire fighter safety. The largest increases are expected mainly
on Federal lands in western States in ecosystems where fires would naturally occur every few
years (35 years or less) if not suppressed. Fire has continued to be a management tool used by
many public and private wildland owners/managers in the southeastern States. However, Federal
land managers in the southeast also plan to significantly increase their use of fire above current
annual levels.
This policy statement integrates two public policy goals. (1) to allow7 fire to function, as
nearly as possible, in its natural role in maintaining healthy wildland ecosystems, and (2) to
protect public health and welfare by mitigating the impacts of air pollutant emissions on air
quality and visibility. This document provides guidance on mitigating air pollution impacts
caused by fires in the wildlands and the wildland/urban interface. It identifies the responsibilities
of wildland owners/managers and State/tribal air quality managers to work together to coordinate
fire activities, minimize air pollutant emissions, manage smoke from wildland and prescribed
fires managed for resource benefits, and establish emergency action programs to mitigate the
unavoidable impacts on the public. This policy is not intended to limit opportunities by private
wildland owners/ managers to use fire so that burning can be increased on publicly owned
wildlands. Thoughtful use of fire by private, public and Indian wildland owners/managers within
SMP's is promoted to maintain healthy wildland ecosystems. Neither is this policy intended to
'This document contains EPA policy and. therefore, does not establish or affect legal rights or obligations.
It does not establish a binding norm and it is not finally determinative of the issues addressed. In applying this
policy in any particular case, the EPA will consider its applicability to the specific facts of that case, the underlying
validity of the interpretations set forth in this memorandum, and any other relevant considerations, including any that
may be required under applicable law and regulations.
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imply that States/tribes should relax existing SMP's or limit a State's/tribe's ability to regulate
fires managed for resource benefits.
The EPA used a deliberative process involving a multi-stakeholder workgroup to develop
recommendations for this policy. The workgroup did not reach consensus on all of the issues
raised. The EPA addressed all of the recommendations and concerns raised by the stakeholders
to the extent possible. The multi-stakeholder workgroup also produced several "white papers"
on a number of topics previously identified in earlier drafts of the policy as Appendices to the
policy. These papers will be published as a separate document and can also be found on EPA's
TTN2000 website:
http://134.67.104.12/html/o3pmrh/pbissu.htm. and on the Western States Air Resources Council
(WESTAR) website: http://www.westar.org/proj_frame.html. A list of these papers is provided
in the Table of Contents.
II. SCOPE AND APPLICABILITY
The EPA does not directly regulate the use of fire within a State or on Indian lands. The
EPA's authority is to enforce the requirements of the CAA. The CAA requires States and tribes
to attain and maintain the NAAQS adopted to protect public health and welfare. This policy
recommends that States/tribes implement SMP's to mitigate the public health and welfare
impacts of fires managed for resource benefits. While SMP's will also mitigate nuisance smoke
intrusions, nuisance issues have been left for the individual air quality agencies to address.
This policy applies to all wildland and prescribed fires managed to achieve resource
benefits on public. Indian and privately owned wildlands. regardless of the cause of ignition
(e.g.. lightning, arson, accidental, land management decision, etc.) or purpose of the fire (e.g..
natural, resource management, hazard reduction, etc.).
Federal land management agencies sometimes manage naturally ignited fires to achieve
resource benefits. Planning for naturally ignited fires is obviously limited, but the agencies
require fire management plans to be included in land use plans for an area before a naturally
ignited fire can be managed for resource benefits. Fires ignited in areas without fire management
plans are unwanted or wildfires. The interface between this policy and the Natural Events
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Policy2 regarding ambient PM)0 concentrations caused by wildfires is addressed in section VII.
This policy does not apply to other open burning activities, such as burning at residential.
commercial or industrial sites; open burning of land clearing waste or construction debris. It also
does not apply to open burning of agricultural waste, crop residue or land in the USDA
Conservation Reserve Program. The EPA is working with the USDA Agriculture Air Quality
Task Force to develop equitable policies for emissions from activities that could be classified as
agricultural burning.
This policy addresses the impacts of air pollutant emissions from fires managed for
resource benefits on public health and welfare. The primary indicators of public health impacts
used are ambient air quality impacts above the NAAQS for fine particles with an aerodynamic
diameter less than or equal to a nominal 2.5 micrometers (PM2 5), and particles with an
aerodynamic diameter less than or equal to a nominal 10 micrometers (PM]0). There are both
24-hour (daily) and annual NAAQS for PM2 5 and PMI0. Emissions of nitrogen oxides (NOX).
VOC. and CO from fires can also impact the NAAQS for NO2. O-. and CO. However, the
actions required to reduce VOC and CO emissions are the same as those recommended in this
document to mitigate impacts on the PM25. and PMIO NAAQS. Emissions of NOX. on the other
hand, can increase under some of the burning conditions used to decrease emissions of other
pollutants.
The effects of fire emissions on the public welfare aspects of the NAAQS for PM are
addressed in terms of visibility impairment and regional haze. The policy also addresses the
treatment of fire emissions to meet other CAA requirements, such as prevention of significant
deterioration (PSD) and conformity with SIP's or TIP's.
III. BACKGROUND
A. The Role of Fire in the Wildlands
The role of fire in North American ecosystems has been undergoing change since people
began to play a more active role in managing their natural resources. Native Americans actively
used fire to alter vegetative patterns, to ease travel, or for hunting purposes. Prior to European
2See memorandum from Mary D. Nichols, Assistant Administrator for Air and Radiation to EPA Regional
Offices titled Areas Affected by PM1C Natural Events. May 30, 1996.
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settlement, fire played a natural role as a necessary disturbance phenomena, keeping fuel density
in check as well as insects and the diseases they carry, thereby maintaining North American
wildlands in a healthy state. After European settlement and the introduction of grazing herds of
cattle and sheep, and the practice of fire suppression, public land management agencies have
recognized that not allowing fire to play its natural role in our wildlands has had unintended
negative effects. When forests and grasslands are not allowed to burn naturally (lighting serving
as the principal source of ignition) the result can be heavy accumulation of dead vegetation
which provides fuel for unwanted fires (wildfires). Because of this unhealthy build-up of fuels,
the risk of catastrophic wildfires is much greater as evidenced by several recent fires in our
national forests and other publicly owned lands. These fires put firefighters and the general
public in danger while destroying millions of acres of forests and costing millions of dollars to
suppress. The lack of fire also has unintended ecological effects, leading to the loss of habitat for
rare species and the decline of ecosystems. Fire exclusion can lead to an alteration in natural
community types, and an important loss of biodiversity. Many plant and animal species are on
the decline because they exist in fire-dependent habitats that haven't burned in decades. This
situation has led to a rethinking of Federal land management and fire management policy.
B. Changes in Fire Management Policy
In 1995, a Federal Wildland Fire Management Policy and Program Review was
conducted in response to the unhealthy condition of our public wildlands, and the increase in
unplanned fires that occurred in 1987. 1988. 1992 and again in 1994. As a result of this review,
the five principal Federal fire/land management agencies [the Forest Service (FS) under the
Department of Agriculture; and the Bureau of Land Management (BLM), National Park Service
(NFS), Fish and Wildlife Service (FWS). and the Bureau of Indian Affairs (BIA) under the DOI]
agreed on need for several changes to existing fire/land management practices. Their
recommendations include the reintroduction of fire (allowing it to play its natural role) into
Federal land management programs in "an ongoing and systematic manner, consistent with
public health and environmental quality considerations." The goals of this change in land
management policy are to reduce unnatural fuel densities that contribute to increasing unplanned
fire hazards, and to restore wildland ecosystems to their healthy natural states. The Federal
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agencies previously mentioned began increasing the use of fire in their most vulnerable wildlands
in 1997. Annual treatment targets for all Federal land management agencies will be increased to
more than 5 million acres per year by 2005.
C. Air Quality Considerations
Burning wildland vegetation causes emissions of many different chemical compounds
such as small particles. Nox, CO and organic compounds. The components and quantity of
emissions depends in part on the types of fuel burned, its moisture content, and the temperature
of combustion. Complex organic materials may be absorbed into or onto condensed smoke
particles. Tests indicate that, on average, 90 percent of smoke particles from wildland and
prescribed fires are PM,0. and 70 percent are PM :5.
Historically, EPA's NAAQS for PM have tended to focus emission control efforts on
"coarse" particles-those larger than PM , 5. Before 1987, EPA's PM standards focused on
"Total Suspended Particles." including particles as large as 100 micrometers in diameter. The
EPA revised the standards in 1987 to focus control on PMIO in response to new science showing
that it was the smaller particles capable of penetrating deeply into the lungs that were associated
with the most adverse health effects. For comparison, a human hair is about 70 micrometers in
diameter.
