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.






                                3-10

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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.
                             3-11

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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.
                                 3-12

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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

-------
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
                         3-14

-------
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.
                       3-15

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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
                               3-16

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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






                                 3-17

-------
 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

-------
       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

-------
        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.
                                 3-20

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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
                                                  3-21

-------
      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.
                               3-22

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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.
                               3-23

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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

-------
                               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
                                          3-25

-------