FEDERAL LAND MANAGERS' AIR QUALITY RELATED VALUES WORKGROUP (FLAG)
PHASE I REPORT
(December 2000)

C. 4. Managing Emissions Generated In and Near FLM Areas

Specific strategies need to be developed and implemented for reducing and preventing pollution from the many diverse sources and activities in communities surrounding FLM areas, including "gateway" communities. Accountability mechanisms are needed to ensure that appropriate actions are taken, reported and incorporated into SIPs, visibility protection plans, and Federal land management plans. Various forums (e.g., the Western Regional Air Partnership, and the Southern Appalachian Mountains Initiative) are addressing some of the emissions sources of concern and developing appropriate regional strategies. In addition, EPA has formed other "regional planning organizations" for implementing its regional haze rule. FLMs should participate in these forums, consistent with Federal law (e.g., Federal Advisory Committee Act), to the maximum extent possible and should coordinate their activities within those forums to ensure that comprehensive strategies are developed and implemented to address all the key emissions sources near FLM areas.

A systematic assessment of emission sources in and near FLM areas would be extremely helpful for formulating strategies aimed at mitigating or eliminating adverse impacts on area resources. Without this assessment it is not possible to accurately quantify the extent to which these emissions contribute to the overall problem. Nevertheless, FLMs can, and should, take steps to minimize emissions generated on FLM lands even without an accurate inventory of emissions sources.

a. Prescribed Fire

Prescribed fire is a land management tool used for multiple landscape objectives. Prescribed fire allows the FLM to mimic natural fire return intervals under controlled conditions where smoke management can minimize air quality impacts. The alternative is wildfires, which can be very difficult to control and may cause much more severe air quality impacts. A modeling assessment suggests that using prescribed fire to minimize wildfires can result in a net reduction in fine particle (PM_2.5) emissions in the long term. In the Pacific Northwest wildfire emissions were found to be greater than prescribed fire emissions in the same airshed (Ottmar, 1996).

Since the turn of the century, wildfire has been aggressively suppressed on most of the nation's public lands to protect public safety, property, and to prevent what was thought to be the destruction of our natural and cultural resources. Fire-exclusion practices have resulted in forests, shrub lands, and grasslands plagued with a variety of problems, including overcrowding, resulting from the encroachment of species normally suppressed by fire; vulnerability of trees to insects and disease; and inadequate reproduction of certain species. In addition, heavy accumulation of fuels (such as dead vegetation on the forest floor) can cause fires to be catastrophic, which threatens firefighter and public safety, impairs forest and ecosystem health, destroys property and natural and cultural resources, and degrades air quality. The intense or extended periods of smoke associated with wildfires can also cause serious health effects and significantly decrease visibility.

FLMs recognize prescribed fire as a valuable tool; they also recognize that emissions from prescribed fire can be a significant source of air pollution. Smoke particles are also in the size range (< 2.5 µm) that they play a significant role in visibility impairment. Particulate matter is the main pollutant of concern from smoke because it can cause serious health problems, especially for people with respiratory illness.

The FLMs are committed to minimizing the impacts from smoke by following sound smoke management practices, and if practical, using alternative methods to achieve land management objectives. Each prescribed burn site will have unique characteristics, but in general, smoke impacts can be greatly minimized by burning during weather conditions that provide optimal humidity levels and dispersion conditions for the type of materials being burned, in addition to limiting the amount of materials and acreage burned at one time.

Generally, fire inside wilderness is considered natural-there is a need whenever possible to allow these fires to burn out naturally when the fires do not threaten private property or air quality conditions do not threaten human health. Visibility impairments caused by naturally ignited fires in wilderness should similarly be classified as natural. Unlike stationary source emissions, which are continuous, fire emissions are spatially and temporally sporadic.

EPA has worked in partnership with land management agencies in the U.S. Departments of Agriculture, Defense, and the Interior; State Foresters; State air regulators; Tribes; and others to obtain recommendations and develop a national policy that addresses how best to improve the quality of wildland ecosystems (including forests and grasslands) and reduce threats of catastrophic wildfires through the increased use of managed fire, while achieving national clean air goals (U.S. EPA, 1998). EPA's wildland fire policy describes criteria for wildland managers (federal, state, tribal, and private), and state and tribal air pollution agencies, to use in planning for and implementing prescribed fires, and recommends a variety of smoke management techniques that land managers can use to help reduce smoke impacts from prescribed fires. The policy is available at EPA's website: http://www.epa.gov/ttn/faca/fa08.html

b. Strategies to Minimize Emissions from Sources In and Near FLM Areas

Aside from prescribed fire, other activities that generate air pollution in FLM areas include road building, operation of generators, oil and gas development, etc. Developing strategies for addressing natural resource impacts in or near an FLM area should not only take into consideration the type of activities generating the emissions and their amount, but also the existing condition of the resources of that area. More stringent measures should be required for sources in and near FLM areas that are already experiencing adverse effects from air pollution.

