unwanted or wildfires. The interface between this policy and the Natural Events Policy2 regarding ambient PM10 concentrations caused by wildfires is addressed in section VII. This policy does not apply to other open burning activities, such as burning at residential, commercial or industrial sites; open burning of land clearing waste or construction debris. It also does not apply to open burning of agricultural waste, crop residue or land in the USDA Conservation Reserve Program. The EPA is working with the USDA Agriculture Air Quality Task Force to develop equitable policies for emissions from activities that could be classified as agricultural burning. This policy addresses the impacts of air pollutant emissions from fires managed for resource benefits on public health and welfare. The primary indicators of public health impacts used are ambient air quality impacts above the NAAQS for fine particles with an aerodynamic diameter less than or equal to a nominal 2.5 micrometers (PM2.5), and particles with an aerodynamic diameter less than or equal to a nominal 10 micrometers (PM10). There are both 24hour (daily) and annual NAAQS for PM2.5 and PM10. Emissions of nitrogen oxides (NOx ), VOC, and CO from fires can also impact the NAAQS for NO2, O3, and CO. However, the actions required to reduce VOC and CO emissions are the same as those recommended in this document to mitigate impacts on the PM2.5, and PM10 NAAQS. Emissions of NOx, on the other hand, can increase under some of the burning conditions used to decrease emissions of other pollutants. The effects of fire emissions on the public welfare aspects of the NAAQS for PM are addressed in terms of visibility impairment and regional haze. The policy also addresses the treatment of fire emissions to meet other CAA requirements, such as prevention of significant deterioration (PSD) and conformity with SIPs or TIPs. III. A. BACKGROUND The Role of Fire in the Wildlands The role of fire in North American ecosystems has been undergoing change since people began to play a more active role in managing their natural resources. Native Americans actively used fire to alter vegetative patterns, to ease travel, or for hunting purposes. Prior to European
See memorandum from Mary D. Nichols, Assistant Administrator for Air and Radiation to EPA Regional Offices titled Areas Affected by PM10 Natural Events, May 30, 1996.
settlement, fire played a natural role as a necessary disturbance phenomena, keeping fuel density in check as well as insects and the diseases they carry, thereby maintaining North American wildlands in a healthy state. After European settlement and the introduction of grazing herds of cattle and sheep, and the practice of fire suppression, public land management agencies have recognized that not allowing fire to play its natural role in our wildlands has had unintended negative effects. When forests and grasslands are not allowed to burn naturally (lighting serving as the principal source of ignition) the result can be heavy accumulation of dead vegetation which provides fuel for unwanted fires (wildfires). Because of this unhealthy build-up of fuels, the risk of catastrophic wildfires is much greater as evidenced by several recent fires in our national forests and other publicly owned lands. These fires put firefighters and the general public in danger while destroying millions of acres of forests and costing millions of dollars to suppress. The lack of fire also has unintended ecological effects, leading to the loss of habitat for rare species and the decline of ecosystems. Fire exclusion can lead to an alteration in natural community types, and an important loss of biodiversity. Many plant and animal species are on the decline because they exist in fire-dependent habitats that haven't burned in decades. This situation has led to a rethinking of Federal land management and fire management policy. B. Changes in Fire Management Policy In 1995, a Federal Wildland Fire Management Policy and Program Review was conducted in response to the unhealthy condition of our public wildlands, and the increase in unplanned fires that occurred in 1987, 1988, 1992 and again in 1994. As a result of this review, the five principal Federal fire/land management agencies [the Forest Service (FS) under the Department of Agriculture; and the Bureau of Land Management (BLM), National Park Service (NPS), Fish and Wildlife Service (FWS), and the Bureau of Indian Affairs (BIA) under the DOI] agreed on need for several changes to existing fire/land management practices. Their recommendations include the reintroduction of fire (allowing it to play its natural role) into Federal land management programs in an ongoing and systematic manner, consistent with public health and environmental quality considerations. The goals of this change in land management policy are to reduce unnatural fuel densities that contribute to increasing unplanned fire hazards, and to restore wildland ecosystems to their healthy natural states. The Federal agencies previously mentioned 4

R18-2-1507. A.

