EPA910/F-01-007
vvEPA
United States
Environmental Protection
Agency
Region 10
1200 Sixth Avenue
Seattle WA 98101
AlasKa
Idaho
Oregon
Washington
Office of Air Quality
November 2001
Agricultural Burning
Stakeholder Forums:
Putting the Pieces Together
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Agricultural Burning
Stakeholder Forums:
Putting the Pieces Together
Prepared by:
U.S. Environmental Protection Agency
Region 10, 1200 Sixth Avenue
Seattle, WA 98101
Scott E. Downey
Office of Air Quality
downey. scott@epa. gov
Donald M. Martin
Coeur d'Alene Field Office
martin.don@epa.gov
EPA 910/F-01-007, November 2001
PROTECTED UNDER INTERNATIONAL COPYRIGHT
ALL RIGHTS RESERVED
NATIONAL TECHNICAL INFORMATION SERVICE
U.S. DEPARTMENT OF COMMERCE
NTT1S,
REPRODUCED BY: »•=«• -="^
U.S. Department of Commerce
National Technical Information Service
Springfield, Virginia 22161
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Agricultural Burning Stakeholder Forums:
Putting the Pieces Together
Introduction
The U.S. Environmental Protection Agency (EPA) Region 10 office sponsored four
Agricultural Burning Stakeholder Forums throughout the Pacific Northwest from January to
May 2001. The forums attracted about 300 participants in five-hour sessions in:
*• Coeur d'Alene, Idaho on January 27;
*• Pendleton, Oregon on February 24;
*• Moscow, Idaho on March 10; and
*• Pasco, Washington on May 12.
This report provides an overview of some of the technical information heard at the
forums, a summary of stakeholder perspectives and concerns, and some new information on
efforts being made toward solutions.
Purpose and Goals
The forums were held to create a setting conducive for interested and affected parties to
learn more about the many pieces of the puzzle related to agricultural field burning. Experts in
agriculture, health, and government were invited to share information and interact with
stakeholders in order to meet the following goals:
v " ~ O O
»• Increase knowledge of the different sides of the issue, including technical, human,
environmental, and economic aspects;
>• Improve understanding of the range of people's concerns and questions;
»• Develop ideas for workable solutions; and
>> Increase opportunities for ongoing participation and trust among stakeholders.
The forums were designed with extensive input from various partners and co-sponsors and
tailored to reflect local concerns and conditions. Each forum was designed around three main
themes: 1) the Agricultural perspective, 2) the Public Health perspective, and 3) a moderated
panel discussion with Government agency representatives.
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Summary of Key
Messages
Agriculture: Growers and
other agricultural experts
explained that field burning
was a tool used to manage
crop residue, diseases, and
pests, or to increase crop yields
and the economic viability of
farms. Depending on the crop,
farming method and other
factors, we heard that some
growers burn only as a last
resort, while others may use
the practice every year.
Support was expressed for
more research and education
on alternatives to burning, such
as direct seed farming systems,
and for more economic
incentives to help reduce or
eliminate burning.
Forum Partners
Representatives from the following agencies and
organizations worked cooperatively with EPA to help plan,
host, or conduct the forums.
Agency for Toxic Substances and Disease Registry
Benton County Clean Air Authority, Washington
Coeur d'Alene Tribe
Confederated Tribes of the Umatilla Indian Reservation
Idaho Department of Agriculture
Idaho Department of Environmental Quality
Nez Perce Tribe
North Idaho Farmer's Association
NW Research Center for Particulate Air Pollution & Health
Northwest Dynamics
Oregon Department of Environmental Quality
Oregon State University
Pacific Northwest Direct Seed Association
Pacific Northwest Fiber
Umatilla County Soil and Water Conservation District
Umatilla County, Oregon
University of Washington
Washington Department of Ecology
Washington State University
Whitman County Health Department
Health: We heard that smoke
from field burning can cause
adverse health effects,
especially to those with respiratory diseases like asthma. Concern was raised over why the
practice was allowed to continue, considering the scientific evidence which correlates air pollution
with increased illness and death, and the many complaints received by agencies. Support was
expressed for more research into the health effects of smoke (especially short-term peak
exposures), for more air quality monitoring sites, and for making more real-time air quality
information available to the public.
Government: We heard from various agencies at the federal, state, tribal, and local level that
there is a wide range of tools and approaches used for field burning in the Northwest. Some
jurisdictions operate regulatory permit-based programs, while others have non-regulatory or
voluntary programs. Legal authorities and resources to implement programs are diverse. Some
agencies are more responsible for environmental and public health protection, while others assist
the agricultural community. Stakeholders expressed many opinions over government roles and
desired level of involvement. Some wanted the agencies to do more to control or eliminate field
burning, while others wanted more local flexibility and less regulatory control.
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Putting the Pieces Together
After each forum, an information package was mailed to participants who provided their
address. The package included copies of speaker presentations and the comments and questions
from participants recorded on flip charts at each table. Detailed forum summaries are available
online from EPA Region 10's website at: http://www.epa.gov/rlOearth/ (then click on the Air
button, and then Agricultural Burning). See Appendix 1 for a summary of stakeholder views.
Putting the Pieces Together: Agriculture
We heard that field burning is a way for farmers to manage crop residue after harvesting
and to combat crop diseases, insects, and weeds, and that it can sometimes help to increase crop
yields. We also heard about some ways to manage residue with little or no burning, such as
leaving the stubble on the land and then planting directly through it or working it into the soil, or
through removing the straw by cutting, baling, and transporting it to offsite uses.
