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Clear Air Act


CONTENTS
Clean Air Legislation
Clean Air Act Amendments
Washington Clean Air Act
Primary Pollutants from Prescribed Fires
Fire as a Forest Management Tool
Smoke Management Programs
Meteorological Parameters Required for Smoke Management

Clean Air Legislation
Explosive industrialization, urbanization and the increased use of motor vehicles in the 1950s brought about serious concerns in the U.S. over the growth and complexity of air pollution problems. Interest in Federal clear air legislation began to increase in 1955 when Congress passed the Air Pollution Act of 1955. The legislation provided funding for research into the nature and extent of air pollution problems in the United States.

In 1963, Congress passed the Clean Air Act. The legislation encouraged the first air pollution abatement programs in the United States. It also provided Federal funds to assist control efforts by state and local government agencies and it established limited authority to abate interstate air pollution.

The Air Quality Act of 1967 gave the Secretary of the Department of Health, Education, and Welfare the authority to implement air pollution abatement programs anywhere in the United States.

The Clean Air Act of 1970 greatly increased Federal powers to to enforce air pollution abatement programs. The legislation was intended to protect and enhance the quality of this Nation's air resources and to protect the health and welfare of the general public. It directed the Environmental Protection Agency (EPA) to identify and publish a list of known air pollutants. The legislation directed the EPA Administrator to establish national primary and secondary ambient air quality standards for the identified air pollutants. Primary standards were set to protect public health while secondary standards were set at a level that would protect the public's welfare from any known or anticipated adverse effects of a pollutant. These included effects on soils, water, crops, vegetation, manmade materials, wildlife, animals, weather, visibility, climate, damage to and deterioration of property, hazards to transportation, and the effects on economic values and on personal comfort and well-being.

The Clean Air Act of 1970 required States to identify non-attainment areas (areas which do not meet the National Ambient Air Quality Standards) and to take specific actions to bring those areas into compliance. States were required to produce a State Implementation Plan (SIP) that described how they would achieve and then maintain Federal and State air quality standards. SIPs contain specific guidelines to reduce emissions. States can also reduce or eliminate the use of prescribed fire in non-attainment areas. States can also restrict the use of prescribed fire outside an area of non-attainment, if such fires would contribute to the particulate load within an area of non-attainment. Most importantly though, the Clean Air Act of 1970 provided Federal enforcement when non-attainment appeared to be caused by a State's failure to enforce its State Implementation Plan.


Clean Air Act Amendments
Amendments to the Clean Air Act in 1974 and 1977 provided for the prevention of significant deterioration of air quality in those areas where air quality was already superior to the national standards. Areas where air quality was already above the national standards were designated as Class I areas. The areas included all international parks, all national parks greater than 6,000 acres, all national wilderness areas, and memorial parks exceeding 5,000 acres.

Protection of visibility was an important aspect of the 1974 and 1977 amendments to the Clear Air Act. The legislation specifically set national goals to prevent any future impairment to the visibility in Class I areas and sought to remedy any existing impairment from human-caused sources of air pollution. Federal and state land management agencies were required by law to determine where impairments to visibility existed in Class I areas and to implement plans to bring those areas into compliance.

Part of this process involved the identification of integral vistas or vistas in Class I areas which are important to a visitor's visual experience. In the legislation, an integral vista was defined as a view of a specific landmark or panorama located outside of a Class I area which could be seen from within the Class I area.

However, visibility provisions in the '74 and '77 amendments only applied to major stationary sources of air pollution. They did not apply to prescribed fires since prescribed fires were defined as temporary sources of air pollution. Some state plans though, which can be more restrictive than the Federal regulations, do address temporary sources of air pollution.


Washington Clean Air Act
In the early 1970s, the Washington Clean Air Act designated the Washington State Department of Natural Resources as the state agency responsible for issuing permits and regulating specific types of forest residue burning in conformance with forest protection and air quality laws of Washington State. DNR accomplished this mandate through the creation of the Smoke Management Program that resulted in the first Smoke Management Plan that included voluntary agreements with major burners to reduce air pollution from the prescribed burning of forest residue.