Prescribed Burn Accomplishment; Wildfire Reporting
Each F/SLM conducting a prescribed burn shall complete and submit to ADEQ the "Burn Accomplishment" form supplied by ADEQ. For each burn approval, the F/SLM shall submit a Burn Accomplishment form to ADEQ by 2 p.m. of the business day following the approved burning burn. The F/SLM shall include the following information on the Burn Accomplishment form: 1. 2. 3. Any known conditions or circumstances that could impact the Daily Burn decision process; The date, location, fuel type, fuel loading, and acreage accomplishments; The ERTs and SMTs described in R18-2-1509 and R18-2-1510, respectively, and may
include any further ERTs and SMTs that become available, that the F/SLM used to reduce emissions or manage the smoke from the burn. B. The F/SLM shall submit the Burn Accomplishment form as an original form, a facsimile, or an electronic information transfer. C. ADEQ shall maintain a record of Burn Requests, Burn Approvals/Conditional Approvals/Denials and Burn Accomplishments for 5 five years. D. The F/SLM in whose jurisdiction a wildfire occurs shall make available to ADEQ no later than the day after the activity all required information for wildfire incidents that burned more than 100 acres per day in timber or slash fuels or 300 acres per day in brush or grass fuels. For each day of a wildfire incident that exceeded exceeds the daily activity threshold, the F/SLM shall provide the location, an estimate of predominant fuel type and quantity consumed, and an estimate of the area blackened that day.

R18-2-1508. Reporting A.

Wildland Fire Use: Plan, Authorization, Monitoring; Inter-agency Consultation; Status
In order for ADEQ to participate in the wildland fire use decision-making process, the F/SLM shall notify ADEQ as soon as practicable of any wildland fire use incident projected to attain or attaining a size of 50 acres of timber fuel or 250 acres of brush or grass fuel.
For each wildland fire use incident that has been declared as such by the F/SLM, the F/SLM shall complete and submit to ADEQ a Wildland Fire Use Burn Plan in a format approved by ADEQ in cooperation with the F/SLM. The F/SLM shall submit the Wildland Fire Use Burn Plan to ADEQ as soon as practicable but no later than 72 hours after the wildland fire use incident is declared or under consideration for such designation. The F/SLM shall include the following information in the Wildland Fire Use Burn Plan: 1. 2. 3. 4. 5. 6. An emergency telephone number that is answered 24 hours a day seven days a week; Anticipated burn prescription; Anticipated smoke management prescription; The estimated daily number of acres, quantity, and type of fuel to be burned; The anticipated maximum allowable perimeter or size with map; Information on the condition of the area to be burned, such as whether it is in maintenance or restoration, its ecological function or , and other indicators of fire resiliency; 7. The anticipated duration of the wildland fire use incident;

rule, that you have in front of you, is a joint effort of ADEQ and the Fire Emissions Work Group based on input received at not only the Work Group meetings, but also a series of public meetings that we held throughout the state earlier this year. ARIZONA REPORTING SERVICE, INC. I believe it (602) 274-9944

10-22-2003 7

was in April.
So what we've got in front of us is a
result of those meetings and the Work Group's efforts. The specific requirements for state Regional Haze SIPs can be found at Title 40, Code of Federal Regulations Chapter 51.308 and 51.309. They include,
most notably, greater tracking and monitoring requirements of open burning and burn plans, regular evaluation of such data that comes from burning, and the establishment of annual emission goals under the Smoke and Range Management Rules in cooperation with States, tribes, Federal land management agencies, and private entities that do prescribed burns. Changes to R18-2-602, again, the Unlawful Open Burning Rule of our rules, are not extensive. However, we did -- you'll notice we did kind of strike out the entire rule as it exists and kind of did a new underlying rule. And we basically did that mostly for
improving the understandability and the flow of the rule. So even though you see a completely stricken
version, it doesn't mean that the content and the substance of the rule was changed that much from the original version. This proposed rule contains some additional definitions that have been added in a separate subsection, including definitions for various ARIZONA REPORTING SERVICE, INC. (602) 274-9944