The most recent review of health studies focused attention on the need to better address
the "fine'' fraction particles PM, 5. These more recent studies provide consistent and coherent.
"evidence that serious health effects (mortality, exacerbation of chronic disease, increased
hospital admissions, etc.) are associated with exposures to ambient levels of PM found in
contemporary urban airsheds even at concentrations below current U.S. PM standards" (Criteria
Document-U.S. EPA 1996a, p. 13-1). PM concentrations currently found in many communities
are associated with adverse health effects in the general population, including increased mortality
and morbidity, altered lung function, increased respiratory symptoms, aggravated respiratory and
cardiovascular disease. Sensitive sub-populations, such as children, the aged and those with
existing cardiopulmonary or infectious respiratory disease, may experience effects at lower levels
of PM than the general population, and the severity of effects might be greater. These studies are
the basis for the July, 1997 promulgation of new NAAQS for PM25, which are designed to
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protect public health, with an adequate margin of safety.
Fine particles are also a major cause of visibility impairment in such places as national
parks that are valued for their scenic views and recreation.
D. Visibility Impairment
Visibility conditions are affected by scattering and absorption of light by particles and
gases. The fine particles most responsible for visibility impairment are sulfates, nitrates, organic
compounds, soot and soil dust. Fine particles are more efficient per unit mass than coarse
particles at scattering light. Light scattering efficiencies also go up as humidity rises, due to
water adsorption on fine particles, which allow the particles to grow to sizes comparable to the
wavelength of light. There are distinct regional variations in visibility between eastern and
western States, due, to generally higher relative humidities in the East. Naturally occurring
visual range in the East ma)' be between 105 to 190 kilometers, while natural visual range in the
West is between 190 to 270 kilometers.
Visibility is an important public welfare consideration because of its significance to
enjoyment of daily activities in all parts of the country. Protection of visibility as a public
welfare consideration is addressed nationally through the secondary PM NAAQS which are
equivalent to the primary PM NAAQS. Visibility protection is particularly important in the 156
mandatory Class I Federal areas. "Areas of Great Scenic Importance." and is addressed for these
areas by the special provisions of Sections 169A and 169 B of the CAA.
The effects of smoke from wildland and prescribed fires on air quality will be discussed
throughout this document. The term air quality, as used in this document, refers to ambient
concentrations of pollutants (primarily PM in locations accessible to the general public), and.
where applicable, to impacts on visibility in mandatory Class I Federal areas. Thus, wherever
this document discusses the need for wildland owners/managers to consider the impacts of their
actions on air quality, this may include consideration of the effects of their actions on visibility in
mandatory Class I Federal areas.
Existing requirements to consider effects on visibility which are reasonably attributable
to a single nearby source or small number of sources are contained in the regulations published
by EPA in 1980 at 40 CFR 51.300 (Protection of Visibility). Additional regulations are currently
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being developed to address impairment of visibility that is more regional in its character and
origins ("regional haze"). This interim policy may be revised to be made consistent with the
regional haze rules when they become final.
Please refer to the white paper, "Background on the Role of Fire," for more complete
background information. See Section I to obtain a copy.
IV. DESCRIPTION OF POLICY
The EPA's policy regarding wildland and prescribed fires managed for resource benefits
is that owners/managers of public, private and Indian wildlands should collaborate with
State/tribal air quality managers (air regulators) to achieve their goals of: (1) allowing fire to
function in its natural role in the wildlands, and (2) protecting public health and welfare by
minimizing smoke impacts. The EPA urges air quality managers to participate in public land use
planning activities which involve selecting appropriate resource management treatments,
including the use of fire, and to help identify air quality criteria for fire management plans. Air
quality managers are urged to help evaluate the potential impacts of alternative resource
treatments and assure that air quality concerns (also visibility and regional haze concerns, where
appropriate) are adequately addressed in the public land use planning process. The)' are urged to
solicit information from private and Indian wildland owners/managers on plans to use fire for
resource management, to encourage them to consider appropriate alternative treatments, and to
assist them in evaluating the potential air quality impacts of alternatives to meet particular
management objectives.
Wildland owners/managers are urged to: (1) notify air quality managers of plans to
significantly increase their future use of fire for resource management. (2) consider the air quality
impacts of fires and take appropriate steps to mitigate those impacts. (3) consider appropriate
alternative treatments, (4) and participate in the development and implementation of State/tribal
SMP's.
The EPA will allow States/tribes flexibility in their approach to regulating fires managed
for resource benefits. They are not required to change their existing fire regulations if those
regulations adequately protect air quality. However, there are incentives for States/tribes to
certify to EPA that they have adopted and are implementing a SMP that includes the basic
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components identified in this policy. The main incentive is that, as long as fires do not cause or
significantly contribute to daily or annual PM2.5 and PM10 NAAQS violations, States/tribes
may allow participation by burners in the basic SMP to be voluntary and the SMP does not have
to be adopted into the SIP. Another incentive is the commitment by EPA to use its discretion not
to redesignate an area as nonattainment when fires cause or significantly contribute (see section
VII.B.) to PM NAAQS violations, if the State/tribe required those fires to be conducted within a
basic SMP. Rather, if fires cause or significantly contribute violations, States/tribes will be
required to review the adequacy of the SMP, in cooperation with wildland owners/managers, and
make appropriate improvements.
If States/tribes do not certify that a basic SMP is being implemented, no special
consideration will be given to PM violations attributed to fires managed for resource benefits.
Rather. EPA will call for a SIP revision to incorporate a basic SMP and/or will notify the
governor of the State or the tribal government that the area should be redesignated as
nonattainment. The SMP adopted in response to the SIP/TIP call must require mandatory
participation for greater than de minimis fires, and must be adopted into the SIP/TIP so that it is
Federally enforceable. Also, the SIP/TIP must meet all other CAA requirements applicable to
nonattainment areas.
Fire data requirements for SIP's/TIP's are addressed in section VIII of this policy.
Guidance for meeting CAA requirements to show conformity of Federal fire activities with
SIP's. to address visibility/regional haze impacts, and to address prevention of significant
deterioration of air quality are addressed in section IX.
The following are guiding principles for implementing this policy:
>• Air quality and visibility impacts from fires managed for resource benefits should be
treated equitably with other source impacts.
»• Land and vegetation management practices should be promoted that are best for wildland
ecosystems, yet protect public health and avoid visibility impairment.
> States/tribes should foster collaborative relationships among wildland owners/managers,
air quality managers and the public to develop and implement SMP's.
*• States/tribes will be allowed the flexibility (prior to measuring violations of the PM2 5 or
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PM,0 NAAQS attributable to fires managed for resource benefits) to decide when a SMP
is needed and how the program will be designed to prevent adverse air quality impacts.
This does not preclude wildland owners/managers from including smoke management
components in burn plans for fires they conduct in the absence of an applicable
State/tribal program.
*• All parties (wildland owners/managers, air quality managers and the public) are expected
to act in good faith and will be held accountable for implementing their respective parts
offireandSMP's.
V. COLLABORATION AMONG LAND AND AIR QUALITY MANAGERS
Wildland owners/managers and air quality managers can overcome the barriers to
achieving their goals of: (1) returning fire to its natural role in the wildlands-and (2) protecting
air quality and visibility, by working together toward those ends. Wildland owners/managers
should notify State/tribal air quality managers if they are planning to significantly increase the
use of fire to manage wildland resources. Air quality managers with Federal/State/local public
wildlands within their jurisdictions have a responsibility to participate in the public planning
processes conducted for the management of those publicly owned lands. To arrive at the best
choice of resource treatments and response to fire, it is essential that the air quality impacts of
planned land management activities are adequately addressed. Air quality managers, by
participating in the public land use planning process, can help select the scope of land uses; help
evaluate alternative management tools and help identify when fire is appropriate; and review-
projected air quality and visibility impacts. Air quality managers should also consult with private
wildland owners/managers to determine long-range resource management objectives and help
them evaluate the applicability of alternative treatments based on air quality and visibility
considerations.
Wildland owners/managers also have a responsibility to participate with the other
stakeholders and State/tribal air quality managers in developing rules and SMP's for fires
managed for resource benefits. Air quality managers that intend to develop or revise regulations,
plans or policies applicable to fires should solicit the early participation of all affected wildland
owners/managers in making those revisions.
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A. Land and Vegetation Management
Wildlands are managed by Federal, State and local public agencies (referred to in this
document as public land management agencies); tribal and BIA authorities; and private land
owners. The goals of public land management agencies vary, but are generally to develop,
maintain and enhance wildlife habitat; protect endangered plant and animal species; preserve and
protect cultural resources, scenic vistas and wilderness; provide for recreation; and to sustain
production of natural resources. The goals of private wildland owners/managers may be
sustained production of natural resources, preservation of wildlife habitat, improved grazing
conditions, etc. The goals of tribal wildland owners/managers are generally similar to public
land management agency goals, but may also include aspects of private land owners. Another
common goal of all wildland owners/managers is to minimize the potential for catastrophic
wildfires that could result from heavy accumulations of vegetative fuels.
