AIR POLLUTION CONTROL ACTIVITIES
IN THE STATE OF IDAHO
SMOKE MANAGEMENT PLAN FOR
FIELD BURNING IN NORTHERN IDAHO
PREPARED FOR
U. S. ENVIRONMENTAL PROTECTION AGENCY
REGION X
1200 SIXTH AVENUE
SEATTLE, WASHINGTON 98101
JUNE 1982
ENGINEERING-SCIENCE
DESIGN RESEARCH PLANNING
125 WEST HUNTINGTON DRIVE P.O. BOX 538 ARCADIA, CALIFORNIA 91006 213/445-7560\
OFFICES IN PRINCIPAL CITIES
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SMOKE MANAGEMENT PLAN FOR
FIELD BURNING IN NORTHERN IDAHO
PREPARED FOR:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION X
1200 SIXTH AVENUE
SEATTLE, WA 98101
JUNE 1982
IDAHO AIR MANAGEMENT SERVICES
ENGINEERING-SCIENCE, INC.
801 RESERVE STREET
BOISE, IDAHO 83702
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TABLE OF CONTENTS
PAGE
1. INTRODUCTION 1-1
1.1 PURPOSE 1-1
1.2 SMOKE MANAGEMENT GOALS 1-1
1.3 BACKGROUND 1-2
2. USERS' INSTRUCTIONS 2-1
2.1 REGULATIONS AND AUTHORITY 2-1
2.2 REGISTRATION 2-2
2.3 PERMITS 2-3
2.4 BURNING AUTHORIZATION 2-7
3. OPERATIONAL PROCEDURES 3-1
3.1 ORGANIZATION AND CONTRACT 3-1
3.2 COLLECTION OF WEATHER DATA AND DEVELOPMENT 3-2
OF FORECASTS
3.2.1 WIND INFORMATION 3-5
3.2.2 MIXING HEIGHT 3-7
3.2.3 RAINFALL 3-7
3.2.4 WEATHER FORECASTS 3-8
3.2.4.1 DAILY BURNING WEATHER FORECASTS 3-8
3.2.4.2 AIR STAGNATION ADVISORIES 3-9
3.3 USE OF AERIAL OBSERVATIONS 3-9
3.4 USE OF TEST FIRES 3-9
3.5 COLLECTION AND USE OF AIR QUALITY DATA 3-10
3.5.1 VISIBILITY/COMPLAINTS 3-10
3.5.2 PARTICULATE MONITORS 3-11
3.5.3 AIR POLLUTION EPISODES 3-13
3.6 DETERMINATION OF ACREAGE FOR BURNING 3-13
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TABLE OF CONTENTS (CONTINUED)
PAGE
3.6.1 DETERMINATION OF BURN AREAS 3-13
3.6.2 DETERMINATION OF AMOUNTS OF BURNING 3-17
3.6.3 MODIFICATIONS TO AREAS AND AMOUNTS 3-19
OF BURNING
3.6.4 COORDINATION WITH SCAPCA 3-19
3.7 AUTHORIZATION OF BURNING 3-20
3.8 USE OF COMMUNICATIONS 3-22
3.9 PROGRAM DOCUMENTATION 3-23
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FIGURES
PAGE
FIGURE 2-1 STATE OF IDAHO 1982 SMOKE MANAGEMENT 2-4
FIELD REGISTRATION FORM
FIGURE 2-2 RATHDRUM PRAIRIE DETAILED INFORMATION 2-5
SHEET
FIGURE 2-3 DEPARTMENT OF LANDS OPEN BURNING PERMIT 2-6
FIGURE 3-1 ORGANIZATION OF PERSONNEL IN THE 1982 3-3
IDAHO FIELD BURNING SMOKE MANAGEMENT
PROGRAM
FIGURE 3-2 WEATHER MONITORING SITES 3-4
FIGURE 3-3 PROPOSED DATA SHEET FOR RECORDING OF 3-6
DAILY METEOROLOGICAL DATA PERTINENT TO
FIELD BURNING SMOKE DISPERSION
FIGURE 3-4 VISIBILITY PROTECTION AREAS 3-12
FIGURE 3-5 FLOW DIAGRAM ILLUSTRATING DAILY FORECAST 3-21
DEVELOPMENT AND BURN AUTHORIZATION PROCESS
FIGURE 3-6 PROPOSED FORM FOR RECORDING DAILY BURNING 3-24
ACTIVITY
FIGURE 3-7 PROPOSED FORM FOR RECORDING DAILY SURFACE 3-25
WEATHER DATA FROM REMOTE METEOROLOGICAL
INSTRUMENTS
TABLE
PAGE
TABLE 3-1 GENERALIZED IGGA FORECAST CRITERIA 3-16
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SECTION 1
INTRODUCTION
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1. INTRODUCTION
1.1. Purpose
The purpose of this Smoke Management Plan is to assure
compliance with State air pollution control regulations
pertaining to agricultural burning and to inform the public
of the proposed approach to this problem. The Plan is
divided into two sections. The first, called 'Users'
Instructions,1 is intended to notify persons responsible
for burning of applicable regulations and procedures to
be followed in 1982. The second, called 'Operational
Procedures,' describes how smoke management decisions
will be made and by whom.
1.2 Smoke Management Goals
1.2.1 Fields are burned only when weather conditions are
conducive to good smoke dissipation.
1.2.2 Smoke sensitive areas are identified and special
precautions are followed to protect them from
adverse air quality effects due to open field
burning.
1.2.3 Quick response to smoke-caused problems and adjust-
ment of the Smoke Management Plan as necessary to
prevent reoccurrences.
1.2.4 Restrict unnecessary burning and encourage research
on alternative methods of disease controls and pro-
duction enhancement.