10-22-2003 8

categories of open burning, such as agricultural, construction, and residential. In addition, there are
new definitions for "delegated authority," "independent authority to permit fires," and "prohibited materials." The proposed rule revisions also clarify which open burning activities require open burning permits and those that are exempt from having to obtain a permit. It also contains a more complete list of
information that's required to be in the permit itself. This is both for more efficient permit administration from ADEQ's side and to comply with the various aspects of the Regional Haze Rule as it is contained in 40 CFR 51.309. ADEQ has also added in the language in the proposed rule revisions clarifying that the state rule is not applicable in counties with independent authority to permit fires. And there are three

10-23-2003 3

Welcome to this Arizona Department of Environmental Quality hearing. The subject of this hearing is proposed revisions to Arizona Administrative Code R18-2-602, the "Unlawful Open Burning Rule," and Article 15, the rules covering "Forest and Range Management Burns." hearing is now open. The date is Thursday, October 23rd, 2003, and the time is 1:36 p.m. The location is the The
Flagstaff-Coconino County Public Library at 300 West Aspen, Flagstaff, Arizona 86001. My name is Bruce Friedl and I'm an Environmental Programs Specialist for the Planning Section of the Air Quality Division at ADEQ, and I have been appointed by the ADEQ Director to conduct this hearing. The purposes of this hearing are to provide the public an opportunity to hear about the substance of the proposed revisions to the Arizona Administrative Code R18-2-602 and Article 15; two, to ask questions concerning the proposed rule revisions; and three, to present oral arguments, data, and views concerning the proposed rule revisions in the form of comments on the record. ARIZONA REPORTING SERVICE, INC. (602) 274-9944

10-23-2003 4

Other ADEQ Air Quality representatives in attendance today are Theresa Pella, Air Quality Planning Section Manager, and Kevin Force, Rule Writer, Planning Section. Also present is our court reporter,
the comment period, 5:00 p.m. on Friday, October 24th, 2003. Any written comment must be received no later
than October 24th, 2003. Submit your written comments to Kevin Force, K-e-v-i-n F-o-r-c-e, Air Quality Planning Section, Arizona Department of Environmental Quality, 1110 West Washington Street, Third Floor, Phoenix, Arizona 85007. The fax number is 602-771-2366. You can e-mail written
comments to force.kevin@ev.state.az.us. Notice of this hearing was published in The ARIZONA REPORTING SERVICE, INC. (602) 274-9944

10-23-2003 5

Arizona Republic and The Arizona Daily Sun on September 19, 2003. State statutes require that comments made during the formal comment period be considered by ADEQ in the preparation of a final rule, in which the Department responds in writing to written and oral comments made during the formal comment period. The agenda for this hearing is simple. First, I will ask Theresa Pella to provide an overview of the proposed rulemaking. Second, I will conduct a question and answer period. The purpose of the question and answer period
is to provide information that may help you in making comments on the rulemaking. Third, I will conduct an oral comment period. At that time, I will call speakers in the order in which I have received their speaker slips. Please be aware that any comments you make at today's hearing that you want the Department to formally consider must be given either in writing or on the record during the oral comment period of this proceeding. At this time, Theresa Pella will give a brief overview of the background concerning the ADEQ's proposed revisions to A.A.C. R18-2-602 and Article 15. ARIZONA REPORTING SERVICE, INC. (602) 274-9944

For clarification on emission limits as they apply to fire, see the WRAP Policy on Annual Emission Goals for Fire. 47 NWCG Smoke Management Guide, p. 189. 12
4. APPENDICES APPENDIX A. GLOSSARY
This glossary is intended to provide readers with several operating definitions to facilitate a consistent review of this Policy. However, this glossary is not intended to be a complete list of all terms and acronyms. 16 Class I Areas on the Colorado Plateau - The Grand Canyon Visibility Transport Commission Report specified 16 mandatory Class I areas on the Colorado Plateau that were adopted into Section 309 of the Regional Haze Rule. The 16 Class I areas are: Grand Canyon National Park, Sycamore Canyon Wilderness, Petrified Forest National Park, Mount Baldy Wilderness, San Pedro Parks Wilderness, Mesa Verde National Park, Weminuche Wilderness, Black Canyon of the Gunnison Wilderness, West Elk Wilderness, Maroon Bells Wilderness, Flat Tops Wilderness, Arches National Park, Canyonlands National Park, Capital Reef National Park, Bryce Canyon National Park, and Zion National Park. 2064 Natural Conditions Goal# - The ultimate goal of the regional haze program is the absence of visibility impairment due to human-caused emissions. AAQTF - Agricultural Air Quality Task Force. A task force to address agricultural air quality issues established by the Chief of the Natural Resources Conservation Service. Agricultural Fire/Burning* - Any fire ignited by management actions to meet specific objectives (i.e., managed to achieve resource benefits) on agricultural land. Agricultural Land* - Agricultural land includes croplands, pasture, and other lands on which crops or livestock are produced (PL 104-127, Section 1240A). Rangeland will be included with wildland for the purposes of the Fire Emissions Joint Forum work. Alternatives to Burning - See Non-Burning Alternatives to Fire definition below. Anthropogenic Emissions Source Classification (anthropogenic)# - A categorization that designates which fire emissions contribute to visibility impairment in a Federal Class I area. Anthropogenic emissions must be controlled to achieve progress toward the 2064 natural conditions goal for each Federal Class I area in the WRAP region. This classification includes natural and human-caused ignitions. Area Source - A source category of air pollution that generally extends over a large area. Prescribed burning, field burning, home heating, and open burning are examples of area sources. Class I Area - See Mandatory Class I Area and Non-Mandatory Class I Area.