1. Alternative Treatments
Wildland owners/managers may have an array of tools, including fire, that can be used to
accomplish land use plans, depending on the resource benefits to be achieved. Several factors
should be considered when selecting appropriate treatments. Those factors include the costs of
treatment, the environmental impacts (e.g.. air and water quality, soils, wildlife, etc.), and
whether fire must be used to meet management objectives. The best combination of treatments
are those that meet management goals with the most favorable environmental impacts at the most
reasonable costs.
a. Utilization and mechanical treatments
Mechanical treatments may be appropriate tools when management objectives are to
reduce fuel density to reduce a wildfire hazard, or to remove logging waste materials (slash) to
prepare a site for replanting or natural regeneration. On-site chipping or crushing of woody
material, removal of slash for off-site burning or biomass utilization, whole tree harvesting, and
yarding (pulling out) of unmerchantable material may accomplish these goals. Mechanical
treatments are normally limited to accessible areas, terrain that is not excessively rough, slopes of
40 percent or less, sites that are not wet. areas not designated as national parks or wilderness,
areas not protected for threatened and endangered species and areas without cultural or
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paleological resources.
b. Chemical treatments
When the management objective is to preclude, reduce or remove live vegetation and/or
specific plant species from a site, chemical treatments may be appropriate tools. Other potential
environmental impacts caused by applying chemicals must also be considered, however.
c. Fire treatments
Fire is one of the basic tools relied upon by wildland owners/managers to achieve a
myriad of management objectives in fire dependent ecosystems. Most North American plant
communities evolved with recurring fire and. therefore, are dependent on recurring fire for
maintenance. The natural fire return interval may vary from 1-2 years for prairies, 3-7 years for
some long-needle pine species, 30-50 years for species such as California chaparral, and over one
hundred years for species such as lodgepole pine and coastal Douglas-fir. When one
management objective is to maintain a fire dependent ecosystem the effects of fire cannot be
duplicated by other tools. In such cases, fire may be the preferred management tool even when
other treatments may be equally effective for meeting other objectives. Fire can also be used to
reduce heavy fuel loads and prevent catastrophic wildfires.
When fire is the chosen management tool, a combination of treatment methods may be
the best approach to achieving the desired resource benefits with minimum air quality impacts.
Combinations of treatments may include mechanically pretreating an area to thin the fuel load
prior to the use of fire.
2. Role of Federal Land Managers (FLM's)
The major Federal agencies with land management responsibilities include the USDA FS,
the DOI NFS. and FWS. BLM. and BIA. These agencies manage national parks, forests,
monuments, wilderness areas, prairie grasslands, sea shores, Indian lands, wildlife refuges, etc.
The Department of Defense and Department of Energy also manage millions of acres of Federal
land at military bases, training centers and for other purposes.
a. Federal land use and fire management planning
Federal land use planning is an open process for setting land use and management goals
and objectives. The planning process is designed for public participation, and must comply with
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NEPA. State/tribal air quality managers are given the opportunity to participate in land use
planning as part of normal intergovernmental consultation procedures. It is important for air
quality managers to participate in public land use planning decisions to ensure that air quality
concerns are adequately addressed. Through the public participation process, issues are identified
and alternatives are discussed regarding methods for implementing land management activities
such as trail building, improvement of wildlife habitat, timber harvesting, use of fire, etc. The
environmental impacts of these activities are analyzed including, among other things, impacts on
cultural resources, wildlife, vegetation, soils, riparian areas, wetlands, water quality, air quality.
and visibility. Consideration of the air quality impacts of land management activities is essential
to arriving at the best choice of treatments and response to fire.
Two or more levels of land use planning are conducted by FLM's to achieve management
goals. First, broad scale and long-range land use plans must be developed for administrative
units (e.g.. forests, parks, refuges, sanctuaries, etc.). The land use plan identifies the scope of
actions and goals for the lands and resources administered, and typically covers a 10 to 15-year
period.
In addition to land use plans, there are other shorter term (typically 1-5 years) planning
efforts where decisions are made concerning specific activities and programs, including the use
of fire to achieve resource benefits. These may include programmatic plans, such as FMP's. or
specific project plans.
The FMP's are strategic plans that define how wildland and prescribed fires will be
managed to meet land use objectives. The FMP's must contain prescriptive criteria which are
measurable and will guide selection of appropriate management actions in response to fires. The
criteria can relate to suppression actions or describe when fire can be managed to gain resource
benefits. This allows the use of a full range of appropriate management responses to fire, which
may include: full suppression of a wildland fire; suppression on part of a wildland fire while
allowing another portion of the fire to continue playing a natural ecological role and achieve
resource benefits; or the use of prescribed fire.
Project plans are strategic plans to accomplish specific actions and goals established in a
land use plan. Project plans may involve decisions regarding trade-offs between using
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mechanical, chemical and fire treatments. When projects include fires treatments, burn plans are
also required. Burn plans are operational plans for managing specific fires. Burn plans prepared
by FLM's should include smoke management components to minimize fire emissions and
mitigate air quality impacts.
b. Evaluating environmental impacts
Federal agencies evaluate the environmental impacts of the tools used for resource
management on publicly owned lands using NEPA. They generally consider the impacts on,
among other things, plant and animal species in the area, aquatic life, cultural resources, soil
conditions, riparian areas, wetlands, water quality, air quality and visibility. Such analyses
should be undertaken at both the individual project planning level and at the regional planning
level if warranted by the extent of similar activities over a large area.
The impacts of resource management activities, particularly fire, on air quality can vary
significantly by region. The impacts can be strongly affected by meteorology: existing air
quality; the size, timing and duration of the activity; and other activities occurring in the same
airshed at the same time. State/tribal air quality managers can provide technical assistance with
evaluating potential air quality impacts, thus aiding FLM's in their selection of tools and
evaluation of the environmental impacts.
Air quality and visibility impact evaluations of fire activities on Federal lands should:
include recent historic (e.g. 10 years) and projected (life of the plan) annual or
seasonal emissions from wildland and prescribed fires. Emission projections
should be based on estimates provided by wildland owners/managers of acres
burned, pre-burn fuel loading by vegetation type and consumption.
be related to analyses of cumulative impacts of fires on regional and subregional
air quality, when possible.
identify applicable regulations, plans or policies (e.g. burn plans, authorization to
burn, conformity, etc.),
identify sensitive receptors,
include description of planned measures to reduce smoke impacts,
identify the potential for smoke intrusions into sensitive areas, and model air
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quality and visibility impacts, when possible,
describe ambient air monitoring plans, when appropriate.
3. Role of State and Other Public Land Managers
State and local land management agencies manage publicly owned lands similar to
Federal lands. These agencies differ from agency to agency, but can include forestry,
conservation, park service, or fish and game agencies, as well as State or local fire protection
agencies. Many agencies prepare long-range land use plans as well as project specific plans. The
FMP's, similar to those prepared by Federal agencies, may also be prepared. Public land
management agencies generally assess the environmental impacts of proposed projects, such as
fires managed for resource benefits, although the impacts evaluated vary from agency to agency.
Some State/local wildland managers also have responsibilities for private lands. Such
responsibilities may include using fires and other fuels reduction programs aimed at reducing the
potential for wildfires in the wildland/urban interface.
Land use planning for State and locally owned wildlands. although somewhat different
from the Federal process, also requires preparation of written documents that are subject to
public review. State/local wildland managers should notify air quality managers of long-range
plans to use fire for resource management. They should consider alternative management tools
and evaluate the potential air quality impacts of fires. State/local wildland managers should also
participate in the development of State SMP's.
4. Role of Private Land Managers
Private \vildland owners/managers may or may not prepare written land use or project
plans depending on the organization and the size of the property. States/tribes may or may not
require written plans, but activities on privately owned lands must meet all applicable State and
Federal environmental requirements. State requirements include any specific SIP requirements
applicable to private land owners which are designed to ensure that the State complies with CAA
requirements. Private land owners/managers should provide information to the State on long-
range plans to use fire for resource management and should participate in the development of
State SMP's.
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5. Role of Indian Land Managers
Land use plans for Indian wildlands are not subject to review by the general public and
are not subject to State regulations. Activities on Indian lands must meet the requirements of the
CAA and the TIP, however, if one has been adopted. It is important that Indian wildland
managers consider alternative vegetation management tools and consider the air quality impacts
of the management practices chosen both on and off of Indian lands. They are encouraged to
collaborate with other near-by wildland owners/managers and air quality managers on regional
SMP's to assure that fires managed for resource benefits will not cause adverse air quality
impacts at sensitive receptors in the region.