1-1
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1.2.5 Keep the public informed and provide opportunity
for the public participating in developing the
Smoke Management Plan.
1.3 Background
Smoke management is the practice of regulating open burning
activities to those periods when atmospheric conditions are
appropriate to minimize the adverse effects of the resulting
air contaminants on people. It requires knowledge of
atmospheric dispersion characteristics and the ability to
forecast the onset and duration of suitable conditions to
allow burning. It also requires a good understanding of
source characteristics including emission amounts, rates,
response time and the reliability of the operators; air
pollution effects; silvacultural and agricultural practices
and basic air pollution law.
Smoke management requires three activities to be conducted
with reliable accuracy for success:
1. Forecasting of burning weather;
2. Communicating of forecast information and subsequent
burning authorizations; and
3. Implementation of burning in accordance with the
restrictions of burn authorizations.
1-2
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All three activities require judgment and action by individ-
uals who are subject/ of course, to making errors. As a
consequence/ there are no ongoing smoke management programs
with flawless records. All have had occasions of missed
forecasts, misinterpreted communications or wrongly executed
burns resulting in smoke intrusions into sensitive areas.
To minimize the possibilities of such unfortunate results/
most smoke management program operators are continually
working to reduce errors in routine operations. These
efforts include development of more sophisticated forecast
techniques and improvement of data gathering equipment,
better equipment and more rigorous procedures for communica-
tions, increased training and/or regulation to make burning
results more predictable. The program operators in Northern
Idaho have continued to make these same types of changes in
an effort to reduce the potential for future smoke intrusions.
It is recognized by smoke management experts, however, that
these steps will never totally eliminate the potential for
smoke intrusions.
In Northern Idaho open field burning has been conducted for
more than twenty years. Public concern over the practice
has generally increased in the last several years, expressed
in increasing numbers of complaints. The potential of the
air pollution effects of open field burning and resulting
public concern were not lost on the local grass seed industry
and in 1971 the Intermountain Grass Growers Association (IGGA)
1-3
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was formed to address the needs of seed growers with regard
to the problem. Over the next ten years, the State of
Idaho, in its efforts to regulate the potentially substantial
impacts of field burning, developed with IGGA, proposed
plans for regulating burning and conducting research for
non-burning alternatives. These plans were set forth in
"Compliance Schedules" between the grass seed industry and
the State. Both parties continued to operate under the
restrictions of these schedules through the 1970's until
the state legislature cancelled Air Bureau activities on
June 30, 1981.
The last and most substantial effort at evaluating smoke
management programs in Idaho was undertaken by the State just
after the 1979 burning season. Seed growers, members of
the public, and regulatory personnel, through the course of
several meetings, jointly reviewed the Idaho program and
made several recommendations for change. These were imple-
mented in the 1980 season with apparent success.
At the onset of the 1981 field burning season, EPA received
responsibility for all air pollution control in Idaho.
However, Federal enforcement of State agricultural burning
regulations during this period was limited by three con-
straints :
1. General language and lack of case precedents made
State regulations difficult to enforce;
1-4
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2. Federal enforcement authority was designed to deal
with chronic, large-source violations rather than
very short-term widely distributed sources like
field burning; and
3. EPA resources were stretched thin trying to initiate
a statewide air pollution control program.
To assist in the overall effort, EPA retained a consultant/
contractor, Engineering-Science, Inc. (ES), and assigned,
as one of its tasks, the evaluation of field burning activities
in Northern Idaho. A report, "Evaluation of the Grass Seed
Field Burning Program in Northern Idaho" was produced by ES
and served as a key source of information for development
of this 1982 Smoke Management Plan.
As noted, it is anticipated that the State of Idaho's role
in 1982 field burning will be limited, leaving regulatory
responsibilities to EPA. Thus, federal enforcement procedures
will again apply but, in contrast to the 1981 season, EPA
proposes to provide on-site staff to manage and enforce open
field burning in Northern Idaho during 1982. Unfortunately,
federal enforcement procedures are cumbersome by most states'
standards and are not well suited to field burning enforce-
ment. However, if appropriate, substantial federal penalties
can be levied for violations of any regulations included in
Idaho's approved State Implementation Plan and these include
all agricultural burning rules.
1-5
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Traditionally, Idaho has not used a strong, regulation-based
control program to deal with field burning. This reflects
both the State's general approach to regulation of agricul-
tural activities and the cooperative approach to control
expressed by IGGA. Alternatively, the State of Washington
has adopted specific regulations dealing with open field
burning requiring permits to be issued for all open field
burns. This difference in approaches is clearly noted
between Spokane County, Washington where permitting of some
25,OOOA is required while adjacent Kootenai County, Idaho
requires no permits for its 28,OOOA.
During 1981 the apparent disparity in control efforts was
made even greater with the absence of any State of Idaho
regulatory group. Because of acknowledged interstate smoke
effects and disparate treatment of growers between Idaho
and Washington, recent effort at program reform have focused
on assuring uniformity between the two states. To this
end, EPA took the lead in establishing a technical working
group to review the problems of integrating control efforts
while maintaining overall control and compliance with
individual state laws. The product of the committee is to
be an analysis and recommendation regarding the degree of
practical uniformity that can or should be achieved. This
working group's report recommendations will be considered
for incorporation in this Smoke Management Plan and be made
available for public review as part of the process for
developing Smoke Management Program goals.
1-6
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SECTION 2
USERS' INSTRUCTIONS
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2. USERS' INSTRUCTIONS
2.1 Regulations and Authority
Regulations applicable to agricultural burning are contained
in Section 1-1153.08 of Rules and Regulations for the Control
of Air Pollution in Idaho. These regulations, which were
adopted in 1970, will remain unchanged through the 1982 burn
season. (House Bill 804 prohibits changes to air pollution
control regulations until after December 1, 1982.) Therefore,
applicable regulations for 1982 are as follows:
Section 1-1153.08 Agricultural Burning.