Growers are concerned that field burning will be taken out of their "toolbox" of
agricultural practices and they will lose the benefits and flexibility of managing residue through
fire. While some said they use the practice on a routine basis, many others burn only as a
"last resort" when other options fail or aren't available. The different approaches are due to a
complex mix of factors, including the type of crop, how fire affects crop yields, the amount of
residue left after harvest, the cost and availability of farm equipment to deal with residue, straw
markets, habit, and lack of experience with alternatives to burning. In general, grass fields are
often burned every year after harvest (August to September) to stimulate growth of the next
year's crop, while wheat fields are typically burned in the Spring to prepare the field for planting
or in the Fall after harvest to remove excess residue.
Many growers said they support greater use of alternatives to burning, but noted that
some were not economically feasible or practical for all crops and locations in the region. For
example, direct seed farming is more applicable to cereal grains like wheat than for grass crops.
Growers would like to see more research conducted on methods to reduce field burning, large-
scale demonstration projects, and more economic incentives that would reduce the economic risk
of using new practices. A number of efforts related to alternatives and incentives are being
pursued and are described below.
Direct Seed Farming Systems: We heard from several speakers and forum participants that
direct seed farming involves using agronomic practices that are generally more sustainable and
environmentally-friendly than traditional methods. The system can include a combination of
planting and growing crops with much less tilling and soil disturbance, planting crops more often
rather than leaving fields fallow for long periods, using a variety of crops and crop rotations, and
leaving more residue on the field after harvest. Direct seed has been shown to improve soil and
crop health by increasing organic matter, carbon storage, and nutrients. It improves soil structure
and water storage and can break down disease and pest patterns. The extra residue protects soil
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from the direct action of wind and water — reducing erosion, windblown dust, and sediment
transport into streams. And because crop residue is seen as a valuable resource to direct seed
farmers, the need and desire to burn the field after harvest can be reduced.
To further the adoption of direct seed farming, there are numerous research,
demonstration, and education projects underway. For example, EPA and the Washington
Department of Ecology are collaborating with the Pacific Northwest Direct Seed Association
(PNDSA), Washington State University, and the University of Idaho to produce a "how-to" video
that will be used for grower education. The PNDSA is a tri-state grower-based organization
committed to increasing direct seed farming. The project will also enhance the PNDSA website
(www.directseed.org) to serve as a clearinghouse of the latest direct seed information.
In May 2001, the EPA, USDA Natural Resources Conservation Service (NRCS), and the
PNDSA hosted a regional meeting to bring together parties interested in expanding the adoption
of direct seed agriculture through a variety of means, including increased federal funding,
collaborative projects, technical assistance, research, and alternative crop markets. The meeting
was an excellent first step in bringing all the key players together at one table to discuss options.
Alternatives to Burning for Kentucky Bluegrass: EPA is working closely with the
Coeur d'Alene Tribe, the Nez Perce Tribe, and the University of Idaho to study alternatives that
would reduce or eliminate the need for burning of Kentucky Bluegrass crops. The $200,000+
project involves identifying potential alternatives, field testing, evaluating results (including
economic and environmental trade-offs), and providing education on the results.
Offsite Straw Utilization: Another way to reduce field burning and smoke emissions is to cut
and collect some of the crop residue and haul it away for use offsite. There are several examples
across the region where straw is baled and used locally, or sent to other states, Canada, or
overseas. Straw has a variety of uses, including animal feed, mulch, ethanol production, and as a
source material in the manufacture of bio-based products, such as paper and particle board. The
Coeur d'Alene Tribe recently announced that starting next year, all grass and wheat growers on
tribal lands will be required to remove up to 90% of their straw before burning. This "bale and
burn" method will help to support the Plummer-based Pacific Northwest Fiber plant, which
produces panel board.
The State of Washington recently created a Straw Utilization Task Force to explore the
many options, barriers, and opportunities for use of excess straw. EPA participates on the Task
Force and has contributed $190,000 to a project (FiberCrops) which is helping communities to
find practical and economic solutions for use of crop residues as a source material for
manufacturing paper, building materials, textiles, and other fiber-based products (for more
information, see http://www.fiberfutures.org/straw/).
Emission Studies: Northwest wheat and grass grower organizations, state agencies, Northwest
land grant universities, and EPA have been pooling resources to conduct scientific studies that
better quantify and characterize smoke emissions when fields are burned. The data obtained will
help answer questions on how much particulate matter is produced using different burning
methods and what chemical compounds are in the smoke and in what amounts.
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Putting the Pieces Together: Public Health
Concerned individuals and health experts at the forums described how smoke from field
burning can create a public nuisance and present a public health hazard. We learned that hundreds
of people take the time to file complaints each year about field burning and to question why the
practice is allowed. While some are upset with the nuisance odor and haze, most people say that
they or a family member experience health problems associated with the smoke. Reported
symptoms include trouble with breathing, sore throat, coughing, wheezing, stinging eyes, and
headaches. Some say they have to increase their medication use during the burn season or make
additional trips to the doctor or hospital. Others say their lives are disrupted physically,
emotionally and financially due to increased illness, medical costs, work and school absences, and
limits on normal daily activities. Some report feeling trapped in their homes during smoke
intrusions or having to leave the area during the day or for an entire burn season. Others say their
social events have to be cancelled or that their business is suffering economically.