6. Role of Air Quality Managers
State air quality managers which have publicly owned wildlands within their jurisdiction,
have a responsibility to participate in the public planning process conducted for those lands to be
assured that air quality concerns are adequately addressed and they can meet the goals of their
SIP's. They can participate in selecting the scope of land uses, identify air quality issues, and
participate in evaluating and selecting alternative resource management tools. They can also
participate in identifying basic air quality criteria for fire prescriptions. To accomplish this, air
quality agencies should heed solicitations of public participation from land managers and contact
public land management agencies within their jurisdiction
State/tribal air quality managers should also encourage private and Indian wildland
owners/managers to consider alternative treatments and help them evaluate the potential air
quality impacts of alternatives to meet particular management objectives.
B. Air Quality1 Management
State/tribal air quality managers are responsible for adopting plans and rules sufficient to
attain and maintain national and State air quality standards, prevent significant deterioration of
air quality, remedy existing visibility impairment and prevent future impairment in mandatory
Class I Federal areas caused by manmade sources of pollution. This is accomplished mainly by
developing SIP's and TIP's. The SIP's/TIP's include all programs and rules required by the CAA
to meet and assure maintenance of Federal standards. The SIP's/TIP's are frequently amended as
State/tribal rules are revised and new rules are adopted to meet changing CAA requirements.
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The EPA has the authority to adopt and implement Federal Implementation Plans (FIP's) to
address air quality protection in areas where States or tribes do not adopt plans.
1. Role of State/Local Air Quality Managers
The SIP's are developed in an extensive public process involving workshops and public
hearings in which all stakeholders are invited to participate in developing the technical
components of the plans including: (1) emission inventories; (2) modeling analyses; (3)
attainment demonstrations; (4) transportation and general conformity emission budgets; (5)
analyses of air quality data; and (6) control strategy development. State/local air quality
managers should solicit information on the planned use of fire for resource management from all
wildland owners/managers, just as they obtain information on other emission sources within their
jurisdiction, when fires are expected to significantly impact air quality. Air quality managers
should also work with adjacent States to mitigate potential impacts from interstate transport of
smoke.
2. Role of Tribal Air Quality Managers
Eligible tribes may develop TIP's to administer CAA requirements on Indian lands. The
CAA recognizes tribal governments as the most appropriate parties to regulate the environment
on Indian lands and grants EPA the authority to approve tribal programs. The EPA has
developed strategies for Federally implementing CAA requirements if tribes do not adopt TIP's.
Tribal air quality managers should solicit information on the planned use of fire for
resource management within their jurisdiction and the potential for air quality impacts on or from
adjacent jurisdictions. They are encouraged to collaborate with other near-by air quality managers
to develop regional SMP's which assure that fire activities will not cause adverse air quality-
impacts at sensitive receptors in the region.
3. Role of Public Land Managers
Public land managers have the responsibility to participate with the other stakeholders
and air quality managers in developing SIP's. Public land managers, as experts in what is needed
to meet land use and other environmental objectives, need to provide information on the areas
that are to be treated with fire, air pollutant emissions estimates, and assistance in developing
programs to track emissions, monitor air quality and visibility, and mitigate air quality impacts.
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The FLM's of mandatory Class I Federal areas must participate in the development of
SIP's for regional haze and visibility impairment. Congress gave FLM's a key consulting role in
the administration of visibility protection and "affirmative responsibility to protect air quality
related values (including visibility) in mandatory Class I Federal areas." [See section 165 of the
CAA.]
VI. SMOKE MANAGEMENT PROGRAMS (SMP's)
The SMP's establish a basic framework of procedures and requirements for managing
smoke from fires managed for resource benefits and are typically developed by States/tribes with
cooperation and participation by wildland owners/managers. The purposes of SMP's are to
mitigate the nuisance and public safety hazards (e.g., on roadways and at airports) posed by
smoke intrusions into populated areas; to prevent deterioration of air quality and NAAQS
violations: and to address visibility impacts in mandatory Class I Federal areas. Some strong
indications that an area needs a SMP are: (1) citizens increasingly complain of smoke intrusions;
(2) the trend of monitored air quality values is increasing (approaching the daily or annual
NAAQS for PM-, 5 or PM10) because of significant contributions from fires managed for resource
benefits; (3) fires cause or significantly contribute to monitored air quality that is already greater
than 85 percent of the daily or annual NAAQS for PM25 or PM10; or (4) fires in the area
significantly contribute to visibility impairment in mandatory Class I Federal areas.
If a State/tribe determines that a SMP is needed, they can adopt any type of program they
believe will prevent NAAQS violations and address visibility impairment. For example, general
fire regulations may establish basic parameters, such as wind speed, direction, location and
distance to sensitive receptors, etc., within which fires can be ignited or naturally ignited fire can
be allowed to continue to burn. States/tribes may allow wildland owners/managers to voluntarily
notify' them of fire plans or may require prior authorization. They may also exempt de minimis
fires (fires that will cover fewer than X acres or consume less than Y tons of fuel, as established
by the State/tribe) from meeting the regulations. Such regulations leave much discretion to
wildland owners/managers as to when to ignite fires, and what management strategy to follow
with naturally ignited fires. States/tribes may exercise enforcement authorities when wildland
owners/managers are found to have ignited the fire outside of the parameters of the rule, or not to
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have appropriately responded to air quality impacts caused by naturally ignited fires.
General fire regulations may be adequate for areas where fires managed for resource
benefits rarely cause or contribute to air quality problems. However, when plans to use fire on a
large scale could cause significant air quality impacts, or several wildland owners/managers
within an airshed are expected to use fires concurrently, a more structured SMP requiring
cooperation and coordination of fire activities may be required to minimize emissions and
mitigate the air quality impacts.
State/tribal air quality managers, public wildland managers, private and Indian wildland
owners/managers, and the general public should collaborate in the development and
implementation of State/tribal SMP's. The State/tribal air quality manager must certify in a letter
to the Administrator of EPA that at least a basic program has been adopted and implemented in
order to receive special consideration under this policy of air quality data resulting from fire
impacts, as explained in section VII. The SMP does not have to be incorporated into the SIP/TIP
or be Federally enforceable, however. The following describes the basic components (A F) of a
certifiable SMP. There is considerable latitude within the components for individual State/tribal
preferences.
A. Authorization to Burn
The SMP should include a process for authorizing or granting approval to manage fires
for resource benefits within a region. State, or on Indian lands and identify a central authority
responsible for implementing the program. The process may be as simple as receiving
applications for permission to burn and granting approval via telephone or facsimile. The SMP
central authority must review fire applications, consult with the applicants, if necessary, and
promptly make burn/no burn decisions. When authorizing a fire, the authority should consider
all open burning activities (land clearing and construction wastes, agricultural wastes, etc.)
allowed within an airshed. The central authority should strive to treat public and private
wildland owners/managers equitably when authorizing fires. Neighboring States/tribes are
encouraged to create partnerships to coordinate fire projects when inter-jurisdictional impacts are
expected, so as to meet air quality and fire management objectives. Fire emissions should be
minimized and the air quality impacts should be mitigated regardless of political boundaries.
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States/tribes may or may not require written burn plans for de minimis fires, especially if
the central authority records pertinent fire information. However, written burn plans are strongly
recommended for greater than de minimis fires. Burn plans should be prepared by the wildland
owners/managers. The central authority should assist private land owners that cannot prepare
their own plans. When written burn plans are required, especially for fires on publicly owned
lands, they should include such information as the:
location and description of the area to be burned,
personnel responsible for managing the fire,
type of vegetation to be burned.
area (acres) to be burned.
amount of fuel to be consumed (tons/acre),
fire prescription including smoke management components (discussed below).
criteria the fire manager will use for making burn/no burn decisions.
safety and contingency plans addressing smoke intrusions.
The central authority's criteria for authorizing fires should be based on existing air quality
and the ability of the airshed to disperse emissions (e.g.. meteorological conditions) from all
burning activities on the day of the burn. For fires lasting longer than one day. predicted
meteorological conditions for several days should be considered to avoid aggravating existing
problems. Persons receiving authorization to ignite fires must comply with all applicable local.
State, tribal and Federal requirements. Persons responsible for managing greater than de minimis
fires should be adequately trained in fire and smoke management. Fire managers should be
required to follow the authorized burn plan or explain why it was necessary to deviate from the
plan.
B. Minimizing Air Pollutant Emissions
The SMP should encourage wildland owners/managers to consider the alternative
treatments discussed in section V.A.I., above. Public land managers typically consider and
evaluate alternative treatments that may achieve management objectives, their costs and the
environmental impacts of each method. States/tribes should assist private land owners to also
identify economically feasible treatments that will meet their objectives with minimum air
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pollutant emissions. When the use of fire is selected as the best means to accomplish
management goals, there are several ways to reduce emissions from a single fire. The
approaches fall into four categories and their applicability varies by fuel type, (1) minimize the
area burned. (2) reduce the fuel loading in the area to be burned, (3) reduce the amount of fuel
consumed by the fire, (4) minimize emissions per ton of fuel consumed. These emission
reduction techniques rely almost exclusively on reducing the amount of fuel consumed by a
particular fire. The excluded fuels could be consumed by a subsequent fire, however, unless they
are removed from the area or biologically decompose. Also, generally these techniques cannot
be used to reduce emissions from naturally ignited fires.