Chemical

Chemical treatments entail the application of herbicides. It should be emphasized that chemical treatments do not remove fuels, but either kill existing vegetation or inhibit growth. In general, chemicals are appropriate to treat flashy, understory growth such as the weedy vegetation under power transmission lines or along railroad rights-of-way. Alternatively, chemical treatments can be used in conjunction with other treatment types, including
prescribed burning, to extend the period between necessary management activities. A widely-used chemical treatment in vegetation and fuel management programs is called brown-and-burn. In this technique, pesticides are used to kill target species of understory vegetation, converting live fuel to dead fuel. The chemical treatment can be applied in spring, when nontarget species remain green, thereby facilitating a prescribed burn to remove the vegetation that has been rendered flammable. However, because this technique is properly a preburning procedure, it cannot be considered a nonburning alternative. The utility of the growth-inhibiting function of chemical treatment types is exemplified in the maintenance of defensible fuel profile zones (DFPZs). DFPZs are shaded firebreaks, typically along ridgetops, where mechanical or manual treatments have been applied to reduce fuel loads and create an area where, in the event of a wildfire, the decreased fuel load will retard the spread of the fire and fire crews can work at containment and control of blaze. Periodic chemical treatments could be used to maintain the desired fuel characteristics within the DFPZ, obviating mechanical or prescribed burning treatments for many years. The drawbacks to chemical treatment methods include very stringent regulatory requirements, the possibility of adverse impacts on water quality, destruction of species that are not target species, toxicity levels, and negative public opinion. Because chemical treatments have limited efficacy in directly addressing existing fuel load management problems, they are not discussed further in this document. However, under certain site-specific conditions they remain potentially useful options.

Table ES-1. Average Percentage of Acres Harvested that are Burned for Selected Crops in the Western United States
Overall Average Percentage of Acres Burned 2.9% 50.9% 0.2% 2.4% 69.9% 21.2% 43.8% 10.1%
Crop Wheat Rice Corn Barley Sugarcane Orchards (Trees, Bushes, Vines) Grasses and Seeds CRP
Acres Harvested1 31,619,000 500,000 5,766,000 5,696,900 42,900 2,497,767 899,286,174
Acres Burned 905,756 254,706 10,668 137,872 30,000 530,100 394,077 28,917
Notes: 1 Acres harvested and burned are for the 15 Western states, excluding Nevada because burning in that state was not identified for specific crops. 2 Value represents number of acres in the Conservation Reserve Program (CRP).

Volume II:

