Smoke Management Program Administration and Evaluation

Smoke management program administration can range from activities conducted at the local burn program level to a multi-state coordinated effort to manage smoke. The EPA Interim Air Quality Policy on Wildland and Prescribed Fires (Interim Policy) (EPA 1998) recommends that smoke management programs be administered by a central authority with clear decision making capability. As smoke management programs range from voluntary efforts to mandatory regulatory driven programs, the administration will vary accordingly. On the more local level, the programs may be administered by a group of land managers or private landholders seeking to coordinate burning efforts to avoid excessive smoke impacts. Mandatory regulatory driven smoke management programs tend to be administered by tribal/state/district air quality regulatory agencies or state forestry entities. The administration of smoke management programs allows for a number of different approaches to meet EPA objectives and to maintain cooperative and interactive efforts to manage the dual objectives of good air quality and land stewardship.

The Interim Policy also recommends periodic evaluation of smoke management programs to ensure that air quality objectives are being met. From the land management point of view, these same reviews are critical to assessing whether land management objectives are being met under the smoke management program. EPA also recommended periodic evaluation of smoke management rule or regulation effectiveness as part of its Interim Policy. For programs that are under scrutiny by a concerned public or are growing rapidly, continuous evaluation should also be considered. All smoke management efforts—from formal interagency smoke management plans to less structured efforts to address smoke from individual fire operations— can benefit from continuous and periodic evaluation. If a smoke management program changes size, jurisdiction, or regulatory responsibilities, the level of effort applied to managing smoke should also change. To keep a program ahead of growing air quality concerns, a continuous effort to evaluate smoke management effectiveness is useful. This evaluation is also critical for local unit programs that are under formal state or tribal smoke management plans. The evaluation process has applicability to all types of fire, including wildland fire under suppression, wildland fire use and prescribed fire.

Smoke Management Program Administration

Administration of a smoke management program is frequently a function of the size of the burn program using a metric such as acres burned or emissions generated, coupled with the complexity of the local air quality issues. Fire programs located in areas that are not rife with Class I areas, PM₁₀ non-attainment areas, or smoke-sensitive transportation corridors are commonly under voluntary smoke management programs and may be locally administered. These types of programs may be focused on concerns of local area impacts such as nuisance or transportation safety and can be well addressed through local level coordination among burners. State forestry agencies and their respective districts are frequently central points for dissemination of information; many examples of this type of program can be found in the southeastern states.

As air quality complexity rises with potential smoke impacts on non-attainment areas or Class I areas, legal requirements also rise, and frequently trigger a more centralized regulatory based smoke management program. Attendant with the increased program requirements is the commensurate increased cost of the program. Direct costs of smoke management program administration are frequently recovered through the charging of fees to burners. Fees are frequently based on emissions production or tonnage of material to be consumed and are used to offset an authority’s program administration costs. The increased indirect cost of frequent reporting requirements and other permitting tasks such as modeling of impacts and smoke management plan preparation are frequently overlooked. The most common centralized program approach is administered by the state or tribal air quality authority and can be found in such states as Colorado. States such as Florida and Oregon have opted to use their forestry agencies to help directly manage their smoke management programs. Oversight by the respective air quality regulatory authority is usually a part of such a program. There is an option for interagency approaches to smoke management program administration. This approach blends the lines between air quality regulatory agencies and land managers. Personnel from a land management agency may be out-stationed to the respective air quality regulatory authority to assist in the smoke management program administration. The states of Utah and Arizona use this approach respectively and have avoided program management fees in this fashion. This approach can also foster good inter-agency communication and development of joint air quality and land management objectives for smoke management programs.

The future of smoke management program administration will be a reflection of the implementation of the Regional Haze Rule (40 CFR Part 51), which creates a paradigm in which air quality impacts are viewed in a regional sense rather than by locality or state. Tribal smoke management programs are being rapidly developed and will help support this regional approach. The establishment of multi-state smoke management jurisdictions is rapidly becoming a reality with a joint effort by Idaho and Montana being a recent example. The PM_2.5 and ozone standards will also support this type of approach as the impacts of smoke are viewed as a long-range transport issue. The inclusion of all sources of fire emissions, such as agricultural burning and wildland burning, into a singular smoke management program is also a future direction in these programs, and can already be found in the Title 17 Rule in California.

Evaluation of Smoke Management Programs

Size of Program

In lieu of any other parameter that can describe the activity level of a burn program, the number of acres can be used to trigger level of effort for smoke management and subsequent evaluation of smoke effects. As mentioned elsewhere, the representation of fire activity in terms of emissions is more effective for air quality purposes. In lieu of emissions, fire size and fuel type can be used for triggering different smoke management requirements. Small burns located in remote areas with low emissions may not dictate any evaluation greater than tracking the activity level and date of burn. However, more complex situations such as a burn of several days’ duration with heavy emissions located in the wildland/urban interface should be tracked more extensively for smoke management effectiveness. This same complex situation may track the effectiveness of emission reduction practices. It may be beneficial if the criteria are established in consultation with the local or state air regulatory agency. For federal agencies, these criteria can also be linked to the management plan’s monitoring program. A post burn analysis of the smoke management plan and the burn’s smoke effects can be extremely valuable to all concerned parties.