Emission reduction techniques are discussed further in the white paper "What Wildland
Fire Conditions Minimize Emissions and Hazardous Air Pollutants and Can Land Management
Goals Still be Met0" See Section I to obtain a copy.
C. Smoke Management Components of Burn Plans
When burn plans are required they should include the following smoke management
components.
1. Actions to Minimize Fire Emissions
The burn plan should document the steps taken prior to the burn and actions that will be
taken during and after the burn to reduce air pollutant emissions. This includes measures that
will be taken to reduce residual smoke, such as rapid and complete mop-ups. mop-ups of certain
fuels, etc.
2. Evaluate Smoke Dispersion
The central authority should evaluate dispersion conditions prior to authorizing fires.
Burn plans should evaluate potential smoke impacts at sensitive receptors and time fires to
minimize exposure of sensitive populations and avoid visibility impacts in mandatory Class I
Federal areas. The plan should identify the distance and direction from the burn site to local
sensitive receptor areas and to regional/interstate areas where appropriate. Fire prescriptions
submitted prior to the day of the fire must specify minimum requirements for the atmospheric
capacity for smoke dispersal such as minimum surface and upper level wind speeds, desired wind
direction, minimum mixing height, and dispersion index. It may be necessary to purchase
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meteorological services from private companies if they are not available from the National
Weather Service.
3. Public Notification and Exposure Reduction Procedures
The plan should identify actions that will be taken to notify populations and authorities
(e.g., local air quality managers) at sensitive receptors, including those in adjacent jurisdictions,
prior to the fire. The plan should also identify contingency actions that will be taken during a
fire to reduce the exposure of people at sensitive receptors if smoke intrusions occur. The central
authority should perform these functions, if needed, for some private land owners. Appropriate
short-term (less than 24-hour) contingency actions may, among other things, include:
Notifying the affected public (especially sensitive populations) of elev?ted pollutant
concentrations.
Suggesting actions to be taken by sensitive persons to minimize their exposure (e.g.,
remain indoors, avoid vigorous activity, avoid exposure to tobacco smoke and other
respiratory irritants).
Providing clean-air facilities for sensitive persons.
Halting ignitions of any new open burning that could impact the same area.
Analyzing the fire situation and identifying alternative management responses upon
becoming aware that a fire is out of air quality prescription with regard to the air quality
criteria. (Federal land management agencies perform a Wildland Fire Situation
Analysis)3.
Consulting State/tribal air quality managers regarding appropriate short-term fire
management response to abate verified impacts.
Implementing management responses that will mitigate the adverse impacts to public
J A Wildland Fire Situation Analysis (WFSA) is a decision-making process that evaluates alternative fire
management strategies considering fire fighter and public safety, risk to property and resources, fire fighting
resources available, land management objectives, and environmental, social, economic and political constraints.
The environmental and social constraints considered include, among other things, how air quality and/or visibility
will be affected at sensitive receptors by each alternative fire management strategy. The positive, neutral or
negative effects of each alternative on the criteria above are weighed to select the appropriate management
response to the fire. Therefore, while mitigating air quality and visibility impacts must be considered by the FLM
when managing a fire that is not within a prescription, they are just two of several important criteria evaluated.
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health.
Reporting the steps taken to mitigate adverse impacts to the public and appropriate
State/tribal agencies after they have been completed.
4. Air Quality Monitoring
The plan should identify how the effects of the fire on air quality at sensitive receptors,
and visibility in mandatory Class I Federal areas will be monitored. The extent of the monitoring
plan should match the size of the fire. For small fires, visual monitoring of the direction of the
smoke plume and monitoring nuisance complaints by the public may be sufficient. Other
monitoring techniques include posting personnel on vulnerable roadways to look for visibility
impairment and initiate safety measures for motorists; posting personnel at other sensitive
receptors to look for smoke intrusions; using aircraft to track the progress of smoke plumes; and
continued tracking of meteorological conditions during the fire. For large fires expected to last
more than one day. locating real-time PM monitors at sensitive receptors may be warranted to
facilitate timely response to smoke impacts. If needed, the central authority may perform these
monitoring functions for some private land owners.
For additional information on monitoring wildland fire impacts see the white paper "Air
Monitoring for Wildland Fire Operations." See Section I to obtain a copy.
D. Public Education and Awareness
The SMP should establish criteria for issuing health advisories when necessary, and
procedures for notifying potentially affected populations, including those in adjacent
jurisdictions, of planned fires. A program should be implemented to explain the use and
importance of fire for ecosystem management, the implications to public health and safety, and
the goals of the SMP. Wildland and air quality managers should work with the press to
announce pre-fire health advisories, and post-fire results including such things as the
management objectives met; smoke intrusions observed, and/or successful minimization of air
quality impacts.
E. Surveillance and Enforcement
The SMP should include procedures to ensure that wildland owners/managers will
comply with the requirements of the SMP. Fire managers must follow the burn plan, including
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the fire prescription and smoke management components, or explain any deviations from the
plan. Memorandums of understanding may be used to specify the responsibilities of each
State/tribal agency in implementing the SMP.
F. Program Evaluation
The SMP should provide for periodic review by all stakeholders of its effectiveness and
revision of the program as necessary. The effectiveness review should be based on observations
such as reports of smoke intrusions, nuisance complaints, and monitored air quality impacts.
Post-burn reports should be required for fires that exceed their air quality prescription and/or
fires that cause smoke impacts at sensitive receptors. Post-burn reports for escaped fires should
describe the incident, describe the contingency plan implemented, and provide recommendations
to prevent future smoke related problems.
State/tribal SMP's should include procedures for re-evaluating the effectiveness of rules
and regulations every 3 to 5 years. Such procedures should involve all the original participants
(e.g.. wildland owners/managers, air quality managers, the public, etc.) and should review the:
Acres of fires managed for resource benefits planned for the next 5 years.
Need to expand the scope of the program to include authorization of other open
burning.
Need for changes in the SMP
G. Optional Air Quality Protection
The following components are not required in a basic SMP. but States/tribes may adopt
more stringent SMP's or include additional smoke management requirements. For example,
"special protection zones" may be established to provide better protection against smoke impacts.
Special protection zones could be buffers (e.g., 10-25 miles) around wildland/urban interface
areas, nonattainment areas, or mandatory Class I Federal areas. Additional requirements for
burns within a special protection zone may include no burning if high pollution levels already
exist in the area. Also, special protections may only be required for burns that will last overnight,
for multi-day burns or burns during specific seasons.
States/tribes may also establish "performance standards" that would trigger
implementation of additional smoke management requirements if exceeded in an area. The
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performance standards could set limits on the frequency and intensity (e.g.. hours/day, PM
concentration, visibility impairment) of smoke intrusions. Implementation of performance
standards may require real-time monitoring of air quality. Additional requirements for fires after
the performance standards are exceeded may include better dispersion parameters (e.g., increased
wind speed, mixing height, dispersion index, etc.).
VII. ACCOUNTABILITY
A. Role of State/Tribal Air Quality1 Managers
High PM concentrations attributable to fires managed for resource benefits are valid air
quality data that can be used to determine the attainment status of the area represented by the data
for both the daily and annual NAAQS. State/tribal air quality managers are responsible for
monitoring citizen complaints and air quality trends attributable to fires to determine when a
SMP is needed to minimize emissions and mitigate air quality impacts. Air quality managers
should initiate the collaborative process needed to develop and adopt regulations for a SMP. If
the State/tribal air quality manager certifies in a letter to the Administrator of EPA that at least a
basic program (described in section VI) has been adopted and implemented, special consideration
will be given under this policy to air quality data resulting from fires managed for resource
benefits.
1. Wildfires
High PM concentrations attributable to wildfires (unwanted wildland fires) can be treated
as due to a natural event under EPA's Natural Events Policy. The Natural Events Policy
provides that when areas violate the PM10 NAAQS due to a natural event. EPA will: (1) exercise
its discretion, under section 107(d)(3) of the CAA, not to redesignate areas as nonattainment if
the State develops and implements a plan to respond to the health impacts of natural events; and,
(2) redesignate nonattainment areas as attainment by applying appendix K. on a case-by-case
basis, to discount [ambient air quality] data in circumstances where an area would attain but for
exceedances that result from uncontrollable natural events. The elements of a State/tribal action
plan to respond to the health impacts of natural events are described in the Natural Events policy
statement. The EPA plans to revise the Natural Events Policy to also cover PM2 5 NAAQS
violations.