We also heard from two local physicians who provided firsthand accounts of health
impacts in their communities. They see a rise in their patients' respiratory problems, need for
medication, and office visits during the burn season. We also learned from scientists who study
health effects and air pollution that:
*• Particulate matter (PM) air pollution originates from a variety of sources, including cars,
trucks, power plants, industrial processes, fireplaces, backyard burning, agricultural and
road dust, and biomass burning (e.g., wildfires, controlled forest burns, and field burning);
*• Particles between 2.5 and 10 micrometers in diameter are called "coarse" particles or
PM-10, while particles less than 2.5 micrometers are "fine" particles or PM-2.5;
»• Combustion sources, like field burning, generate a complex mixture of fine PM, gases,
and toxic organic compounds;
>• Human and animal studies show that exposure to PM is a health concern;
*• Exposure to fine PM has been correlated with an increase in health problems such as
asthma attacks, decreased lung function, cardiovascular changes, more medication use,
clinic and emergency department visits, hospitalizations, and premature deaths;
* Most at risk for illness are people with chronic respiratory diseases (such as asthma,
emphysema, and bronchitis), cardiovascular diseases, respiratory infections, the elderly,
and children;
*• Even children without any existing illness can be affected because their lungs are still
developing and they are generally more susceptible to environmental threats;
> Many questions remain, however, such as the lower threshold for health effects (how
much PM and how long of an exposure does it take?), the exact biological mechanisms
that cause health effects, why there has been an increase in asthma, the role of co-
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pollutants, the best way to monitor human exposure (central-site vs. personal air quality
monitoring), and the validity of epidemiological studies.
We also heard concerns that the National Ambient Air Quality Standards (NAAQS)
established for particulate matter by EPA under the federal Clean Air Act may not adequately
protect the health of susceptible people during smoke intrusions from field burning. There are
several reasons for this concern, including:
*• The only national standard being implemented is for PM-10;
> The standard is based on 24-Hour and annual average PM levels, not the short-term peak
exposures over an hour or two typically seen during smoke intrusions from field burning;
> It is these short-term "spikes" that may cause the most drastic acute health effects; and
*• Air quality monitors used for measuring air concentrations are not necessarily located in
the path of a smoke plume.
The law requires EPA to periodically review and update the NAAQS to ensure that they
provide adequate health and environmental protection. EPA updated the PM standards in 1997 to
include 24-hour and annual PM-2.5. However, the decision to revise the standards was
challenged in court by a number of parties. In a recent decision, the Supreme Court unanimously
upheld the constitutionality of the 1970 Clean Air Act provision that authorizes EPA to set
national air quality standards at levels necessary to protect public health and welfare (without
consi:1 ?ring the economic costs of implementing the standards). EPA is now in the process of
reevaluating the standards for PM proposed in 1997 and is supporting and compiling research on
what kinds and what levels of PM are unhealthy, and over what time periods. Documents related
to this review are available at http://www.epa.gov/ttn/oarpg/ramain.html.
There are many other efforts underway within the Pacific Northwest to further
understanding of air pollution and health effects. A few are described below.
EPA N\V Research Center for Particulate matter and Health: Established in 1999 at the
University of Washington, the "PM Center" is one of five around the country funded by EPA to
study the effects of particulate air pollution on human health. The Center's multi-disciplinary
teams of scientists are looking at the relationships between ambient air quality, population
exposures, and individual exposures in order to better understand and prevent PM-associated
health effects. Mechanisms of PM toxicity and potential biomarkers are also being studied.
Jane Koenig, PhD, the Center's Program Director, spoke at the forum in Coeur d'Alene. The
Center can be found online at http://depts.washington.edu/pmcenter/.
Candis Claiborn, PhD, of Washington State University, leads the Center's research in
eastern Washington, and spoke at the Pasco forum. Dr. Claiborn is collaborating with EPA,
Eastern Washington University, the Washington Department of Ecology, and the Idaho
Department of Environmental Quality on projects to better monitor and model the transport and
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dispersion of smoke from field burning. The research team is measuring the particulate
concentrations and chemical compositions of smoke sampled downwind of wheat stubble burns.
Fire, Smoke and Health Workshop: On June 5 and 6, 2001, a workshop was held at the
University of Washington that focused on the public health implications of adverse air quality
resulting from wildfire smoke and related events such as prescribed forest fires and agricultural
burning. The workshop brought together scientists and air quality specialists from across the
country and the Northwest to identify current research and research needs, to propose health
advisory levels for short-term exposures, and to develop outreach and educational materials for
health and air pollution agencies to use in the event of smoke emergencies. An excellent
collection of smoke and health related guidance documents, policies, technical articles, workgroup
products, and outreach materials can be found at the workshop's website at
www.firesmokehealth.org.
Idaho Proposes Revisions to Air Pollution Emergency Rule: In November 2000, the Idaho
Board of Environmental Quality adopted a temporary rule to add PM-2.5 action-levels and
criteria to their Stage 1 Air Pollution Forecast based for both 24-hour and 1-Hour averaging
times. After several months of negotiated rulemaking and public participation, the Idaho
Department of Environmental Quality is proposing language for a revised temporary rule that is
expected to become effective upon the conclusion of the 2002 session of the Idaho Legislature.