Intensity and Duration of Smoke Effects

The intensity and duration of smoke impacts are critical parameters that can represent a variety of smoke management effectiveness measures. Duration of smoke impacts upon the public, a non-attainment area, a transportation corridor or Class I area can be tracked and assessed through direct air quality monitoring. The public can be tolerant of one day of heavy levels of smoke, however consecutive day impacts may lead to a rash of complaints. The criteria for evaluating a program may be to assess the number of consecutive days/hours of impact to a specific area. The intensity level of smoke impact also plays a role, as short bursts of high levels of smoke punctuated by clear air is frequently tolerable by receptors. An application of this type of criteria exists in Oregon where number and intensity of smoke intrusions is tracked annually. This type of criteria is applicable to individual incidents as well.

Methods of tracking the intensity and duration of smoke impact include:

• Number and type of public complaints (citizen, doctor, hospital, etc.);
• Intrusion of smoke into designated smoke sensitive areas through specific air quality measurement;
• Violations or percent increase of criteria pollutants attributable to smoke;
• Visibility impacts (local and regional).

As the National Ambient Air Quality Standards (NAAQS) include both short term and annual standards, the full impact of smoke on the NAAQS may not be readily determined until well after the burn season is completed, which further supports the importance of incorporating evaluation into a smoke management program. Impacts on visibility were previously viewed on an annual basis, however that has changed to tracking impacts on Class I areas to determine effects on the 20% clearest and 20% dirtiest days. These methods for tracking and evaluation should be established prior to the event or as part of the overall smoke management program as they can take significant planning or coordination. Pre-planning for the air quality element of the Wildland Fire Situation Analysis used by federal agencies for wildland fires (USDI and USDA Forest Service 1998) can also be beneficial as the public, air quality regulatory community, and land management entity has the opportunity to increase acceptance of smoke effects.

The evaluation criteria should be as quantitative as possible in light of the complexity of the burn or program and the air quality concerns of the area. Proximity to non-attainment or Class I areas should automatically trigger some programmatic evaluation. Visibility should be considered in terms of plume blight, regional haze and impacts on safety (transportation). Conversely, a small incident with a small quantity or short duration of emissions in an area with few air quality concerns should not warrant extensive programmatic or individual incident evaluation effort. Again, advance coordination with concerned parties can help determine this varying level of effort.

If an incident or program results in a smoke intrusion above a pre-defined level such as number of complaints or presence of smoke in an avoidance area, the cause should be evaluated as soon as possible. The breakdown of the smoke management plan for an incident is equivalent to the breakdown of the fire behavior prescription for the burn. Smoke management contingency programs are another element of a smoke management program included in the Interim Policy (EPA 1998). Factors such as weather/smoke dispersion forecasting or fuel condition changes can lead to such a smoke intrusion and need to be evaluated quickly following a failure of the system in order to be addressed in a proactive fashion. Determination of what caused the adverse air quality impact allows for growth of the program through implementation of changes to avoid future recurrence. If a program or incident was conducted such that no smoke criteria were exceeded, evaluation of the factors which led to success are also valuable in building confidence among cooperating parties. The development of an annual report which outlines the air quality effects of a burning program or the smoke management program demonstrates the commitment to addressing both land management and air quality objectives and can show significant and useful trends to concerned parties. The knowledge that smoke impacts are being addressed effectively in terms of specific criteria is valuable when working with the concerned public and media.

Sources for Evaluation

Evaluation can be the assessment of air quality monitoring data collected by the land manager or utilization of existing air quality networks as operated by a regulatory agency (state/district/county/EPA/ tribe). The meteorological conditions under which burns occur is another criteria that can be evaluated to help assess the smoke management program. For complex smoke areas, the use of digital camera points could allow distribution of the real-time images over the Internet to concerned parties, including the public. The concerned public can also be directly queried as to the level of smoke levels and duration of effects.

Annual Evaluation

One of the most effective means of evaluating the smoke management program is to hold periodic meetings amongst the concerned parties such as the burners, regulators and potentially-concerned public. The frequency of such reviews should depend on the air quality complexity and smoke impacts. Many statewide smoke management programs meet annually to review the years’ activities, successes and problems. These meetings could include review of activity/ emissions of burners, record-keeping efforts, effects tracked through the previously mentioned methods, and discussion of program logistics and costs. This same review meeting is also an opportune time to plan for future changes, discuss emerging issues, and conduct training if needed. The Interim Policy (EPA 1998) also urges such an evaluation process occur annually. These annual sessions may be an effective way of addressing an Interim Policy goal of assessing the adequacy of the rules and regulations pertaining to smoke management for a respective state, tribe or other managing entity. Reflecting the state of the smoke management program, whether statewide or at the land manager level, through the issuance of an annual program report on smoke management can be another technique for assessing the program and informing the public of the investment into smoke management.

Continuous Evaluation

If a specific incident were to have significant adverse effects, it might trigger immediate review to prevent a repeat occurrence. This immediate incident assessment can be an effective way of addressing pressing public concerns that may have arisen due to the impacts. During a wildland fire use incident, daily conference calls amongst the land manager and the regulatory agencies which discuss acres/fuels/emissions or qualitative smoke behavior can be very effective at addressing smoke concerns. This real-time evaluation can prevent conflict over smoke impacts and can ensure accurate information be provided to the public as well as incorporated into the message transmitted to the media by the respective agencies.

Incident debriefings should consider air quality effects and how they were addressed. In wildland fire use, there is a continuous evaluation of air quality as part of the Wildland Fire Situation Analysis (USDI and USDA Forest Service 1998). Establishment of criteria for evaluation of air quality effects prior to the actual event or implementation of a program can allow for greater buy-in by potentially affected parties when the fire occurs. Criteria for evaluation should also include indicators of success.