The open burning of plant life grown on the premises in the
course of any agricultural, forestry or land clearing opera-
tion may be permitted when it can be shown that such burning
is necessary and that no fire or traffic hazard will occur.
Convenience of disposal is not of itself a valid necessity
for burning. (9-21-70)
(a) It shall be the responsibility of any person conducting
such burning to make every reasonable effort to burn
only when weather conditions are conducive to a good
smoke dissipation and only when an economical and
reasonable alternate method of disposal is not avail-
able. (9-21-70)
(b) When such alternate method is made available, it shall
be put into use within a reasonable time. (9-21-70)
2-1
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(c) Any person conducting an agricultural, forestry, or
land clearing burning operation similar to an operation
carried out by a governmental agency shall follow the
rules and procedures of the agency with regard to
minimizing air pollution. (9-21-70)
(d) When such burning creates air pollution or a public
nuisance, additional restrictions may be imposed to
minimize the effect upon the environment. (9-21-70)
The U.S. Environmental Protection Agency is currently
responsible for managing a program to control air pollution
in Idaho. Though the legislature voted to reestablish the
State's Bureau of Air Quality on August 2, 1982, it is
unlikely the Bureau will be organized or staffed to assume
responsibility for the 1982 burn season. Therefore, EPA,
supported by its contractor, Engineering-Science, Inc. (ES)
will be responsible for regulating agricultural burning in
accordance with State regulations and the Clean Air Act.
Since Section 1-1153-08, previously codified as Regulation
D, Section 3, H is part of the federally-approved State
Implementation Plan, it is enforceable by EPA according to
Section 113 of the Clean Air Act.
2.2 Registration
As in past years, registration is required of any grass seed
or cereal grain fields prior to burning. It shall be the
responsibility of any person conducting such burning to
complete and return by July 1, 1982 the appropriate forms.
2-2
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Examples of these forms are shown in Figures 2-1 and 2-2.
These forms can be detached and used or additional forms
can be obtained by contacting:
Dennis Carlson
Executive Director
Intermountain Grass Growers Association
East 2375 Mullan
Post Falls, Idaho 83854
Phone: 773-5862
or
Jim Boylan
Engineering-Science, Inc.
801 Reserve Street
Boise, Idaho 83702
Phone: 344-6875
IT IS IMPORTANT TO NOTE THAT REGISTRATION DOES NOT AUTHORIZE
BURNING.
2.3 Permits
Air pollution regulations in Idaho do not require a permit
for agricultural burning. However, depending upon location
of fields, certain Federal, State and local agencies respon-
sible for fire safety do require burning permits. Compliance
with air pollution regulations does not relieve a person of
the responsibility of obtaining and meeting the terms and
conditions of any applicable burning permits.
For example, during the period May 10th to October 20th the
State Department of Lands requires a burning permit. A copy
of this permit is shown in Figure 2-3.
2-3
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FIGURE 2-1
STATE OF IDAHO
1982
SMOKE MANAGEMENT FIELD REGISTRATION FORM**
NAME AND ADDRESS
PERSON IN
LINE
NO. (
1 S
2 S
3 S
4 S
5 S
6 S
7 S
8 S
9 S
CHARGE OF
LOCATION
SEC. , TWP
T
T
T
T
T
T
T
T
T
BURNING:
OF FIELD*
. , RANGE )
R
R
R
R
R
R
R
R
R
DATE:
PHONE #:
FIELD COMMUNICATION (INCLUDE
CHANNELS/FREQUENCIES) :
PHONE #:
ON RATHDRUM TYPE OF FIELD
NUMBER OF PRAIRIE? (GRASS OR
ACRES (YES OR NO) CEREAL GRAIN
(Continue List on Additional Forms if Necessary)
*THE RATHDRUM PRAIRIE DETAILED INFORMATION SHEET MUST BE COMPLETED FOR
EACH FIELD LOCATED ON THE RATHDRUM PRAIRIE.
**ALL FORMS MUST BE COMPLETED AND RETURNED PRIOR TO THE BURNING OF ANY
GRASS SEED FIELD OR CEREAL GRAIN FIELD. (AUTHORIZATION FOR BURNING MUST
BE OBTAINED FROM PROGRAM MANAGER LOCATED AT THE RATHDRUM PRAIRIE WEATHER
STATION OR APPROPRIATE DEPARTMENT OF LANDS REPRESENTATIVE PRIOR TO
IGNITION.)
PLEASE RETURN WHITE COPY OF COMPLETED FORMS TO:
JIM BOYLAN
ENGINEERING-SCIENCE, INC.
801 RESERVE STREET
BOISE, IDAHO 83702
RETAIN YELLOW COPY FOR PERSONAL RECORDS
SIGNED
2-4
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FjusUKH 2=;
REGISTRATION NO.
RATHDRUM PRAIRIE
DETAILED INFORMATION SHEET
DATE:
OWNER:
PLEASE LIST REGISTRATION FORM LINE NUMBER(S) CORRESPONDING TO FIELD(S)
IDENTIFIED IN SECTION BELOW.
PLEASE LOCATE AND IDENTIFY IN THE SECTION BELOW: FIELD(S) TO BE
BURNED, ROADS, HOUSES, OTHER SENSITIVE AREAS OR HAZARDS AND INCLUDE
ARROWS WITH DISTANCES TO SENSITIVE AREAS OUTSIDE OF THIS SECTION.
WHEN MORE THAN ONE FIELD IS SHOWN, LABEL THE FIELDS USING THE
CORRESPONDING REGISTRATION FORM LINE NUMBERS.