Putting the Pieces Together: Government
Representatives from EPA, state, tribal, and/or local agencies participated in moderated
panel discussions at each of the forums. Officials were asked to briefly explain their agency's
unique role in field burning, and then answer questions from the audience. We learned there are
many approaches and authorities being used across the region to manage field burning - from
regulatory-based permits to voluntary programs. We heard that an agency's involvement is
generally a matter of their statutory and legislative authority, financial resources available to
develop and operate programs, and how important the issue is considered.
The wide range of program effectiveness found throughout the Northwest is one reason
that EPA Region 10 became more involved in the issue. While there is not a one-size-fits-all
approach that can be applied everywhere, EPA is helping individual jurisdictions develop and
implement more effective programs through financial and technical assistance, supporting science-
based research into alternatives to burning, supporting additional health -.Tect studies, and
providing leadership on issues of "regional" concern, such as cross-border movement of smoke
and interagency coordination. To guide these efforts, a Regional Strategy was developed, which
is summarized below:
LONG-TERM GOALS
1) To prevent agricultural burning from endangering public health and safety.
2) To minimize or prevent other impacts such as regional haze and nuisance smoke.
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OBJECTIVES
1) To understand, communicate, and implement our responsibility for field burning in the
Northwest (Idaho, Oregon, Washington, and Tribal lands).
2) To help find and support non-burning alternatives, economic incentives, and agricultural
best management practices to significantly reduce the number of acres burned and smoke
emissions.
3) To develop a regional approach involving local, state, federal, and tribal jurisdictions that
results in more consistent and effective programs to control and reduce field burning and
smoke emissions.
4) To improve the effectiveness of using National Ambient Air Quality Standards (NAAQS),
emergency action-levels, and air quality monitoring networks to protect public health.
5) To promote better science-based information and understanding of human exposure and
health effects from smoke and its constituents, especially the effects of short-term
exposure.
6) To determine the status and be able to measure the progress of jurisdictions in managing
field burning and reducing impacts.
The full Strategy can be found at the EPA Region 10 website at: http://www.epa.gov/rlOearth/
(then click on the Air button, and then Agricultural Burning). To date, EPA has contributed
nearly $2,000,000 toward projects that support the Strategy (see ix 2).
Efforts by EPA are only a small part of the overall work being done throughout the region
on field burning, as individual programs are actually developed, staffed and administered at the
state, tribal, and local level. It is not the purpose of this report to outline how each jurisdiction
operates, or their effectiveness. Descriptions of individual field burning programs and agency
contacts in 21 western and mid-western states and 19 local areas can be found in an Agricultural
Burning Smoke Management Survey that was prepared for the Western Governors Association.
This document is available at http://www.airsci.com/FEJF/agsurvey.pdf. Please note that it does
not profile tribal programs. Please contact individual tribes or EPA for this information.
The forums highlighted many actions that have been taken within the last year by agencies
related to field burning. Some of these and newer examples are described below:
Idaho Enacts Field Burning Rules: Idaho recently enacted temporary rules governing crop
residue disposal via field burning. The rules were effective July 1, 2001, and will go before the
2002 Idaho Legislature for review. The new rules require producers who will be burning their
fields to register the location of fields and the number of acres to be burned with the Idaho State
Department of Agriculture. The rules state that the Director will designate, for a given airshed,
burn or no-burn days; the hours that burning will be permitted; and the number of acres to be
burned based on the recommendation of the Idaho Department of Environmental Quality. A copy
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of the rules is available by calling 208-332-8620, or at the Idaho State Department of
Agriculture's website at http://www.agri.state.id.us/Crop/idapa_02.htm.
Clearwater Airshed Pilot Smoke Management Plan: This cooperative project between the
Nez Perce Tribe, the Idaho Department of Environmental Quality, and EPA will support the
development and implementation of a smoke management plan on the Palouse and Camas Prairies
in northern Idaho's Clearwater Airshed. The plan will address reasonable options to reduce
smoke and the adverse impacts of smoke generated by field burning during August through
October. The project will serve as a model for how smoke from agricultural burning might be
successfully controlled in an area of mixed geography, multiple jurisdictions, and shared
responsibilities.
Washington Web-Based Burn Permit System: The Department of Ecology is improving their
field burning permit program by developing a centralized web-based system to provide staff with
more accurate and timely permit data. The system would allow the local permitting authority in
each County, and/or growers, to enter, update, and view permit information such as acres and
crops to be burned, location of fields, burning justification and alternatives considered, practices
to reduce emissions and ensure fire safety, and post-burn reports. When combined with
meteorological information, Ecology burn managers will be better able to minimize smoke
impacts and notify the public in areas that may be affected. Longer range plans call for the data to
be made viewable through a Geographic Information System (GIS) mapping program to further
aid in making daily burn call decisions. For more information on Ecology's field burning
program, see http://www.ecy.wa.gov/programs/air/agricultural_information.htm.
Field Burning in Oregon: Agency jurisdiction for field burning in Oregon depends on location.
