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WRAP PolicyFire Tracking Systems

DraftDecember 9, 2002

FEJF Meeting

December 10-11, 2002

Jackson, WY

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Introduction

Intent of WRAP FTS Policy– Assist states/tribes to address emissions inventory

and tracking associated with fire in a way that is adequate for SIP/TIP implementation.

WRAP FTS Policy Identifies– Essential fire activity information necessary to

consistently calculate emissions and uniformly assess fire impacts to regional haze.

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Section 309

“A statewide inventory and emissions tracking system (spatial and temporal) of VOC, NOx, elemental and organic carbon, and fine particle emissions from fire. In reporting and tracking emissions from fire within the State, States may use information from regional data gathering and tracking initiatives.” 51.309 (d)(6)(ii)

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Section 309 & Section 308

Periodic Progress Reports– Demonstrate reasonable progress– Tracking emissions of pollutants from all

sources (including fire)

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Section 308 SIP/TIP must provide for

– “...inventory of emissions of pollutants that are reasonably anticipated to cause or contribute to visibility impairment…” 51.308(d)(4)(v)

Long-Term Strategies– Emissions information relied upon to determine the

emission reduction obligations

– Identify all anthropogenic sources of visibility impairment considering area sources

– Anticipated net effect on visibility due to projected changes in area source emissions

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Policy Statement A

Fire activity information for all fire types is needed in the WRAP region. A fire tracking system that captures this information will form the basis of a fire emissions inventory compiled annually, which is needed to support Regional Haze Rule requirements.

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Policy Statement B A fire tracking system includes the following seven

essential components that are necessary in order to consistently calculate emissions and to uniformly assess impacts to regional haze:

1. Date of Burn

2. Burn Location

3. Area of Burn

4. Fuel Type

5. Pre-Burn Fuel Loading

6. Type of Burn

7. “Anthropogenic” or “Natural” Classification

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Policy Statement C

A fire tracking system should include additional components as needed to support the development and implementation of annual emission goals and other control measures.

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Policy Statement D

A fire tracking system should include a component that addresses the projection of fire emissions, which is necessary to meet the requirements of the Regional Haze Rule.

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Policy Statement E

The development of fire tracking systems by states and tribes will be done collaboratively with state, tribal, local and federal land management agencies, and private parties.

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Appendix CSupporting Information Essential Components 1 through 7 Optional Components

– Daily Tracking– Fuel Consumption– Non-Burning Alternatives – Additional Fire Tracking Information

Data Collection Methods– Direct Data Collection– Indirect Estimation

NEW

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Future FTS Related Work Assess potential de minimis levels

– FEJF base on source/impact relationships

Format for fire tracking system components– FEJF work closely with Emissions Forum

– FEJF develop further guidance

• procedure for submittal and format of fire tracking system information

• quality assurance methods

Fire emissions projection component– FEJF develop guidance

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WRAP November 13, 2002

WRAP FTS Policy presented by Pete WRAP Board discussion

– No major concerns– FEJF thanked for developing the FTS Policy– Support for FTS Policy but no formal action

due to ongoing comment period– Support for the FEJF to come back to the

WRAP Board for an e-mail approval process prior to the next WRAP meeting

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WRAP FTS Policy Review

November 4 - 15, 2002– WRAP website posting– Notice of review to 200+ people

10 Comments Received– 7 States (AK, CA, CO, ID, OR, UT, WY)– EPA OAQPS– Salish and Kootenai Confederated Tribes– NTEC

Comment summary will be posted

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Changes Based on Comments

No changes to Policy Statements. Clarification regarding states/tribes

responsibility to supply essential activity information from their FTS to the WRAP.

Addition of Non-Burning Alternatives section to the Optional Components in Appendix C.

Revised Fire Emissions Projection annotation for clarification.

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Changes Based on Comments

Applicability of FTS to other emission inventory needs (e.g., NAAQS).

Inclusion of some sources not addressed by the Policy (e.g., residential wood combustion) in other emissions inventory efforts as area sources in populated areas.

Tribal language modified for appropriateness and consistency.

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Changes Based on Comments Additional footnoting for clarification purposes. Additional website references for FEJF work

products. Other minor formatting/wordsmithing changes

throughout. Several comments applicable to upcoming work

(i.e., guidance) will be forwarded to a new FEJF Task Team for consideration.

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Review / Approval Process

FEJF– Review December 10-19, 2002– Conference Call December 19, 2002 for

consensus approval

WRAP– E-mail review and consensus approval– After FEJF consensus approval and before the

next WRAP meeting (April 2-3, 2003)