SECTION
SPECIAL BURN CONSIDERATIONS:
FOR OFFICE USE ONLY
FIELD ID.
MAP COORDINATES
PLEASE SUBMIT WITH REGISTRATION FORM TO:
JIM BOYLAN
ENGINEERING-SCIENCE, INC.
801 RESERVE STREET
BOISE, IDAHO 83702
2-5
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State of Idaho BURNING PERMIT N° 067UO
In accordance with 38-115, Idaho Code, Rule 601.04 of the State Board of Land Commissioners*
Name
Address
Phone No.
is hereby granted a permit to burn the following materials:
LOCATION
Section
Burning will be confined to the hours of
Date Issued
through
inclusive
Township
Township
Range
Range
County
County
The permittee must keep the burning operation confined within cleared firebreaks or
barriers and provide the following men, equipment, and precautions on the fire until
It Is out.
Issued By (Fire Warden)
Phone No.
/ certify I have.read and understand this Permit and
assume full responsibility for this permit burning.
Forest Protective District
Received By
X
See Reverse Side
(38-115. Idaho Code, Rule 601.04)
CAUTION: This psr.rt does rat relieve perm.ittea.iiom cesnonsibility .of. fir« damage and suppression
costs as a result of fire escaping from prepared permit area.
DL 806 (1/75)
38-115. Closed season for fires Permits Regulations -j. ^ /«.
.Ejjyjpsion of closed season Suspension of permits Penalty.,;,':
frja period from May 10 to October.20, inclusive, of each year .
shall be known as the closed season. During the closed season
it shall be unlawful for any person to set or cause to be set a
fire in any slashing area, or a .fire to any stump or stumps, log ; o
of logs, down or standing timber or to set or cause to be set,
a'fire on any forest or range lands or dangerously near thereto,
or in any field in any forest protective district, without having
first procured a permit from the fire warden of the district, pro-
vided, that unless campfires have been prohibited during critical
hazard perioeds, campfires may be set without permit provided '
there is compliance with the provisions of section 38-116, Idaho
Code. Every permit shall prescribe the conditions upon which
the permit is given, and contain rules and regulations governing
the setting of fires and the prevention of the spread thereof to
the property of another. At no time shalt any fire be set when
the wind is blowing to such an extent as to cause danger of the
fire getting beyond the control of the person responsible -for.1_
setting it, or without sufficient'meiv'tools, supplies and fire-, ^i"'"^
fighting equipment to control it, and the fire shall be kept '
under the control of the person responsible for setting it until
it is out. The state board of land commissioners shall from
time to time make all necessary rules and regulations govern-
ing the setting of fires .on forest .lands for both the closed and
open-season,'.and for their proper control and extinguishment.
It shall be the duty of the director of the department of lands
rto prepare .the proper form of permit to be used in carrying
out the provisions of this section. The fire wardens shall at /'
.'all times have authority to refuse permits and/or to revoke the"
same and to postpone their use when issued, when -they shall -
deem it necessary so to do in the interest of public safety.
Any permits obtained by misrepresentation shall be invalid.
In seasons, localities and under conditions of unusual fire
danger, the director, with the advice of the fire warden of any
protective district, shall have the power to extend the period
of closed fire season in any district of the aforementioned "
districts to meet the particular fire hazard of each djstrict, and
when the safety of the-public requires, change the dosed
season in any district by fixing inclusive dates other than
those herein designated; close to entry therein by any person
or party, the forest and range lands in any section of the state
'wherein a critical fire hazard exists, and may restrict or suspend
travel on any road or trail 'leading into any such land, until, a
permit shall have been secured from the fire warden of the
"forest protective district'wherein such lands are situated, and
may also, without proclamation, suspend any and all'permits
or privileges authorized by this section and prohibit, the set- '
ting of any campfires^ and/or'fire in forest and range land 01
dangerously near to such, or in fields in any forest protective
district. S-.-jiii-s.-i.
Any violation of the provisions of this sectibn"shalj be deemed"
a misdemeanor.
601.04 Burning Permits. In each instance that a burning permit is issued during closed season, the permit shall be subject to the
following conditions: ;
1. Permits issued for open fires shall be limited for that period of time needed to accomplish the prescribed burning; provided,
however, in no event shall such permit be issued for more than 10 days.
2. Each permit shall contain all the terms and conditions deemed necessary by the State Forester for such 'burning; which terms .c
and conditions shall remain effective for the entire period of the permit.
FIGURE 2-3
DEPARTMENT OF LANDS OPEN BURNING PERMIT
2-5
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2.4 Burning Authorization
Any person conducting agricultural burning on the Rathdrum
Prairie must obtain authorization to burn from the program
manager located at the Rathdrum Prairie Weather Station
and, in other areas, from the appropriate State Department
of Lands Office prior to ignition. Failure to obtain
available weather information or abide by the daily burn
authorizations may be evidence of a violation of Section
1-1153.08(a).
2-7
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SECTION 3
OPERATIONAL PROCEDURES
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3. OPERATIONAL PROCEDURES
The following discussion of daily program organization and
operations describes proposed activities for the State of
Idaho, the Intermountain Grass Growers Association (IGGA)
and to the extent necessary, the Spokane County Air Pollution
Authority (SCAPCA). The proposed operation of the Idaho
Smoke Management Program will be similar to that conducted
during the 1980 season but will include changes incorporated
by Engineering-Science, Inc. (ES) for the 1982 season. The
changes are made to improve program technical approach, overall
effciency and enforcement capabilities. ES's participation,
as a contractor to EPA, is presumed even though the State
legislature has authorized funding of the Bureau of Air Quality
for fiscal year 1983 (1982 season). It is anticipated to be
fiscal year 1984 before the Bureau has the resources and
personnel in place to assume full program responsibility.