On the west side, in the Willamette Valley, the Oregon Department of Agriculture (ODA),
Natural Resources Division, Smoke Management Program is responsible for overseeing open field
burning, propane flaming, and stack burning of all perennial and annual grass seed residue and
cereal grain residue within the Willamette Valley. It is illegal to burn any field residue in the
Valley without a permit. In the 1960's, burning exceeded 300,000 acres per year in the Valley,
but State action required a phase down in field burning to a present level of about 40,000 acres
(not including some other agricultural burning methods such as stack and propane flaming). ODA
operates an extensive research program each year for developing alternatives to field burning. For
the 1997-99 biennium over $1,000,000 was budgeted for research and development. Projects
included developing alternative crops, alternative field management practices, and straw
utilization. Funding comes primarily from fees paid by grass seed growers. For more information,
see http://www.oda.state.or.us/Natural_Resources/smoke.htm.
East of the Cascades, the authority for regulating field burning resides mainly with local
government. To date, ordinances have been adopted in Jefferson, Umatilla, and Union Counties.
The Oregon Department of Environmental Quality assists in reviewing and revising these local
programs.
Air Quality Monitoring: Many individuals at the forums said they'd like to see more air quality
monitors in their area and have better access to monitoring information. We learned that air
quality monitoring can have many practical uses, such as tracking smoke emissions in real-time
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during a burn event, informing the public of potential smoke impacts, triggering emergency
actions such as burn bans, providing better scientific understanding of actual emissions from field
burns, and documenting exceedances of air quality standards.
In the last year, both Idaho and Washington used funding from EPA and their own
resources to increase the network of air monitors in areas at risk to impacts from field burning and
from other major smoke sources such as wildfires and prescribed forest burning. EPA and the
U.S. Forest Service also assisted Union County, Oregon, in locating a new real-time PM-2.5
monitor near LaGrande, Oregon. The Nez Perce Tribe is adding a new monitor on tribal lands as
part of the Clearwater Airshed project. Even with widespread support for more monitoring of air
quality, progress is limited because the equipment is very expensive to acquire, install, and
operate.
Another frequent message heard at the forums was a desire for better public access to air
quality information, especially real-time data that could warn of impending smoke intrusions into a
community. The availability of this kind of information is still limited, but is increasing as a result
of several projects or programs. For example, the Air Quality Index (AQI) is required to be used
in large metropolitan areas (more than 350,000 people) for reporting daily air quality in
newspapers, radio, television, and the Internet. The AQI indicates how clean or polluted the air is
on a given day, along with associated health concerns. Although it is not required, some agencies
in the region now report the AQI for many smaller communities as a public health service. To
find out if AQI reporting is available for your local area, you can start at EPA's AirNow website
(www.epa.gov/airnow) which contains links to many state and local AQI sites. Some states in the
region are in the process of upgrading their telemetry equipment and calibrating monitors to
increase the number of sites with the capability of reporting air quality in real-time to the public.
Smoke Management: Smoke management is the use of policies and procedures to minimize
smoke impacts from burning. The topic was discussed primarily at the Moscow and Pasco
forums. A Smoke Management Program (SMP) usually includes the following components:
1) Authorization to Burn
- authorities responsible for implementing the SMP
- process for granting approval to bum
2) Emission Controls and Fire Safety
- alternatives to burning
- metric^ to reduce smoke
- fire safety procedures
3) Program Operation
- acres, locations, crops, etc. to be burned (emission inventory)
- smoke-sensitive areas (towns, roads, schools, hospitals, etc.)
- meteorological data to predict smoke direction, elevation, and dispersion
- communication of burn decisions
- monitoring of air quality during burns and appropriate actions if problems arise
- collection of post-burn data
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4) Information and Education
- public notice prior to burns
- outreach on purpose of burn and potential impacts
- actions to avoid health impacts
- cross-border and interagency coordination
5) Oversight and Evaluation
- compliance/enforcement of SMP
- assess air quality impacts
- collect, assess, and respond to complaints
- revise program as needed
Smoke management is often controversial because it is not a fail-safe way to protect the
public from smoke impacts. Programs may be rudimentary or poorly-operated, or there may be
unpredicted changes in weather patterns that result in impacts even from the best run programs.
Still, smoke management is widely used to minimize the effects of fire emissions on public health
and welfare and significant resources are being invested into the development of better technical
tools for smoke management.
Burning Information Systems: Northwest agencies and universities are collaborating on a
number of projects to improve smoke management operation and public access to information.
For example, a project called BlueSky-RAINS is integrating two ongoing technical efforts -
EPA's Rapid Access INformation System (RAINS) and the U.S. Forest Service's BlueSky
project. RAINS is being developed as a user-friendly system for EPA staff to view, organize, and
map a wide array of environmental information from desktop cr-nputers. The BlueSky project is
combining state-of-the-art information on fire emissions from planned forest and agricultural
burning activities with real-time, high-resolution, meteorological model (MM5) predictions and
air quality dispersion modeling. The result will be a comprehensive web-based information system
related to vegetative burning activities and potential impacts throughout the Pacific Northwest.
BlueSky-RAINS will focus initially on linking to existing information such as fire emission
sources, ambient air quality, meteorological data, remote sensing, land use, and agency programs
and activities. Later phases will provide more comprehensive capabilities, such as predicting and
displaying local, regional, and transboundary movement of smoke plumes and cumulative effects
within an airshed from multiple emission sources. Such information should be useful to the burn
managers looking for accurate, real-time, predictions of smoke emissions, as well as to the public
(such as smoke-sensitive individuals), local agencies, and the media interr ,ted in learning about
potential fire, smoke, or health impacts for their area. The system is still in the early stages of
development, but early phase information should be available within several months.