Examples of potential air pollution prevention practices that FLM agencies may encourage or develop and use are categorized under the following three strategies:

Pollution Prevention Strategies

• Review land management plans for affected FLM areas to assess whether they include strategies to limit and reduce air pollution emissions and incorporate protective measures into planning and decision documents.
• Place priority on pollution prevention.
• Encourage zero and near-zero emitting technologies.
• Promote use of clean fuels.

Mobile Source Strategies

• Promote the adoption of Low Emission Vehicle standards or the conversion of Federal fleets to alternative fuels.
• Improve control of evaporative emissions.
• Adopt and enforce more stringent emission standards for the tour bus industry and other high-emitting vehicles (e.g., snowmobiles).
• Retire high-emitting vehicles from Federal fleets as quickly as possible and/or relocate high-emitting vehicles to less sensitive areas until they can be retired.
• Establish emission budgets from the transportation sector for selected FLM areas.
• Develop mass transit systems in some NPS units (e.g., light rail in Grand Canyon NP and a bus system in Zion NP).

Minor Source Strategies

• Apply RACT, BACT, LAER, best and reasonably available control measures, etc., to existing sources, as appropriate.
• Go beyond conformity requirements to include the protection of AQRVs in FLM areas by ensuring all actions FLMs can practicably control in and near FLM areas will not cause, or contribute to, an adverse impact on any AQRV.

Improved involvement with interested parties in gateway communities (those adjacent to FLM areas) will likely be required to ensure growth in these communities occurs in a manner that mitigates the impact on natural resources. These communities may need to enhance their participation in the planning processes of FLMs. Similarly, FLMs must participate in planning activities for public lands located in the FLM area and communities adjacent to FLM areas to ensure air quality concerns are adequately addressed. Mechanisms must be identified and developed for community involvement in developing, implementing, and enforcing emission management strategies for sources near and in FLM areas.

Implementing strategies to achieve emission reductions in and near FLM areas will require efforts in at least three specific areas:

1. FLMs should ensure that sufficient emphasis is placed in agency planning documents requiring the minimization of air pollution emissions from new activities or practices.
2. FLM agencies should inventory air pollution emissions within FLM areas. After emissions have been quantified, FLMs, States, and adjacent communities will be able to assess the impact of these emissions through the use of appropriate models. Knowledge of Class I area emissions will also improve FLM ability to consult with States during the development and review of their SIPs (especially visibility SIPs).
3. FLMs should cooperate with States and local communities in assessing the need for, and the development of, appropriate emission reduction strategies in and near FLM areas that address non-PSD sources. Without an acknowledgment from States and local communities that these sources may pose a threat to FLM areas and a systematic assessment of these potential impacts, current efforts to protect FLM area resources may be insufficient.

c. Conformity Requirements in Nonattainment Areas

Conformity criteria and procedures ensure that actions on lands administered by Federal agencies do not cause a violation of the NAAQS, increase the frequency of any standards violations, or delay attainment. Conformity to SIPs is only required for activities within nonattainment areas for non-transportation related sources if emissions are above de minimis levels and regionally significant. Any activity that represents 10 percent, or more, of the emission inventory for that pollutant in the non-attainment or maintenance area is regionally significant. Examples of actions that may require a conformity determination include road paving projects, ski area development, or mining. Activities such as prescribed fire, that are included in a conforming land management plan, are exempt from conformity requirements.

The FLM should define the process to be used in conformity determinations and perform the conformity analysis before a project is implemented. A conformity analysis typically includes emission calculations, public participation, mitigation measures/implementation schedules, and reporting methods. The Pacific Southwest Region of the USDA/FS has published a Conformity Handbook for FLMs to assist in conformity compliance. In an approved Plan of Operation, FLMs can require monitoring. For example, in the case of Carlota Mine, located on National Forest land in Arizona, the USDA/FS requested additional mitigation measures to protect AQRVs in the Superstition Wilderness.

Transportation projects in FLM areas classified as nonattainment are subject to a more complicated transportation conformity process. Consultation with State and local air quality and transportation agencies will be required to comply with applicable regulations.