3.1 Organization and Contract
In fulfilling its obligations under the Clean Air Act, EPA is
conducting air pollution control activities in Idaho with the
aid of ES during the absence of the Idaho Bureau of Air Quality.
The ES contract directed the company to perform many of the
responsibilities of a normal air pollution control agency,
leaving ultimate enforcement of violators to EPA. A specific
requirement of the contract was the evaluation of the northern
Idaho field burning activities and control programs.
3-1
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Because funding for the State's Air Bureau will not be
available until August 2, 1982 and field burning this year
will probably begin in July, the State was not anticipated
to have personnel available to conduct the 1982 Smoke Manage-
ment Program. Consequently, ES's activities under the
contract were modified to include management of field burning
activities. ES personnel would carry out functions formerly
completed by State personnel including coordination with
IGGA and other interested parties, managing daily burning
activity and identifying potential violations of regulations.
The organization of personnel involved in the operation of the
1982 Idaho Smoke Management Program are identified in Figure
3-1.
3.2 Collection of Weather Data and Development of Forecasts
Meteorological data for the Idaho smoke management program
will be obtained from the National Weather Service Office
at Spokane International Airport (Gieger Field). Each
weekday morning, the IGGA meteorologist will consult in-person
with NWS staff. The IGGA meteorologist will also obtain
and analyze weather maps, charts, and reports useful to
making dispersion and wind direction forecasts.
The morning meteorological information will be updated
periodically based upon local surface and upper air informa-
tion from weather monitoring stations which are sited at
locations identified in Figure 3-2. Throughout the day
additional wind and vertical mixing information will be
3-2
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IGGA
METEOROLOGIST/
FORECASTER
MET. TECH.
MET. TECH.
CLERICAL
EPA
IDAHO OPERATIONS OFFICE
(BOISE)
ES PROJECT MANAGER
(BOISE)
SMOKE MANAGEMENT
PROGRAM MANAGER (ES)
(NORTHERN IDAHO)
FIELD
ENFORCEMENT
STAFF (ES)
Figure 3-1.
Organization of personnel in the 1982 Idaho Field Burning
Smoke Management Program
3-3
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b Upper level wind dir.
r Radio comm. available
Surface wind direction
and speed
O Upper air soundings
A,n- Part, monitor, nepheio-
meter
Surface visb.,temp., wind
Figure 3-2. Types and locations of ambient monitoring instruments for
operation of the Idaho smoke management program and analysis
of smoke effects.
3-4
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received by interrogating surface weather stations and by
releasing radiosondes and pilot balloons to obtain upper
level temperatures and winds. ES and IGGA staff will
work collaboratively in collecting this information. During
the Rathdrum Prairie burning season, this equipment will be
located with IGGA and ES personnel at the IGGA weather
station site near the center of the Prairie. Later in the
season, these weather instruments will be transferred to
the south Spokane County area which will be closer to the
center of burning activity at that time. IGGA is anticipated
to provide at least two staff members in addition to the
meteorologist to operate and maintain this wind and tempera-
ture measuring equipment throughout the burning season.
Also, throughout the day, ES staff will interrogate NWS
personnel as necessary for more recent assessments of the
weather situation.
An example of the data form to be used by the ES to record
burn forecast data is shown in Figure 3-3.
3.2.1 Wind Information
Wind direction and wind speed data shall be determined
chiefly through:
a. Upper air soundings, which are taken twice a day by
the National Weather Service at Spokane International
Airport (morning soundings will be obtained each day by
the IGGA meteorologist);
3-5
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FIELD BURNING WEATHER AND FORECAST
DATA SHEET
DATE
TIME
TODAY'S FORECAST
INVERSION BREAK-UP
TEMPERATURE
TIME (PDT)
FORECAST MIX. HT.
ELEVATION DIRECTION AND SPEED (KTS.)
(MSL)
Surface
3,000 '~~~
4,000
5,000 _ZHIIIIH
6,000
7,000
8,000
9,000
10,000
11,000
12,000
PRECIPITATION
TOMORROW'S FORECAST
OTHER CONSIDERATIONS
REVISED
7/6/79
NWS CONTACT PERSON:
OTHER CONSULTANTS:
BY:
AUTHORIZED BURNING PERIOD(S)
AND SPECIAL RESTRICTIONS
RATHDRUM PRAIRIE
WORLEY
ST. MARIES
CONTACT WITH DOL FIRE WARDENS
MICA OFFICE (664-8197)
CONTACTED AT
A.M.
ST. MARIES OFFICE (245-4551)
CONTACTED AT A.M.
FIGURE 3-3. Proposed Data sheet for recording of daily meteorological
data pertinent to field burning smoke dispersion.
3-6
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b. Pilot balloon soundings taken at the Rathdrum Prairie
weather station and southern Spokane County by IGGA
personnel;
c. Visually tracked in-field balloon releases;
d. Tracking of smoke plume movements by observers located
at the Rathdrum Prairie weather station, in fields,
and in moving vehicles; and
e. Remote weather sites, accessible by telephone.
This information will be recorded on appropriate forms
and logs.
3.2.2 Mixing Height
Vertical dispersion information for conducting the smoke
management program will be determined from the early morning
(4 A.M.) sounding taken at the Spokane NWS station and
minisonde measurements taken as needed throughout the day
at the Rathdrum Prairie weather station. Other useful
information on upper level winds and stability will be
sought from the NWS.
3.2.3 Rainfall
In general, determination of proper field fuel moisture
conditions for burning will be left to the individual
farmer both for periods following rainfall and after
nighttime periods of high relative humidity and dew.
Rainfall data from the nearby recording stations will be
collected.