Visibility and Regional Haze: Paniculate matter is a significant source of haze and reduced
visibility. In 1999, a national Regional Haze Rule was established by EPA to improve visibility in
national parks and wilderness areas across the country. The rule requires states to develop
programs designed to meet long-term goals for protecting visibility. Since regional haze can be
caused by many sources located across a broad region often covering several states, regional
planning organizations have been formed to help develop the technical and policy tools needed to
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comply with the regulations. One of these is the Western Regional Air Partnership (WRAP), a
collaboration of western tribal governments, state governments and various federal agencies. The
activities of the WRAP are conducted by a network of committees and forums. Since burning of
all kinds (agricultural, wildfire, prescribed fire, etc.) contributes to regional haze, the Fire
Emissions Joint Forum (FEJF) was created. The FEJF is developing a number of policies and
technical products related to fire and visibility protection, including products related to smoke
management, fire emissions inventory and tracking, alternatives to burning, and public education.
For more information, please see http://www.wrapair.org/index.html.
Agricultural Air Quality Task Force (AAQTF): The 1996 Farm Bill required the U.S.
Department of Agriculture (USD A) to form a task force made up of experts in agricultural
production and air quality. In 1999, the AAQTF issued recommendations on agricultural burning
to the USDA. Last year, EPA sought public comment on the recommendations to develop EPA
policies to address the air quality impacts of agricultural burning. It will likely be several months
before the policy is completed. For more information, see
http://www.nhq.nrcs.usda.gov/faca/aaqtf.html.
Prescribed Forest Burning and the National Fire Plan: An issue that came up at some of the
forums was why there was so much attention focused on agricultural field burning when
government agencies, especially federal ones, are engaged in prescribed forest burning activities
that also produced significant amounts of smoke. In fact, the practice of using fire to manage
forest lands is increasing in many areas of the west because of the decades-old policy of
suppressing all wildland fires. This has resulted in significant deterioration of forest ecosystem
health and dangerous accumulations of fuels which has greatly increased the risk of having larger,
more severe, high-intensity wildfires.
To help address the situation, prescribed fire activities are guided by fairly mature and
detailed statewide Smoke Management Plans in Idaho, Oregon, and Washington in order to
minimize impacts to air quality. And recently, the U.S. Congress appropriated $2.9 billion for
2001 to help implement a National Fire Plan. The U.S. Forest Service is working collaboratively
with EPA and other federal and state agencies to address air quality concerns as the Plan is
implemented. Many of the efforts underway will also result in better technical tools and improved
coordination of agricultural field burning programs (such as the BlueSky-RAINS project). For
more information, see http://www.fireplan.gov/.
Conclusions
Field burning is a complex issue without easy solutions or quick fixes. We heard from
various stakeholders that no matter what the course, some person or group will be impacted -
either economically, socially, or physically. The stakeholder forums provided much valuable
information for both the participants and for those charged with finding workable solutions.
Clearly, progress is being made on several fronts, such as:
> Increased research and demonstration of feasible alternatives to burning, such as direct
seed farming systems and straw utilization;
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»• Development and implementation of enhanced Smoke Management Programs;
* Improved science-based studies and public outreach on the health effects of smoke;
>• Additional data being collected to better quantify and characterize field burning emissions;
> More air quality monitors being installed and increased public access to data;
>• More effective regulatory programs are being developed or improved, such as for web-
based permitting, statewide rules, and regional haze; and
>• Increased focus and resources on transboundary and interagency smoke issues.
The efforts described in this report are just some of the many that are underway
throughout the region and the country. Some projects will have immediate benefits, while others
are more long-term. Some solutions are community-based, while others are regional in scope.
EPA will continue to work with our partner agencies to reduce field burning and its impacts by
providing regional leadership and assisting those jurisdictions which have the primary
responsibility for protecting air quality and public health. However, it is up to all of us who are
affected - farmers, scientists, regulators, and concerned citizens - to continue putting the pieces of
the puzzle together.
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Appendix 1: Summary of Stakeholder Views
This summary of comments, questions, and perspectives on field burning came from the flip charts
at the four forums. Some have been edited for readability.
Understanding the Agricultural Perspective — What did we learn?
»• Widespread participation, education, and government interest is needed for solutions.
>• Markets for fiber solutions are needed and this is a limiting factor.
> More dependable diversity: straw use, crop markets, infrastructures (like oil press).
*• Burning increases grass seed yields significantly.
* Crop rotation is effective for disease control.
>• Need to invest in straw use alternatives (stubble removal is expensive).
* Direct Seed works and there are many benefits, like leaving nutrients in the field, but more
research needed, especially without burning.
•> Research needed into stubble management, equipment, agronomic practices, economics.
* There are many alternatives to burning.
*• Varieties and species respond differently to burning or not burning.
> Fire is a necessary tool, but more research is needed on alternatives to burning.
> Grass crops reduce soil erosion and protect water quality
»• Develop incentives for environmental practices, e.g., the Harkin Bill Conservation Act.
> Farming is complex - need a systems approach for solutions.
* Carbon storage issue is important to environment (less soil disturbance = more carbon).
*• Carbon credits used to offset fossil fuel burning - could be possible international approach
to offset cost to farmer of change to direct seeding.
*• EPA should get a direct seed proposal to USDA's Agricultural Air Quality Task Force.
What More Do We Need to Know about Agricultural Aspects?
>• Research on burning alternatives, rotation of crops, alternative crops, and burn methods
to reduce smoke.