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2. Fires Managed for Resource Benefits
High PM concentrations attributable to fires managed for resource benefits will be given
special consideration under this policy, as described in section VII.B., if the State/tribe has
certified to EPA that it is implementing a basic SMP. States/tribes should flag monitored values
influenced by fires when submitting the data to EPA's Atmospheric Information Retrieval
System. They must also document the basis for flagging the data. Supporting information could
include the location of fires relative to the monitor, meteorological data such as wind speed and
direction, filter analyses indicating heavy carbon deposits, the sample date (collected during the
fire season), and the absence of other carbon sources during that period, among other things. The
documentation should address the possible influence of other carbon sources such as wood-fired
boilers, residential wood combustion and wildfires. The type and amount of documentation
should be sufficient to demonstrate that fires managed for resource benefits caused flagged
values to be above the level of the annual NAAQS. The documentation should be made
available to the public for review. [For example, newspaper announcements, periodic air quality
reports, distribution at public meetings.]
When smoke intrusions cause high PM concentrations, air quality managers have two
goals: (1) to reduce immediate impacts on public health, and (2) to take appropriate steps to
mitigate future impacts. To meet these goals, air quality managers must contact the wildland
owner/manager responsible for the fire(s) to determine the cause of the impacts. The air quality
manager should verify that contingency actions to reduce exposure are being implemented, and
determine whether, (i) the fire was authorized, (ii) a burn plan (including the smoke management
components) was followed, (iii) the prescription failed and why.
If requirements of the SMP were not met, the State/tribe can exercise various
enforcement authorities to address the problem. If the fire manager complied with the SMP, the
adequacy of the requirements should be reviewed. If air quality data are frequently flagged as
resulting from failure of the smoke management components of the burn plan, EPA will call on
the State/tribe to work with wildland owners/managers to improve future burn plans and the
SMP. When a fire managed for resource benefits breaks out of its fire prescription, and cannot
be returned to the prescription, the fire manager will treat it as a wildfire for the purposes of
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suppression. However, any resulting high PM concentrations must continue to be addressed
under this policy, and the data can not be treated as due to a wildfire natural event.
B. Role of the Environmental Protection Agency
1. Impacts with a SMP
If fires managed for resource benefits cause or significantly contribute to violations (see
definition) of the daily or annual PM2 5 or PM,0 NAAQS. the State/tribe must submit the
following documentation to EPA to avoid a SIP/TIP call or redesignation of the area to
nonattainment:
>• Evidence supporting the finding that flagged air quality values were due to fires managed
for resource benefits,
> Evidence that the fires were subject to a certified State/tribal SMP.
The State/tribe may consider that such fires caused or significantly contributed to
violations of the daily NAAQS if 25 percent of all the PM concentrations that are above the level
of the daily NAAQS. have been flagged as being due to fire impacts.
The State/tribe may consider that such fires caused or significantly contributed to
violations of the annual NAAQS if the sum of the measured concentrations for all days flagged
as due to fires, divided by the total number of sample days (fire days plus non-fire days) is greater
than or equal to 25 percent of the annual NAAQS (i.e., 4 ug/m3 for PM25 or 12 ug/m3 for PM10).
If the evidence is convincing. EPA will exercise its discretion under section 107(d)(3)
not to redesignate the area as nonattainment. Rather, following the first NAAQS violation based
on 3 calendar years of PM air quality data. EPA will call on the State/tribe to review the
effectiveness of the SMP in collaboration with wildland owners/managers and make appropriate
improvements to mitigate future air quality impacts. The same procedure will be followed if a
second NAAQS violation occurs the following year. If fires cause or significantly contribute to a
third consecutive NAAQS violation, EPA will call for the SMP to be made part of the SIP/TIP
and be Federally enforceable.4 If the area was designated nonattainment previously, EPA will
4For example, the first violation of the PM10 NAAQS may be determined using air quality data for calendar
years 1997-1999. Subsequently, 1998-2000 data for the same area could show a second violation, and data for
j999-2001 could identify a third violation for the area.
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also call on the State/tribe to review the effectiveness of the SMP and make appropriate
improvements.
2. Impacts Without a SMP
If a certified SMP has not been implemented, EPA will not give special consideration to
the high PM concentrations attributed to fires managed for resource benefits that cause or
significantly contribute to: (1) violations of a PM, 5 or PM10 NAAQS, (2) visibility impairment in
mandatory Class I Federal areas, or (3) failure to achieve reasonable progress toward the national
visibility goal. Rather, EPA will call for adoption of the basic SMP, described in section VI, as
part of the SIP/TIP for PM and visibility. The EPA will also notify the governor of the State or
the tribal government that the area should be redesignated as nonattainment The SMP adopted
in response to the SIP/TIP call must require mandatory participation for greater than de minimis
fires, must be adopted into the SIP/TIP, and must be Federally enforceable. The SIP/TIP will
also have to meet all other CAA requirements applicable to nonattainment areas.
3. Interstate Transport of Smoke
Several key provisions of the CAA address interstate pollutant transport. Section
110(a)(2)(D) provides that a SIP must contain provisions preventing subject sources from
contributing significantly to nonattainment problems or interfering with maintenance in any other
State. That section also prohibits interference with any SIP required measures under part C to
prevent significant deterioration or to protect visibility. Section 169A authorizes EPA to
promulgate regulations requiring states that "ma)' reasonably be anticipated to cause or contribute
to" visibility impairment in mandatory Class I Federal areas to include in their SIP's measures
necessary to eliminate or reduce such impairment. Section 126 provides that, in response to
petitions from government entities regarding significant pollutant transport, EPA may prescribe
certain corrective measures. Also, sections 169B, 176A and 184 contain provisions for
cooperatively addressing interstate pollution problems by establishing interstate transport regions
and commissions to address region wide pollution and visibility concerns. The EPA
promulgated a final rule, pursuant to the requirements of section 301(d) of the CAA that
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authorizes eligible Indian tribes to also implement these provisions.5 If fires managed for
resource benefits in one State (or on Indian lands) cause or significantly contribute to NAAQS
violations in another State (or on Indian lands), EPA is authorized to take action under section
110(k)(5) of the CAA to address the problem. If, among other things, EPA finds that a SIP/TIP
is substantially inadequate to attain or maintain the NAAQS, it may require the SIP/TIP to be
revised to correct the inadequacy (e.g.. transported smoke).
C. Role of Wildland Owners/Managers
Wildland owners/managers are responsible for following State/tribal regulations
applicable to fires, obtaining authorization to burn, and following the approved burn plan, when
one is required. Owners/managers are responsible for taking appropriate actions to control the
fire and reduce exposure to smoke when adverse air quality impacts result from a failure of the
air quality prescription or an escaped fire.
There is a special need for fires managed by Federal agencies to have burn plans that
include smoke management components. Fires managed by Federal agencies are most likely to
impact air quality in recreation areas (national parks, forest, etc.) and impair visibility in
mandatory Class I Federal areas. The EPA encourages Federal agencies to include smoke
management components in all bum plans, regardless of the existence of a State/tribal SMP.
VIII. DATA ON WILDLAND and PRESCRIBED FIRES
Most of a State/tribal program to protect air quality is contained in a SIP or TIP. Since
the use of fire for resource management is expected to increase substantially, especially on
Federal lands. State/tribal air quality managers will need information to develop potential annual
or seasonal air pollutant emission estimates for SIP/TIP planning. As for an)' source, emissions
from fires can be estimated by multiplying the estimated level of activity by an emission factor.
The level of activity for fire is the mass of biomass (fuel) consumed, usually expressed in tons.
Emission factors expressed in pounds per ton of fuel consumed are available in EPA's
publication AP-42 (which is scheduled to be updated). Emission factors are derived from an
estimate of overall combustion efficiency (i.e. stoichiometric ratio). The mass of fuel consumed
5See Volume 63 Federal Register 7254, February 12. 1998.
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is the product of fire size (acres), pre-burn fuel loading (tons per acre), and fuel consumption
(percent of pre-burn loading). An emission inventory can be compiled by the affected air agency
for an individual fire, a statistical class of fires, a burn program, or a population of fires in a
given area over a period of time based on this information.
Federal land management agencies currently collect data on wildland and prescribed
fires, however, no standard reporting format is followed. These raw data are usually limited to
the time and approximate location of the fire, fire perimeter area, weather (occasionally) and a
qualitative description of fuels at the point of ignition. The data are not collected for the purpose
of calculating air pollutant emissions and are probably inadequate for that purpose.
A National Interagency Fire Statistics Information Project has been initiated to develop an
easily accessible system for storing a set of commonly agreed upon fire data. 'Post-burn data,
such as that described above, on future wildland and prescribed fires would be stored in this
database. The database will be accessible by air quality managers to estimate past, current, and
future emission trends from this source category.