3-7
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3.2.4 Weather Forecasts
3.2.4.1 Daily Burning Weather Forecasts
Weather forecast will be assembled by the chief IGGA
meteorologist each morning prior to 7:00 A.M. Synoptic
maps supplied by the NWS will be inspected as well as
computerized weather prognoses. Prior to 8:00 A.M.,
local NWS forecasters will be interrogated regarding
expected dispersal conditions. The meteorologist
will forecast synoptic wind flow patterns through
pressure gradient analysis and surface temperature
forecasts (the time of "breakup" of a surface based
inversions can strongly affect wind flow fields and
this breakup depends on the surface temperature reaching
a critical value). He also will make forecasts regarding
microscale winds affecting flow over the Rathdrum
Prairie and Spokane Valley.
Forecasts will be updated throughout the day based upon
upper level wind and temperature measurements taken
at the Rathdrum Prairie weather station. Additional
information from the NWS, obtained from facsimile and/or
teletype units1, will be used to provide continuous
updating of regional meteorological information.
Based on the developed forecasts the IGGA meteorologist
will advise the program manager regarding the areas and
amounts of burning and aid in the judgments regarding
the burning of individual fields.
llnstallation in 1982 contingent upon available funds.
3-8
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3.2.4.2 Air Stagnation Advisories
Air Stagnation Advisories (ASA) are issued by the
National Weather Service when atmospheric dispersal
conditions are poor for an extended period of time
(36 hours) and a buildup of air pollutants is expected.
ALL OPEN BURNING WILL BE PROHIBITED WHEN AN ASA IS IN
EFFECT.
3.3 Use of Aerial Observations
When feasible, aerial observations will be used to make
rapid, accurate assessments of meteorological conditions as
well as important burning information such as plume height
and trajectory. In addition, the use of aircraft will
facilitate:
a. Measurement of atmospheric temperature soundings;
b. Observation and more precise timing of forecast weather
changes;
c. Immediate identification or verification of micro-
meteorological changes; and
d. Observation of the extent and timing of smoke intru-
sions .
Due to the additional expense the use of aircraft are
anticipated to be extremely limited.
3.4 Use of Test Fires
There is often little difference between test fires and
normal burning on the Rathdrum Prairie since most fields
are authorized for burning on an individual basis. Test
3-9
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fires will not normally be conducted in other areas. Often
the IGGA meteorologist will be on-site prior to the time of
ignition for balloon releases or other observations. No
specific requirements will be placed on test fires used for
determining existing meteorology prior to additional burning
except that the field should be representative of others to
be burned. Test fires will not be selected which would
result in other burning being unnecessarily delayed. The
scheduling of Rathdrum test burns, as with all other burns,
will be done directly between the grower and the weather
staff. All such burns will be authorized by the ES program
manager.
3.5 Collection and Use of Air Quality Data
No formal procedures will exist for the use of quantified
ambient air quality data such as visibility, particulate
loadings, and air pollution episode data since current
monitoring will be inadequate for these purposes. However,
visibility observations from Coeur d'Alene Airport will
be used in making post-season assessments of impact there.
3.5.1 Visibility/Complaints
Prevailing visibility will be a factor in establishing
burn releases in the area. It will be tracked formally
and informally to quantify overall air quality as well as
the intensity of smoke intrusions. In addition, reduced
visibility due to field smoke in certain key communities
will be reason to curtail burning upwind of those areas.
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These communities are Spokane, Coeur d'Alene, Post Falls,
Hayden Lake and Liberty Lake. Additional areas identified
in Figure 3-4 will be protected also. Burning will be
restricted in areas upwind of these visibility protection
areas to avoid direct plume impact.
Complaints are a measure of air quality and will be used
in identifying affected areas where burning may need to
be limited beyond that which has been authorized already.
Complaints will be recorded by ES staff, Division of
Environment (Coeur d'Alene), IGGA and SCAPCA and compiled
annually. They will be used as a non-specific but
important measure of the program's success.
3.5.2 Particulate Monitors
Nephelometers, high volume samplers and other particulate
measuring instruments, as currently available in Northern
Idaho, cannot provide information in a time frame to be
of value to smoke managers in controlling burning. There-
fore, routine interrogation of real-time particulate
monitors is not planned for the 1982 season.
The nephelometers operated by SCAPCA in Spokane (and any
others that may be approved for northern Idaho) are sensi-
tive to field burning smoke and will be used to retrospec-
tively quantify smoke intrusion intensity and duration.
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3000 ft. MSL Contour Line
Visibility Protection Area
Figure 3-4.
Visibility protection areas - a one mile (1.6 Km) wide
protective area around identified cities, recreational
areas, and airports. A recommended smoke management
goal would be to prevent visibility reducing smoke
intrusions into these areas.
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3.5.3 Air Pollution Episodes
Air pollution episodes in this area usually occur in the
winter due to high levels of carbon monoxide (CO) in the
city of Spokane. TSP and ozone are not a problem. How-
ever, field burning advisories will be adjusted to mitigate
any potential effects due to field burning should it be
necessary.
3.6 Determination of Acreage for Burning
Because burning on the Rathdrum Prairie will be conducted
only after direct contact between the burning crew or grower
and the program manager and weather forecaster, the avail-
ability and conditions of individual fields should be
well known at the time of a burn request. Tracking these
factors will be intrinsic therefore to the Rathdrum opera-
tion. Such tracking in southern Kootenai, and Benewah
counties will be accomplished at the fire district level.
Direct contact between burn managers, fire safety agents
and growers is anticipated to result in a good understanding
of local field and burning conditions.