*• Alternative uses for residue.
*• Impacts of residue removal to soil tilth and organic matter.
»• How can we decrease burning and keep farmers alive and profitable?
>• Economic impacts of burning or not burning.
»• Need more agronomic research, sustainable farming practices.
>• Equipment needs and costs for converting to direct seed.
>• Alternative residue uses: cost, environmental impacts, and research.
»• Is there a difference in quantity of smoke depending on type of crop?
>• Is there a difference in compounds emitted by crop type?
>• Which meteorological conditions are best for burning?
*• What can be done to make alternatives to burning economically viable?
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How do we get started in learning and asking hard questions to motivate change?
What can be done by state and federal governments to improve markets for fiber?
Carbon-stored in soil tillage breaks down organic matter.
Goal is to improve plants to store carbon.
Farm Program incentives should look at a systems approach.
Burn distribution: when, where, how much?
Understanding the Health Perspective — What did we learn?
People with lung and other diseases are vulnerable to smoke.
Emergency room visits increase during burning.
Increasing population means more people exposed.
Pollution from different sources contains different chemicals that affect health differently.
Smoke content analysis is being done.
Smoke from vegetative burning is mostly PM-2.5.
PM-10 may be annoying but PM-2.5 is dangerous.
PM-2.5 particles migrate indoors and may equal ambient levels outdoors.
PM-2.5 is definitely detrimental to public health as the particle's lodge deep in the lungs.
EPA should re-look at air quality standard for short-term PM exposure.
•> Insufficient data so far to establish a short-term standard for PM-2.5.
*• There are not enough continuous monitors distributed around the Pacific Northwest.
>• There are new monitoring stations in Idaho and Washington.
»• There are a lot of gray areas, unknown effects, and studies are inconclusive and confusing.
>• There is controversy over the validity of many PM health studies.
> Relative risk is difficult to understand.
* Need to research the cumulative sources of air pollution.
What More Do We Need to Know about the Health Aspects?
What level of burning is acceptable?
Total cost of burning to society.
Correlation between field burning and air quality.
Percent of PM-2.5 from field burning.
Chemical components of wheat and grass smoke.
Data on agricultural chemicals and residue from burning.
Reports from complaint hotlines.
Barriers to improved continuous monitoring networks with alert systems.
Correlation of local forecasting to making burn decisions.
How to manage airsheds.
Threshold for human health impacts from PM.
Resolve confounding effects of other pollutants (e.g., ozone).
Underlying cause of asthma. Why is there an increase?
EPA needs to look at other sources of burning and their effects.
More coordination between EPA and agencies that manage forest burning.
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Understanding Mandates and Constraints of the Agencies
- Key points from the Regulatory Panels
»• Citizens do make a difference.
> Need continued involvement of all affected parties.
> Idaho is adopting short-term PM action-levels and statewide field burning rules
*• Idaho currently has the densest locations of monitors in the Northwest.
»• Coeur d'Alene Tribe seeks partnerships with the community, EPA and Idaho.
f Many state air regulations are enforceable by EPA.
»• EPA can use Section 303 of the Clean Air Act to prevent health endangerment.
> New regulations are not the preferred or intended approach by EPA.
»• Locally-based solutions are the key, that's what will work over the long term.
>• Airsheds don't recognize political boundaries.
>• Agencies are working for solutions on a regional level, across state and tribal borders.
>• Look at smoke in total - all sources.
* Need to share data and work together (local, state, federal, tribal).
Where do we go from here? Ideas for workable solutions.
Keep all of the stakeholders involved in solving problems.
Continue collaborative problem solving with producers, researchers, agencies and public.
Keep attention on regional issues, but remember that solutions are found and felt locally.
Be consistent across the region from a regulatory standpoint.
Create an early-warning system for smoke so people know about potential impacts.
Put smoke reports on TV and radio, like weather forecasts.
Increase resources for monitoring, weather forecasting, and reviewing data.
Better understand agriculture's contribution to air quality problems.
Have better permit programs.
>• Establish schedules so all growers don't burn at the same time.
>• Clarify and establish criteria for essential burning.
»• Do more research on the health issues.
*• Change federal incentives for crop selection.
>• Reward "good" and penalize "bad" farming practices.
*• Provide incentives to growers to change their practices.
>• Invest in a major commitment to agricultural research.
*• More research into alternatives and implementation of Best Management Practices.
»• More research of farm problems that lead to burning (crop diseases and pests).
>• More research on harvesting Kentucky Bluegrass in alternate years without burning.
> Increase financial/tax incentives to reduce burning.
* Support straw utilization efforts, such fiberboard plants.
> Reduce smoke emissions by baling in areas where feasible.
* Set goals for reductions in burning and measure progress.
>• Educate growers and public on ways to minimize smoke impacts.
»• Promote burning as a last alternative - not the first.
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Appendix 2
EPA Funding to Support Regional Agricultural Burning Strategy
Project Description
Mediation services for field burning lawsuit in
Washington State
Internet-Based Permit System for Agricultural
Field Burning
Cereal-Grain Crop Open-Field Burning Emissions
Study
Fiber Crop Solutions: assist communities in the
Columbia Basin with feasible alternatives to
burning through utilization of agricultural residues
Idaho PM-2.5 Monitoring: new sites to monitor
fine particulates, including smoke impacts from
agricultural and silvicultural burning and wildfires
No-Till Sowing into Irrigated Wheat Stubble
Instead of Burning: agricultural research and
demonstration project
Agricultural Field Burning Smoke Emissions:
Concentration Measurements
Facilitation services for Stakeholder Forums
Assessment of Agricultural Burning by Real-Time
Monitoring of PM-2.5 in Lewiston, Idaho
Amount
$50,000
$60,000
$45,134
$190,000
$225,000
$37,500
$17,019
$16,185
$40,000
Recipients, Contacts and Collaborators
National Center Associates, Inc.