Non-Burning Management Alternatives and Implementation Plan Strategies The majority of information collected and reviewed in this study suggests that
states, local agencies, tribal communities, and fire control experts agree that the development and use of non-burning alternatives is desirable. However, identification, development, and use of these alternatives throughout the 15 Western states and tribal communities appears to be in the fundamental research stages. This fact, in combination with the lack in most states of formal requirements to implement non-burning alternatives, made identification and characterization of alternatives a difficult task. Over 20 different non-burning alternatives were identified in the following categories: 1. 2. Leave residues in place either with or without infield residue treatment (e.g., cut, mulch, and drop in place; soil incorporation); Improved management practices and scientific advancements in horticulture (e.g., genetic selection for disease/pest resistance or less fuel residual); Alternative land use (i.e., conservation tillage; land conversion to nonagricultural use; and plant crops with residues that do not need to be burned); and Residue collection and hauling for use offsite (e.g., haul to waste or landfill facility; haul to ethanol production facility).
In order to determine the reasonableness, or feasibility, of implementing nonburning management alternatives, it is important to assess the impacts they have on agriculture, the environment, and other aspects of society. In this study, the impacts to non-burning alternatives were defined and criteria were established for assessing their effects and determining the feasibility of implementation. The range of impacts due to implementation of non-burning alternatives included: Agronomic impactswhat happens to the agricultural production unit when an alternative is implemented, what the grower must do on the land and how does that change affect the productivity of the land; Environmental impactswhat effect does the alternative have on visibility, air quality, water quality, wildlife, and other vegetation;

Page 1 of 2

MONTANA Residue Name wheat; all (irrigated) wheat; all (irrigated) wheat; all (irrigated) wheat; all (irrigated) wheat; all (irrigated) wheat; all (irrigated) wheat; all (irrigated) wheat; all (irrigated) wheat; all (irrigated) wheat; all (irrigated) wheat; all (irrigated) wheat; all (irrigated) wheat; all (irrigated) wheat; all (irrigated) wheat; all (irrigated) wheat; all (irrigated) wheat; all (irrigated) wheat; all (irrigated) Crop Name wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all wheat; all Total Grand Total County Powder River Powell Prairie Ravalli Richland Roosevelt Rosebud Sanders Sheridan Stillwater Sweet Grass Teton Toole Treasure Valley Wheatland Wibaux Yellowstone RL (tons/acre) 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 A_BURN (acres) 2,655 2,655 Year Burned R_BURN (tons) 5,055 5,055 Comments
A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ A_BURN based on estimate of 1% of irrigated wheat burned per J.Coeffield, MTDEQ

orchard pruning; unspecifiedPierce orchard pruning; unspecified Total orchard removal orchard removal orchard removal orchard removal orchard removal orchard removal Chelan Douglas Franklin Garfield Grant Kittitas
Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE Daily A_BURN provided in permit database from S.Nolph WDOE

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WASHINGTON A_BURN (acres) 5 1,018 2,1,130 2,Year Burned R_BURN (tons) 72 15,263 32,904 1,256 542
Residue Name orchard tree removal orchard tree removal orchard (maintainence - no removal) orchard (maintainence - no removal) peas peas orchard (maintainence - no removal) hasi - hay - alfalfa seed - irrigated hasi - hay - alfalfa seed - irrigated hasu - hay - alfalfa seed - unknown gsbu - grass seed - bluegrass - unknown gsbu - grass seed - bluegrass - unknown gsbru - grass seed - brome - unknown turnip - seed turnip - seed gcd - grass cover - dryland gsuu - grass seed - unknown - unknown gsuu - grass seed - unknown - unknown gsuu - grass seed - unknown - unknown gsuu - grass seed - unknown - unknown spot burning spot burning CAUTION: not listed on internal permit CAUTION: not listed on outside permit spot burning spot burning CAUTION: not listed on internal permit CAUTION: not listed on outside permit spot burning spot burning
Crop Name orchard removal orchard removal orchard removal Total peaches peaches Total pears pears Total peas; dry edible peas; dry edible peas; dry edible Total plums and prunes plums and prunes Total seeds; alfalfa seeds; alfalfa seeds; alfalfa seeds; alfalfa Total seeds; KBG seeds; KBG seeds; KBG Total seeds; other seeds; other seeds; other seeds; other seeds; other Total seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified seeds; unspecified Total unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified unspecified
County Okanogan Yakima Yakima Yakima Walla Walla Whitman Yakima Franklin Grant Walla Walla Garfield Whitman Columbia Franklin Grant Klickitat Columbia Garfield Walla Walla Whitman Adams Asotin Columbia Columbia Columbia Douglas Grant Grant Grant Lincoln
RL (tons/acre) 2.5 2.6 2.5 2.5 1.2 0.8 0.8 0.2