3.6.1 Determination of Burn Areas
Areas for burning will be chosen primarily on the basis
of wind direction. Though the effects of wind speed and
thermal stability will be considered, areas of concentrated
burning will be selected downwind of major population
areas, highways and airports. Upwind burning of these
areas will be allowed only at a very reduced level when
3-13
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light surface winds and good vertical mixing are suffi-
cient to maintain acceptable surface air quality.
Wind flow patterns will be developed for both surface and
upper levels, particularly the top of the mixing layer
since the major proportion of the smoke will be concen-
trated here. Upper level flow directions will be based
upon routine pilot balloon and rawinsonde data received
throughout the day. From these wind directions and
allowing for transverse horizontal dispersion, potential
impact areas at long distances, 10 to 60 miles (15 to
100 km) downwind, will be identified for any proposed
burning. If such trajectories indicate impact on major
cities or other sensitive areas, burning will be restricted
accordingly in the proposed area. ("Upwind for a given
receptor (city, sensitive area, etc.) will include any
area where, if pollutants were emitted, some portion
would, through advection and dispersion, reach the
receptor.) Often the "backward" plume concept will be
applied to the wind flow field to determine areas from
which burning emissions would cause receptor impacts.
Surface wind flow fields will be developed in a similar
manner based upon wind observations, augmented by smoke
observations and experience with local terrain-induced
flow phenomena. Since information on local surface winds
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will be available on a real-time basis, revisions to the
surface flow field will be made routinely throughout
each day.
The potentially large number of permutations of surface
and transport winds may be limited to a few regimes typi-
cally observed in the Spokane/Coeur d'Alene area. These
regimes and likely areas of burning are summarized in
Table 3-1.
When possible operators will make use of very light surface
winds to maximize plume rise. Under this conditions, upper
level transport winds must be sufficient (10-15 miles per
hour) for smoke to travel beyond sensitive areas within a
few hours. Light surface winds also will be used near
sensitive areas, even though directions are somewhat less
certain, in order to take advantage of good burning and
plume rise conditions. Periods with high surface wind
speeds (>15 knots) will not be utilized due to plume
fracture and fire safety concerns.
Use of upslope/downsloped surface flow to burn certain
fields in critical locations will continue, but only
under very close monitoring of low level wind flows.
Bunder appropriate conditions, easterly, downslope winds,
prevalent in morning, will be utilized to burn fields
near smoke sensitive areas on the eastern perimeter of the
Rathdrum Prairie. After some period of westward drift
on the waning downslope flow, developing westerly surface
winds normally carry the now dispersed plume back toward
the east.
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TABLE 3-1
GENERALIZED IGGA FORECAST CRITERIA
FORECAST ELEMENT
COMMENTS
TRANSPORT WIND DIRECTION
Southwesterly
Easterly
Northeasterly
Areas favorable for burning
Spokane Valley, Foothills,
Rathdrum Prairie
S. Spokane Co.
S. Kootenai Co.
S. Spokane Co.
S. Kootenai Co.
WIND SPEEDS
Transport (Upper Level) Winds:
Should be 10-20 mph
Lower speeds provide too slow
of clearing and allow downward
diffusion over protected areas.
Surface Winds:
Should be 6 - 10 mph
Higher speed fracture convective
column; lower speeds usually
too variable
TEMPERATURE PROFILE
No low level stable layers
RELATIVE HUMIDITY
Low humidity preferrable but
RH much less significant a
factor than other criteria
CLOUDINESS AND
PRECIPITATION
Cannot burn during and after
precipitation; Cloudiness may
signal useful ventilation
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Because the timing of the burning with respect to the
change in wind direction is critical, if smoke entrained
in surface layers is not to impact Spokane and other
smoke sensitive areas on the west of Rathdrum Prairie,
ignition times will be closely controlled so as to coin-
cide with the latest forecast for wind directions change.
Such precise control of burning requires: 1) Use of
short forecast periods; 2) Close monitoring of meteorolo-
gical conditions; and 3) Immediate communications with
the field personnel and accordingly it will only be con-
sidered when all three conditions are met.
Parameters -affecting transverse dispersion are extremely
difficult to prejudge and such estimates will be based
largely upon general experience under similar conditions
and the results of test fires or scheduled burns already
in progress. Significant terrain features and bodies of
water which can greatly affect dispersion will be taken
into account in planning burning activities.
3.6.2 Determination of Amounts of Burning
The amount of burning to be authorized will be based on
the program manager's judgment of downwind effects and
acceptable air quality. The process of matching of
emissions to ventilation conditions will be accomplished
by evaluating fields on a case-by-case basis and weighing
the anticipated combined effects with those from other
authorized fields. The manager will consider at least
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the following factors before making a decision regarding
burning:
1. Ventilation conditions (surface and transport wind
speeds and directions, turbulence, atmospheric
stability);
2. Plume characteristics (mixing depth, surface wind
speed, field fuel conditions);
3. Special area concerns (heavily populated areas,
highways, problem terrain, airports, identified
visibility protection areas);
4. Field conditions including fuel type, loading and
moisture content, adjacent smoke sensitive areas,
capability of crew conducting burning, and field
size, shape and acreage. (In general, burning will
remain restricted after periods of rainfall with
about one day's drying required for each 0.1 inch
of rainfall.)
5. Air quality considerations (effects on visibility
and particulate loading, exposure time); and
6. Fire hazard considerations (adjacent woodlands,
forests and other crops, wind speed, temperature,
relative humidity, fuel conditions, Department of
Lands burn advisories).
Although burning may be denied in consideration of one
or more of these factors, burning releases will not be
tied to specific values for mixing height, fuel moisture
3-18
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content or other significant parameters. In general,
however, field burning will not be conducted until any
existing inversion is totally "broken up." This allows
maximum air volume for dispersal of the smoke. When the
atmospheric structure is such that other stable layers may
hinder vertical movement, whether or not an inversion is
present, burning will remain restricted unless vertical
mixing heights of 3500 feet or greater are present. However,
this restriction will not apply to fields located on the
eastern edge of the Rathdrum Prairie in order to to take
advantage of the upslope/downslope wind direction change
often associated with inversion breakup in this area.