The EPA encourages the Federal land management agencies to develop the fire statistics
database and FLM's to report fire data to the system. These fire data will be needed by air
quality managers in regions where most wildland and prescribed fires occur on Federal lands.
Air quality managers should request similar fire data for wildland and prescribed fires on State,
private and Indian wildlands as well as information on other types of open burning to complete
their emission inventories.
Statewide emissions from fire use in all 50 states during 1989 have been estimated based
on a survey of [Federal. State and private] land owners/managers. [Ref. Peterson/Ward] Also, a
spatially resolved inventory of prescribed burning by county for 1990 and by 50km grid for 1995.
2015 and 2040 was prepared for 10 western States as part of the Grand Canyon Visibility
Transport Commission's activities. [Ref. Peterson/Lahm] The emission estimates are based on
fuel models derived from 14 types of vegetative cover spatially mapped throughout the area and
estimates of fuel loadings as either low, medium or high. The procedures followed by Peterson
and Lahm to estimate emissions for the western states provide a good model for developing
emissions estimates for other areas, also.
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Further information on developing emissions estimates and the data required can be
found in the white paper "Emission Inventories for SIP Development." See Section I to obtain a
copy.
IX. MEETING OTHER CLEAN AIR ACT REQUIREMENTS
A. Demonstrate Conformity of Federal Activities
Activities on Federal lands must meet the requirements of the CAA, including the
provisions of section 176(c), that such activities "conform" to the purpose of the applicable SIP.
The EPA's Conformity rules, implementing the provisions of section 176(c), only apply to
Federal actions taken within a nonattainment or maintenance area. The Transportation
Conformity rules govern transit-related activities, and all other type of activities are governed by
the General Conformity rules. The rules require a Federal agency to demonstrate, prior to
initiating a project, that its action conforms to all applicable requirements in a SIP and will not
cause or contribute to NAAQS violations. The General Conformity rules provide Federal
agencies with several options for demonstrating conformity. The following options are most
typically followed : (1) a modeling demonstration to show that emissions from the project will
not increase the frequency or severity of a NAAQS violation. (2) obtaining emission reductions
that offset the new project emissions, or (3) showing that the project's emissions are already
included in. or accommodated by. the emissions inventory of the SIP for the relevant
nonattainment or maintenance area. Federal activities occurring on tribal lands will be addressed
by EPA consistent with its Tribal Air Rule and the requirements of the CAA.
The above procedures can be followed to demonstrate conformity of fire projects for a
Federal land management agency's administrative units based on the FMP's developed for such
units. The demonstration can be made on an annual basis for all burns within the airshed of a
nonattainment or maintenance area. Alternatively, the demonstration can be made for each
individual fire project conducted at the administrative unit.
In addition to the previously cited methods for demonstrating conformity of Federal fire
projects, EPA will pursue, in consultation with the other Federal agencies, adding an alternative
method to the General Conformity rules through rulemaking. At a minimum. EPA believes that
the alternate method should require a Federal agency to document that its fire projects are
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managed within a certified SMP. The SMP also must require regional coordination (cooperation
of all jurisdictions in an airshed) of burn plan authorization and real-time air quality monitoring
at sensitive receptors, when warranted, in addition to the basic program components discussed in
section VI.
B. Visibility/Regional Haze Requirements
The EPA's visibility regulations (45 FR 80084, December 2, 1980) protect mandatory
Class I Federal areas from manmade impairment that is "reasonably attributable" to a single
emission source or small group of sources. FLM's for mandatory Class I Federal areas have a
key consultative role and responsibility to participate in the development of SIP's for visibility
impairment that is reasonably attributable to specific sources. In Part C of the CAA which
includes the visibility protection mandate. Congress assigned FLM's the "affirmative
responsibility to protect air quality related values (including visibility)" in mandatory Class I
Federal areas. Under EPA's regulations. States must take appropriate actions to address all
sources of visibility impairment, including fires, in response to a FLM's certification of
reasonably attributable impairment in mandatory Class I Federal areas.
A new regulatory program to protect mandatory Class I Federal areas from "regional
haze" impairment was proposed by EPA on July 31. 1997 (62 FR 41137). After the regional
haze rules become final. States will need to address the impacts of fires and other contributing
sources on meeting reasonable progress in their control strategy analyses, as well as during
periodic progress assessments. The EPA will revisit this section of the Air Quality Policy on
Wildland and Prescribed Fires after the final rules for implementing the regional haze program
have been promulgated. The EPA will also develop guidance on assessing natural background
visibility to aid in implementing the regional haze rules, and will consider the following paper at
that time. The white paper "Estimating Natural Emissions From Wildland and Prescribed Fire"
presents preliminary options for defining natural wildland and prescribed fire emissions that may
or may not be consistent with the final regional haze rules. See Section I to obtain a copy.
C. Prevention of Significant Deterioration
Title I, part C of the CAA requires SIP's to include provisions to prevent the significant
deterioration of air quality in areas designated as attainment or unclassifiable for any NAAQS.
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"Significant deterioration" for any pollutant is defined as an unacceptable incremental increase in
ambient concentrations above the baseline concentration for that pollutant in an area. The PSD
"increments" have been established for SO2, NO2, and PM10. The EPA adopted NAAQS for
PM25. which became effective on September 16, 1997. However, no increments have yet been
promulgated for PM2 5
The SIP's are required to contain emission limits and such other measures as may be
necessary to prevent significant deterioration of air quality. See section 161 of the Act. In
addition, SIP's are required to include a preconstruction review permit program for new and
modified major stationary sources. See section 165 of the Act. The SIP's must ensure that
increases in emissions from all types air pollution sources do not cause the allowable increment
for a pollutant to be exceeded.
While fires managed for resource benefits generally are not subject to a preconstruction
review and the issuance of a PSD permit, the emissions from such activities may affect the air
quality in a PSD area. Under adverse conditions, the combined PM emissions from increased
fire activities and from other sources could possibly result in ambient concentrations that exceed
the allowable PSD increments for PM. Historically. EPA has often regarded fires managed for
resource benefits to be temporary activities.6 The PM emissions resulting from fire activities
differ from the PM emissions generated by most other sources because they are generally short-
lived. That is. the burning generally is carried out infrequently at a specific location (once ever)'
5-20 years) and the duration tends to be short (approximately 1-2 days). Even with the proposed
increased utilization of fire as a resource management tool, the resulting PM emissions are
expected to be relatively uncommon at a particular location and of short duration.
Section 163(c)(l)(C) of the Act authorizes States with approved PSD programs to
exclude (with the Administrator's approval) concentrations of PM caused by "construction or
other temporary emission-related activities" when determining compliance with the PSD
increments. The EPA generally supports the concept of allowing States with approved SIP's to
exclude emissions caused by temporary managed fire activities from increment analyses,
6See Volume 58 Federal Register 31633, June 3, 1993.
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provided the exclusion does not result in permanent or long-tern air quality deterioration.
Nevertheless, the decision as to whether PM emissions from fire activities should be counted
against the PSD increments for PM is a decision to be made by individual States. The EPA
expects States to consider the extent to which a particular type of prescribed burning activity is
truly temporary, as opposed to those activities which can be expected to occur in a particular area
with some regularity over a period of time.
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DEFINITIONS
Air Quality: The characteristics of the ambient air (all locations accessible to the general
public) as indicated by concentrations of the six air pollutants for which national standards have
been established [i.e., paniculate matter (PM), sulfur dioxide (S02) nitrogen dioxide (NO2),
ozone (O3), carbon monoxide (CO) and lead], and by visibility in mandatory Federal Class I
areas. For the purposes of this policy, concentrations of PM are taken as the primary indicators
of ambient air quality.
Air Quality Manager: The regulatory body responsible for managing the air quality
protection program for a State, local or tribal government.
Air Quality Related Values (AQRV): Those special attributes of a mandatory Class I
Federal area that deterioration of air quality may adversely affect. Some examples of AQRV
include: flora and fauna, water, visibility, and odor among others.
Ambient Air: That portion of the atmosphere, external to buildings, to which the general
public has access.
Administrative Unit: A unit of land (Forest, Refuge. Park, etc.) under the administration
of a public land management agency.
AP-42: The Environmental Protection Agency's (EPA) Compilation of Air Pollutant
Emission Factors for stationary point, area, and mobile sources. An emission factor is a
representative value that attempts to relate the quantity of a pollutant released to the atmosphere
with an activity associated with the release of that pollutant. Emission factors are then used to
estimate the magnitude of a source's pollutant emissions.
The plan includes the project objective, fire prescription (including smoke management
components), personnel, organization, equipment, etc.