Table 4-2. Grass Seed Impacts of Non-Burning Alternatives1
Vol. II: Non-Burning Management Alternatives, Final - May 2002 Leave Residues in Place Soil Incorporation: Wet or Dry Soil Incorporation: Fallow Field Power Generation Facility Permitted Burn Facility Mulch Residue Waste Facility Cut or Collect Residues and Haul Ethanol Production Facility Use as Animal Feed Fiberboard Facility Use as Compost or Mulch Manufacturing or Use Facility Use For Erosion Control Redistribution Facility Particleboard Facility Scientific Improvements Less Fuel Residual Other Tolerances Diseasepest Resistance Alternative Land Use Land Conversion to Non-Agriculture Plant Crops that are not Burned Conservation Tillage
Feasibility factors are phrased to indicate a negative outcome. Higher ratings indicate worse consequences for that impact and alternative.
0 = no problem exists 1 = problem may exist 2 = problem does exist 3 = a major problem exists
Blank = not relevant or viable
ACCOUNTABILITY MECHANISMS
This section describes the strategies used to research, identify, and characterize
accountability mechanisms of greatest importance in supporting the development and use of nonburning alternatives within the 15 Western states. Accountability mechanisms are procedures used for tracking if, and to what extent, non-burning alternatives are used by local, state, tribal, or federal entities. Where possible, accountability mechanisms which are currently in place and are actively in use at the state, county, and local levels, as well as in the tribal community setting, are identified in this report. In addition, a discussion of how each accountability mechanism is important in supporting or promoting the development and use of non-burning alternatives is provided. Accountability mechanisms important to the implementation and use of non-burning alternatives by individual burners are also discussed in greater detail in Section 7.0.
The identification and characterization of accountability mechanisms of
importance in the development, consideration, and use of non-burning alternatives was a complex process. It required a thorough assessment, understanding, and interpretation of current agricultural burning practices in the West. It also required a thorough assessment of the regulatory and programmatic structures in place for addressing agricultural or open burning activities in each state (and where applicable for each county or local air authority). An understanding of the variety of practical, technical, political, and economic forces affecting stakeholders involved in or currently conducting agricultural burns was also critical for the successful identification and characterization of accountability mechanisms in this effort. To collect the desired information and to address the expectedly wide distribution of information sources, the same three-tiered approach discussed in Section 2.0 was employed. This approach included contacting and/or researching the availability of information from three different levels of information sources. It was expected that these sources would provide varying information perspectives and levels of programmatic detail. The majority of the information pertaining to this task came from the first level of information sources.

burning appears to have the potential to significantly impact air quality. These mechanisms actively address the identification of effective non-burning alternatives, establish requirements to consider the use of alternatives to burning prior to burn approval, and offer practical assistance in offsetting costs to implement the typically more expensive non-burning alternatives. Mechanisms 15, 16 and 17 provide accountability at the state or local level that facilitates the active identification of, and encourages the consistent use of, effective non-burning alternatives in conjunction with or as a substitute to traditional existing agricultural burning practices. Mechanism 15 provides incentive to actively consider non-burning alternatives by making it a requirement of pre-burn approval. This usually occurs during the pre-burn permitting process. If no pre-burn permitting process exists, in all but the most unique of circumstances, it is impractical and unrealistic to expect non-burning alternatives will be considered to any significant extent. The relationship between the requirement to secure approval prior to burning and the requirement to consider or practically implement some form of non-burning alternative to at least a portion of the slated burn acreage is key to encouraging the consideration and use on non-burning alternatives in the West. Mechanism 16 provides financial assistance in one form or another to burners who implement non-burning alternatives. This serves to help overcome one of the most often voiced oppositions to the use of non-burning alternatives which is that of cost ineffectiveness. Cost ineffectiveness is the most often cited reason for not using or implementing non-burning alternatives. Practical use or effectiveness is another reason (see Table 6-1 of this report). The latter may be overcome in time by more scientific research and close coordination with the agricultural community. The former remains a significant barrier for most state, regional, or local level entities who are trying to implement non-burning alternatives programs. In some cases subsidies, tax credits, permit fee reductions, or rebates may be an effective way to address this barrier. However, it is not always feasible for public entities to accommodate these financial incentives. Although it may not always be feasible to provide financial assistance to offset direct costs, it might be feasible for state air quality or environmental agencies to identify, if not actually recruit, other state or local experts in the areas of manufacturing, product development, marketing, and distribution to assist in the economic development of some types of non-burning alternatives. In at least one case during this research effort, it was found that members of the