3.6.3 Modifications to Areas and Amounts of Burning
Burning authorizations issued by the program manager will
be amended as weather conditions change, or ambient smoke
levels or other factors become unacceptable. These changes
will be communicated by telephone or radio to the burning
crew or grower affected.
3.6.4 Coordination with SCAPCA
Each day after development of the daily burning forecast
and identification of proposed areas for burning, but prior
to release of any significant burning the Idaho program
manager will contact the Spokane County Air Pollution Control
Authority (SCAPCA) program director to discuss proposed
burning activity in Spokane County. At this time, (approx-
imately 10 A.M.) potential burning activity will be assessed
3-19
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and decisions made to avoid excessive impacts in any
areas. Anticipated impact areas will be identified, as
well as the expected severity and duration of any smoke
intrusions.
When deemed necessary the Idaho Program Manager will seek
reductions in proposed burning in Spokane County to stem
anticipated excessive impacts in Idaho.
Each day the Idaho Program Manager will contact the
SCAPCA program director to identify and discuss the actual
impacts of burning just completed. Estimates of impact
areas, severity and times of intrusion will be made as
well as recording of complaint totals. Attempts will be
made at preliminarily identifying the field(s) implicated
in the smoke problem. The results of these discussions
with SCAPCA will be entered in an appropriate log for
permanent record.
The overall process of developing an issuing burn authori-
zations and tracking resulting burning is displayed
schematically in Figure 3-5. Responsible parties for
each function are identified.
3.7 Authorization of Burning
All grass seed field burning in Northern Idaho will require
authorization by the program manager. On the Rathdrum Prairie,
such authorizations will be issued directly to seed growers.
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COLLECT WEATHER DATA
NWS, IGGA
I
ANALYZE DATA AND
PREPARE FORECAST
IGGA
PREPARE BURNING
ADVISORY
IGGA
1
REVIEW FORECAST AND IGGA-PREPARED
ADVISORY
PM
CONSULT WITH SCAPCA
PM
±
ISSUE BURNING AUTHORIZATIONS AND
ADVISORIES p(v,
RESPONSIBLE PARTY
IDENTIFICATION KEY
FPO - Fire Protectection
Organization
FS - ES Field Staff
IGGA - Intermountain Grass
Growers Association
Staff
NWS - National Weather Service
PM - ES Smoke Management
Program Manager
RECEIVE
t
NECESSARY
PERMITS
AND AUTHORIZATION
M
G
t
ISSUE
PERMITS
FPO
1
Figure 3-5.
Flow diagram illustrating
daily forecast development
and burn authorization
process
CONDUCT BURNING
G
t
REPORT ACCOMPLISHED
BURNING
G
L
OBSERVE
BURNING
FS
1
ID POTEN-
TIAL VIOLA-
TIONS FS
I
DOCUMENT AND ANALYSE BURNING
AND EFFECTS PM
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In other areas, the authorizations will be delivered through
the Department of Lands, fire permit-issuing agents in com-
pliance with the daily restrictions set forth by the program
manager.
Authorizations will include a brief weather discussion and
at least the following:
1. Identification of the field(s), areas and acreage(s)
affected;
2. An earliest ignition time; and
3. A latest time for ignition to be completed.
Authorizations may also include restrictions or guidance
regarding fuel conditions, wind direction or speed, ignition
method or other factors important to smoke dispersion.
Scrupulous records of authorizations will be maintained for
use in subsequent smoke intrusion analyses or enforcement
actions. Proposed forms for recording authorization data
are shown in Figures 3-3 and 3-6.
3.8 Use of Communications
Routine communications, including authorizing burning,
regarding field burning activities will be handled by tele-
phone. To the extent possible in the Rathdrum Prairie
area, use will be made of the IGGA radio network that will
maximize direct communication between most parties involved
in the program.
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Where possible the program manager and meteorologist will
take advantage of the existing on-farm radio systems.
However, these arrangements will rely upon the availability
of an individual to relay or repeat messages. Under such
circumstances the program managers will feel less freedom
in authorizing burning since the initiation of the burning
must rely upon rebroadcast, subsequent repetition, or hand-
carrying of the authorizing message. Under atmospheric
conditions requiring precise control of burning, it is
anticipated that program operators may limit authorizations
to fields with which there is direct communication.
3.9 Program Documentation
Well organized records of weather data, air quality data,
burn releases and acreage accomplishment will be maintained
on a routine basis by all ES participants in field burning
management. Such records will establish a data base to be
used for subsequent program evaluation, improvement and
quality assurance, as well as, supporting burn management
decisions in any litigation regarding burning.
Where not already in use, standardized procedures will be
adopted for the gathering of information and issuance of
advisories. These procedures will be facilitated through
use of standard forms, logs, checklists and flow diagrams.
Suggested formats for logging daily burning activities
and the collection of remote weather data are illustrated
in Figures 3-6 and 3-7.
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DAILY BURN ACTIVITY LOG
DATE
GROWER
NAME
FIELD
ID
NUMBER
NUMBER
ACRES
PROPOSED
AUTHORIZED
START TIME
ACTUAL
IGNITION
TIME
NUMBER
ACRES
COMPLETED
COMMENTS
Figure 3-6. Proposed form for recording daily burning activity
3-24
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REMOTE WEATHER LOG
DATE
SITE
(NAME/NO.)
TIME
WD
WS
VISIBILITY
COMMENTS
Figure 3-7,
Proposed form for recording daily surface weather data from
remote meteorological instruments
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