Class I Area: An area set aside under the Clean Air Act (CAA) to receive the most
stringent protection from air quality degradation. Mandatory Class I Federal areas are (1)
international parks. (2) national wilderness areas which exceed 5,000 acres in size, (3) national
memorial parks which exceed 5.000 acres in size, and (4) national parks which exceed 6,000
acres and were in existence prior to the 1977 CAA Amendments. The extent of a mandatory
Class I Federal area includes subsequent changes in boundaries, such as park expansions.
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De Minimis Fires: Fires that will cover fewer than X acres or consume less than Y tons
of fuel, as established by a State or tribe.
Federal Implementation Plan (FIP): A plan (or portion thereof) promulgated by the
Administrator, as provided for under the CAA and any applicable EPA regulations, including
regulations governing tribal air plans, to fill all or a portion of a gap or otherwise correct all or a
portion of an inadequacy in a State or tribal implementation plan (TIP), and which may include
enforceable emission limitations or other control measures, means or techniques (including
economic incentives, such as marketable permits or auctions of emissions allowances), and
provides for attainment of the relevant national ambient air quality standard (NAAQS).
Federal Land Manager (FLM): With respect to any lands in the United States, the
Secretary of the Federal department with authority over such lands. Generally, the Secretaries
delegate their authority to specific elements within each department. For example, the National
Park Service and the Fish and Wildlife Service manage those areas under the authority of the
Department of the Interior.
Fire Dependent Ecosystem: A community of plants and animals that must experience
recurring disturbances by fire, in order to sustain its natural plant succession, structure and
composition of vegetation, and maintain appropriate fuel loading and nutrient cycling to ensure
proper ecosystem function.
Fire Management Plan (FMP): A strategic plan that defines a program to manage
wildland and prescribed fires, and documents the FMP to meet management objectives outlined
in the approved land use plan. The plan is supplemented by operational procedures such as
preparedness plans, burn plans and prevention plans.
Fuel: Includes combustible vegetative matter such as grass, trees, shrubs, limbs,
branches, duff, and stumps.
Indian Land: Indian land in this document refers to Indian country which is (a) all land
within the limits of any Indian reservation under the jurisdiction of the United States
Government, notwithstanding the issuance of any patent, and, including rights-of-way running
through the reservation, (b) all dependent Indian communities within the borders of the United
States whether within the original or subsequently acquired territory thereof, and whether within
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or without the limits of a state, and (c) all Indian allotments, the Indian titles to which have not
been extinguished, including rights-of-way running through the same. [See 18 U.S.C. 1151.]
Land Use Plan: A broad scale, long range plan (e.g., forest plan, refuge plan or resource
management plan) that identifies the scope of actions and goals for the land and resources
administered by a land owner/manager.
National Ambient Air Quality Standards (NAAQS): Standards for maximum
acceptable concentrations of pollutants in the ambient air to protect public health with an
adequate margin of safety, and to protect public welfare from any known or anticipated adverse
effects of such pollutants (e.g., visibility impairment, soiling, materials damage, etc.) in the
ambient air.
National Environmental Policy Act (NEPA): Establishes procedures that Federal
agencies must follow in making decisions on Federal actions which may impact the environment.
Procedures include evaluation of environmental effects of proposed actions, and alternatives to
proposed actions: involvement of the public and cooperating agencies.
Nuisance Smoke: Amounts of smoke in the ambient air which interfere with a right or
privilege common to members of the public, including the use or enjoyment of public or private
resources.
Particulate Matter (PM): Any airborne finely divided material, except uncombined
water, which exists as a solid or liquid at standard conditions (e.g., dust, smoke, mist, fumes, or
smog).
PM25: Particles with an aerodynamic diameter less than or equal to a nominal 2.5
micrometers.
PMIO: Particles with an aerodynamic diameter less than or equal to a nominal 10
micrometers (including PM2 5).
Prescribed Fire: Any fire ignited by management actions to meet specific objectives
(i.e., managed to achieve resource benefits).
Prescription: Measurable criteria which guide selection of appropriate management
response and actions. Prescription criteria may include the meteorological conditions affecting
the area under prescription, as well as factors related to the state of the area to be burned such as
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the fuel moisture condition and other physical parameters. Other criteria which may be
considered include safety, economic, public health, environmental, geographic, administrative,
social or legal considerations, and ecological and land use objectives.
Prevention of Significant Deterioration (PSD): A requirement in the CAA, which
establishes the maximum allowable increases in ambient air concentrations of selected air
pollutants above baseline concentrations in areas designated as Class I, Class II. or Class III.
Project Plan: A strategic plan for accomplishing specific actions and goals (objectives)
established in a land use plan. A project may include several activities such as cutting and
hauling trees and shrubs, planting trees, building trails, and fire treatment.
Regional Haze: Generally, concentrations of fine particles in the atmosphere extending
up to hundreds of miles across a region and promoting noticeably hazy conditions; wide-spread
visibility impairment, especially in mandatory Class I Federal areas where visibility is an
important value.
Sensitive Receptors: Population centers such as towns and villages, camp grounds and
trails, hospitals, nursing homes, schools, roads, airports, mandatory Class I Federal areas, etc.
where smoke and air pollutants can adversely affect public health, safety and welfare.
Smoke Management Program (SMP): Establishes a basic framework of procedures and
requirements for managing smoke from fires that are managed for resource benefits. The
purposes of SMP's are to mitigate the nuisance and public safety hazards (e.g., on roadways and
at airports) posed by smoke intrusions into populated areas; to prevent deterioration of air quality
and NAAQS violations; and to address visibility impacts in mandatory Class I Federal areas in
accordance with the regional haze rules.
State Implementation Plan (SIP): A CAA required document in which States adopt
emission reduction measures necessary to attain and maintain NAAQS, and meet other
requirements of the Act.
Suppression: A management action intended to protect identified values from a fire,
extinguish a fire, or alter a fire's direction of spread.
Tribal Implementation Plan (TIP): A document authorized by the CAA in which
eligible tribes adopt emission reduction measures necessary to attain and maintain NAAQS, and
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meet other requirements of the CAA for lands within tribal jurisdictions.
Violation of the PM NAAQS: As revised in 1997, the daily PM10 standard is violated
when the 99th percentile of the distribution of 24-hour concentrations for a period of 1 year
(averaged over 3 calendar years) exceeds 150 ug/m3 at any monitor within an area. The annual
PM]0 standard is violated when the arithmetic average of 24-hour concentrations for a period of 1
year (averaged over 3 calendar years) exceeds 50 ug/m3 at any monitor within an area.
The new NAAQS levels for PM2 5 are set at a daily concentration less than or equal to 65
ug/m3, and an annual mean concentration of less than or equal to 15 ug/m3 The daily standard is
violated when the 98th percentile of the distribution of the 24-hour concentrations for a period of
1 year (averaged over 3 calendar years) exceeds 65 ug/m3 at any monitor within an area. The
annual standard is violated when the annual arithmetic mean of the 24-hour concentrations from
a network of one or more population-oriented monitors (averaged over 3 calendar years) exceeds
15 ug/m5. Compliance with the annual PM2 5 NAAQS is based on population-oriented monitors
because the health information, upon which the standard is based, relates area-wide health
statistics to area-wide air quality as measured by one or more monitors.
Volatile Organic Compounds (VOC): Any organic compound which participates in
atmospheric photochemical reactions, which are measured by a reference method, an equivalent
method, or an alternative method. Some compounds are specifically listed as exempt due to their
having negligible photochemical reactivity. [See 40 CFR 51.100.J Photochemical reactions of
VOC's with oxides of nitrogen and sulfur can produce O3 and PM.
Wildfire: An unwanted wildland fire.
Wildland: An area where development is generally limited to roads, railroads, power
lines, and widely scattered structures. The land is not cultivated (i.e., the soil is disturbed less
frequently than once in 10 years), is not fallow, and is not in the United States Department of
Agriculture (USDA) Conservation Reserve Program. The land may be neglected altogether or
managed for such purposes as wood or forage production, wildlife, recreation, wetlands or
protective plant cover. [The distinction between wildlands, to which the recommendations in
this document apply, and agricultural lands is subject to further discussion.]
Wildland Fire: Any non-structural fire, other than prescribed fire, that occurs in the
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wildland. Note: Wildland fires include unwanted (wild) fires and naturally ignited fires that are
managed within a prescription to achieve resource benefits.
Wildland Fire Situation Analysis (WFSA): A real time decision-making process
carried out by federal land management agencies to select an appropriate management response
to wildland fire. The WFSA considers fire fighter and public safety, risk to property and
resources, fire fighting resources available, land management objectives and environmental.
social economic and political constraints. The environmental and social constraints considered
include, among other things, how air quality and/or visibility will be affected at sensitive
receptors by each alternative fire management strategy.
Wildland/Urban Interface: The line, area or zone where structures and other human
development meets or intermingles with the wildland.
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