Developing Implementation Plans: Recommended Strategy
The results of this effort suggest a very clear starting point and methodology for
developing implementation plans to increase the identification and use of non-burning alternatives in the West. Based on the results and conclusions found in the prior sections of this report, the following strategy for developing successful non-burning alternatives program implementation plans is recommended for any state, region or tribal entity desiring to increase the identification and use of non-burning alternatives: 1. Air quality or environmental program entities should conduct a focused review to identify the nature and extent to which agricultural burning contributes to air quality problems in the state, or local, or tribal area. A starting point for this review could be the evaluation of agricultural burning activity presented in the companion Volume I document to this report. A key element of this review that should be included is a careful consideration of the definition of agricultural burning. This is important so that accurate comparisons can be made between other states, local or tribal programs. The review should also take into account the potential impacts that agricultural burning may have on interstate regional air quality. If agricultural burning does not contribute significantly to local or statewide air quality problems which fall under the jurisdiction of the state, local or tribal entity, it is still recommended that the focused program assessment also take into account, to the greatest extent possible, the potential impacts agricultural burning may have on interstate regional air quality. If agricultural burning is not found to be a significant source of air pollution for a given state, local region, tribal entity, or interstate region, it may not be necessary to continue with non-burning alternatives program development. This may be the case for some states that appear to lack accountability mechanisms as noted in Section 5.0 of Volume II. If agricultural burning is found to make a significant contribution to air quality problems on either a local, state, tribal community or regional level, then the air quality or environmental agencies in authority in the affected areas and the areas contributing to the problems should work together to define solutions and develop non-burning alternatives programs. This will help to ensure success on a regional level. If agricultural burning is found to be a significant source of air pollution for a given state, local region, tribal entity or interstate region, or if a given entity desires to more effectively implement non-burning alternatives, then 7-14

64 FR 35771 51.309 (d)(6)(v). WRAP Initiatives Oversight Committee (IOC), Transmittal Letter, November 15, 2001, Appendix C of the WRAP Fire Categorization Policy. 17
The following paragraphs provide a summary of some of the current efforts by regulatory entities to use ERTs as a means to reduce emissions from prescribed fire and agricultural burning. 3.1 California Title 17 of the California Code of Regulations requires district smoke management programs to include general burning requirements for agricultural burning, prescribed burning, and prescribed fires in wildland and wildland/urban interface areas. In addition to the general requirements, the law includes specific requirements for rice, barley, oat, and wheat straw, such as certain firing techniques and specific burning windows. There are also specific fuel moisture burning requirements for rice straw burning. 3.2 Oregon In Oregon the rules for agricultural burning include, but are not limited to, measures to ensure that crop residues are evenly distributed and in good burning condition, rapid ignition techniques are employed, and alternatives to open burning of fields are considered. For prescribed fires on wildlands, the Oregon Smoke Management Program requires land managers to consider utilization of residue, fuel reduction measures, alternate treatment practices, and reduction of prescribed burning emissions to achieve emissions reduction goals established within the Oregon Visibility Protection Plan. Burning during the spring when the 1000-hour and larger fuels have high fuel moisture is promoted. Post-burn reports require the tracking of fuel moisture content, ignition method, and other information to support calculation of ERT use. 3.3 Washington In Washington, wildland land managers are encouraged to use techniques, such as fans, crane piling, mass ignition, accelerated mop-up, and other methods of increasing combustion efficiency and reducing the smoldering stage of burning. No tracking of specific ERTs is required. The Washington Smoke Management Plan for silvicultural burning does establish a tracking system to measure progress toward specific emission reduction targets. Burn days and specific burning conditions are established by the Department of Ecology for agricultural burning and a permitting system is in place. 3.4 Utah Agricultural burning is not regulated by the State of Utah. However, counties require such burns to be conducted during optimal dispersion conditions. State air quality regulations require wildland land managers to take measures to prevent smoke impacts. State law requires identification of best management practices including the use of ERTs. Land managers are required to identify the techniques that are employed in addition to fuel moisture and ignition method in their daily emissions report.