Smoke management program updates

 
 
Revisions to standard permit conditions, July 2015
 
Summary
  • For all new permits, at least one public notification message must include a specifically-worded health statement.
  • Daily maximum numbers of piles or acres have been increased for some permitting categories.  The changes reflect Colorado’s experiences with prescribed fire smoke over the last five years.
Implementation, effective Aug. 1, 2015:
  • Health message:  Wording and mechanics of the new required health message are detailed on our health messaging page.  If you have questions or comments, please let us know.
  • New projects:  New standard permits will have the new conditions.  You don’t need to do anything special.  For a new project, please use a current application form
  • Renewals, and existing 2015 permits:  If you want an existing permit amended so that it has the new conditions for the remainder of 2015, and also when you are ready to request renewals for 2016, send an email to cdphe_fireapps@state.co.us with
  1. The name(s) and/or permit number(s) of the project(s),
  2. Notes about any minor changes, or say that there are none other than the year.  
  3. In this transitional year, indicate which method you will use to distribute the health message.  Specifically, for each project choose one or more of the following and in the email tell us which: 
___    Project-specific press release.  Send a copy to cdphe_fireapps@state.co.us.       
___    Seasonal press release.  Send a copy to cdphe_fireapps@state.co.us.       
___    Other:    ___________________       
___    APCD’s neighbor letter, to all homes within ___ miles     
 
Amendments
 
If you request an amendment for 2015, the new health outreach must be completed and sent to APCD before the new conditions may be used, even if that involves additional unplanned outreach effort.
 
Renewals
 
If you choose not to put your renewal on the most current application form, we’ll paste in the new block about health messaging.  In order to do this, we must have the information on how you will distribute the health message. If you are renewing a long-duration project on a form that needs updating, we’ll let you know.
  • Worksheets:  To see the updated new worksheets, go to
-  Broadcast worksheept.  The broadcast worksheet now refers to canopy closure rather than canopy cover, correcting a previous error.
If you would like to compare the new versus old standard conditions, please see the Powerpoint presentation used during the June stakeholder conference call.
 
Background
 
Measurements of particulate concentrations at some burns late in 2013 showed that existing standard permit conditions can result in smoke concentrations several times as high as the National Ambient Air Quality Standards (NAAQS).  The data suggested it is not reasonably possible for prescribed burns always to remain below the NAAQS.  For a prescribed burn program that at least continues historic activity, it is likely that sometimes air quality at the nearest occupied home may rate as “unhealthy for everyone” or even “hazardous.”
A key response to the new information is due diligence in advising residents about the health consequences of possibly heavy smoke.  Agencies and landowners who conduct prescribed fires in Colorado must now give potentially affected people the link to our wood smoke and health web page: www.colorado.gov/cdphe/wood-smoke-and-health.
Also, in responding to the new information, we recognized an opportunity to evaluate smoke management in light of long-term air quality tradeoffs.  It matters little for air quality whether any given quantity of wildland fuel burns in a prescribed fire or eventually burns in a wildfire.  Even whether one form of fire is better for air quality is uncertain. 
Given that the difference in consequences for air quality is minor, and recognizing that prescribed fire is preferable to wildfire for many resources other than air quality, we are increasing the amount of prescribed fire that smoke permits allow.
Because smoke from prescribed fires sometimes reaches levels that can have substantial health consequences, increased diligence in advising impacted people about the smoke is necessary.
We will continue to manage a smoke program that meets the requirements in Air Quality Control Commission Regulation 9.  Some of the regulation’s provisions are:
  • In order to minimize emissions and smoke impacts, each permittee shall use the best smoke management techniques appropriate to the proposed burn. (IV. C. 2)
  • To the degree practical, all burning shall be conducted during periods conducive to smoke dispersal. (IV. C. 3)
  • The authority granting the permit may impose conditions on wind direction at the time of the burn to minimize smoke impacts on smoke-sensitive areas.  (IV. C. 6)
  • APCD must consider whether the applicant will notify the public about the location, expected duration and projected smoke impacts from the fire.  (V. D. 8. e) 
  • Planned ignition fire permits shall include… All permit conditions necessary to ensure that the burn will be conducted so as to minimize the impacts of the fire on visibility and on public health and welfare. (V. E.)
The ways in which Regulation 9’s mandates will be met include continuation of most existing permit requirements other than daily activity limits: public notification, conditions that vary by forecasted ventilation, limits on sequential days of broadcast ignition for burns most likely to generate smoke at night, ending ignition times by sunset or earlier, use of specialized non-standard conditions for some burns, etc.  Our focus in smoke program evolution continues to be incremental change based on shared learning, and on shared responsibility for the outcomes of required good decision-making.
For information about specific changes please see our June 2015 presentation on Revisions to Standards Conditions.