Washington Department of Ecology
Karen Wood, kwoo461@ecy.wa.gov
Washington Department of Ecology
Karen Wood, kwoo461@ecy.wa.gov
Fiber Futures
Jeanne Trombly,
jeanne@fiberfutures. org
Idaho Department of Env. Quality,
Matthew Stoll, mstoll@deq.state.id.us
Washington State University Cooperative
Extension, Lind Experiment Station,
Bill Schillinger, PhD, schillw@wsu.edu,
Washington State University
Candis Claiborn, PhD, claiborn@wsu.edu
NW Dynamics, LLC
Idaho Department of Env. Quality,
Ray Roetman, rroetman@deq.state.id.us
Start Date
March 2000
(Completed)
July 2000
July 2000
August 2000
August 2000
October 2000
November 2000
(Completed)
December 2000
(Completed)
December 2000
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EPA Funding to Support Regional Agricultural Burning Strategy
Eastern Washington Agricultural Burning PM-2.5
Characterization Study: install and operate
additional air quality monitoring sites
Independent Evaluation of Agricultural Burning:
characterize air quality impacts in eastern
Washington and northern Idaho from field
burning
Study of Hydrocarbons, Irritating and Toxic
Phenols, and other Biological Toxics in Smoke
from Burning Wheat Stubble
Support to Fire, Smoke and Health Workshop:
conducted June 2001
Orchard Chipping Project: feasible alternative to
burning of orchard tear-out and prunings
Extension of MM5 12 Kilometer Domain to
Cover Entire State of Idaho: enhances
meteorological model and data for Idaho
Clearwater Airshed Pilot Smoke Management
Plan: state portion
Clearwater Airshed Pilot Smoke Management
Plan: tribal portion
Smoke Management Improvements for Union
County: support for air quality monitoring of
PM-2.5 near LaGrande, Oregon
$202,030
$54,688
$72,226
$50,000
$130,000
$100,00
$90,241
$123,051
$6,200
Washington Department of Ecology
Mike Regan, mrag461@ecy.wa.gov
Washington Department of Ecology
Karen Wood, kwoo461@ecy.wa.gov
Washington State University
Candis Claiborn, PhD, claiborn@wsu.edu
Eastern Washington University
JeffCorkill, PhD, jcorkill@ewu.edu
Washington State University
Candis Claiborn, PhD, claiborn@wsu.edu
University of Washington
David Kalman, PhD,
dkalman@u . Washington . edu
Washington Department of Ecology
Susan Billings, sbil461@ecy.wa.gov
Idaho Department of Env. Quality,
Diane Riley, driley@deq.state.id.us
University of Washington
Idaho Department of Env. Quality,
Robert Wilcosz, rwilkosz@deq.state.id.us
Nez Perce Tribe
Julie Simpson, julies@nezperce.org
Union County Soil and Water
Conservation District,
Union County, U.S. Forest Service
January 200 1
March 2001
March 2001
March 2001
May 2001
May 2001
July 2001
September 2001
July 2001
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EPA Funding to Support Regional Agricultural Burning Strategy
GIS Mapping of Washington's Agricultural Burn
Permitting Data Base
$60,000
Washington Department of Ecology
Karen Wood, kwoo461@ecy.wa.gov
July 2001
Development of Agricultural Burning Best
Management Practices Manual
$60,000
Washington Department of Ecology
Karen Wood, kwoo461 @ecy.wa.gov
July 2001
Study to Investigate Possible Alternatives to
Reduce or Eliminate the Need for Agricultural
Field Burning of Kentucky Bluegrass
$125,153
Coeur d'Alene Tribe
anomee@veriomail.com
Nez Perce Tribe
University of Idaho
August 2001
Reducing the Need to Burn Cereal-Crop Straw
Residue through Adoption of Direct Seed/No-
Till:
a) Further develop www.directseed.org
b) Produce direct seed "how-to" video
$23,066
Washington Department of Ecology
Melissa McEachron,
mmce461@ecy.wa.gov
Whitman County Conservation District
PNW Direct Seed Association
Washington State University
Pending
Quantifying Post-Harvest Emissions from Grass
Field Burning
$12,500
Idaho Department of Env. Quality,
Dan Redline, dredline@deq.state.id.us
Washington State University
Bill Johnston, PhD, wjohnston@wsu.edu
Pending
Pacific Northwest Burning Information System:
BlueSky-RAINS project
$60,000
Idaho Department of Env. Quality,
Robert Wilcosz, rwilkosz@deq.state.id.us
Pending
BlueSky-RATNS (funding from EPA
Headquarters)
$150,000
U.S. EPA Region 10
schweiss j on@epa. go v
U.S. Forest Service , PNW Research Stn
Sue Ferguson, sferguson@fs.fed.us
Pending
Note - This table includes only EPA funding contributions to projects - some are fully-funded by EPA while other projects have
received other funding or in-kind services from various other sources.
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