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"Big League" Burners



Is this page SO not my problem?


If your burn program belongs in Colorado's big league and you don't already know about the 'significant user' process, you probably don't need to worry about it.  Chances are your agency's main or regional office or your ranch manager already took care of it for you.




Colorado law has special provisions for property owners and land management agencies that make it into Colorado's big league for prescribed burning. Every ten years these most active burners must complete a review with the Air Comission to determine that their decisions about when to use prescribed fire are made in ways consistent with protecting air quality. In essence, while individual smoke permits set boundaries on the 'how' about managing smoke, a "significant user" hearing reviews the 'whether.'


Is your burn program in or approaching the big leagues? To qualify, the entity for which you burn must own or manage more than 10,000 acres in Colorado, and its prescribed burns generate at least 10 tons a year of particulate matter, PM-10.  Very approximate examples of projects that generate 10 tons of PM-10 are one permit for 500 piles of 1,000 ft3 each, or five permits each to underburn 60 acres of healthy ponderosa.


If so, your program is, in the words of the legislation, a significant user of prescribed fire.  (We definitely don't consider everyone else who burns as insignificant, but we might as well enjoy the more recent word associations for significant users of something.)  Significant users include most of Colorado's large public land management agencies and a few large ranches. 

As of 2013, the following entities have successfully completed significant user reviews:

  • Air Force Academy
  • Banded Peak Area Ranches*
  • Blue Valley Ranch*
  • Bureau of Land Management
  • Colorado Parks and Wildlife Division
  • Colorado State Land Board
  • Denver Water Board
  • Fort Carson
  • Jefferson County Open Space
  • Larimer County Natural Areas
  • National Park Service
  • Trinchera Ranch*
  • U.S. Fish and Wildlife Service
  • U.S. Forest Service


* privately owned land

The Air Quality Control Commission considers each significant user's planning document at a public hearing. The document describes how decisions are made to identify fuel treatment alternatives to achieve resource objective goals and how decisions are made to select among various fuel treatment alternatives. It demonstrates for lands selected for fuel treatment how compliance with the State standard will be achieved. The State standard requires that air pollution emissions be minimized to the extent feasible, practicable and reasonable.


The Commission doesn't approve or disapprove of a planning document.  Instead, after considering the document and the processes it describes, the Commission may make formal comments.  If it does, staff must take those comments into account when issuing smoke permits for the lands covered by the planning document.  The Commission's review is valid for ten years, or less if the land manager's planning processes change substantially.


It can take 6-12 months to generate then secure review of a planning document.  If your program may even be approaching the threshold, contact us.  Planning documents are public record. We will send you examples if you ask.  The examples can be very helpful for a manager preparing their agency's or ranch's significant user planning document. The Air Division is required to charge an hourly fee to review and process significant user planning documents for a public hearing.