Amendments to the Washington Clean Air Act in 1991 required modifications to the Smoke Management Plan. The major change was that participation in the program was no longer voluntary (except for Indian tribes).


Primary Pollutants Produced by Prescribed Fires
Prescribed fires produce pollutants which affect air quality. Primary emissions include particulates, hydrocarbons and carbon monoxide - all regulated by the Clean Air Act.

Particulate matter, or visible smoke, is regulated through the ambient air quality standard for Total Suspended Particulates (TSP). The standards for TSP cover a range of particles from 0 to 50 microns. Particulate matter of this size can remain suspended in the atmosphere for periods of a few seconds to several months. Suspended particulate matter is that portion of the TSP (<10 microns) which is transported large distances downwind and can have the greatest impact on air quality.

The EPA recommended that TSP, as an indicator of particulate matter, be replaced for primary and secondary standards by standards which include only those particles less than 10 microns (PM-10). The PM-10 standards focus on particles less than 10 microns because particles of this size are inhalable and can therefore affect human health (for comparison, a human hair is 70 microns).

Ninety percent (90%) of smoke particles from prescribed fires, or slash burns, are less than 10 microns, easily breathable and also good scatters of light. Eighty two percent (82%) or smoke particles from prescribed fires are less than 1 micron. Particles of this size can be trapped in alveoli in the lungs.

Range of Emission Factors from Forest Fire Smoke
Component Emission (lbs/ton) Potential Impacts
Carbon dioxide 2,000 - 3,500 No direct impact
Water vapor 500 - 1,500 Visibility
Carbon monoxide 20 - 500 Health
TSP 20 - 180 Visibility/Health
Hydrocarbons 10 - 40 Visibility/Health
Other organics Unknown Visibility/Health
Nitrogen oxides 1 - 9 Visibility/Health
Sulfur oxides Negligible Health


Fires as a Forest Management Tool
Fires and their associated smoke have been an integral part of the forest ecosystem since the beginning of time. Return cycles for major forest fires can range from 5 to 15 years in ponderosa pine to over 500 years in coastal forests of Washington and Oregon.

Fires can be classified into three main categories:

Prescribed Fires

These are fires ignited by land managers to achieve specific resource management objectives such as 1) site preparation for replanting, 2) aesthetic enhancement, 3) controlling undesirable species, 4) perpetuating fire dependent plant and animal species, 5) controlling insects and forest diseases, 6) improving wildlife habitat, and 7) wildfire hazard reduction.

Prescribed Natural Fires

These fires are naturally ignited fires (lightning or person-caused) but allowed to burn if they meet certain predetermined management objectives.

Wildfires

Wildfires are natural or person-caused fires that do not meet predetermined management objectives and are therefore actively suppressed.


Smoke Management Programs
Smoke management is the combined use of meteorology, fuel moisture, fuel loading, suppression and burn techniques to keep visibility and air quality impacts of smoke within acceptable limits. Smoke management practices provide the most practical and effective means of achieving objectives of the Clean Air Act with respect to prescribed fire emissions and PM10 standards.

Smoke management programs have three main objectives. They are :

1. Identify and avoid smoke sensitive areas

2. Reduce emissions

3. Disperse and dilute smoke before it reaches smoke sensitive areas.

The key to an effective smoke management program lies in the land manager's ability to combine favorable weather conditions with a variety of prescribed fire techniques to keep smoke emissions to a minimum.

Land managers use three techniques to manage smoke emissions from prescribed fires. They are:

Avoidance - Conduct prescribed burns on days when smoke intrusions into smoke sensitive areas is highly unlikely, i.e., burn on days when the winds will carry smoke away from smoke sensitive areas.

Dispersion/Dilution - Dispersion refers to processes within the atmosphere which mix and transport pollutants away from the source. Dispersion depends on three characteristics of the atmosphere; atmospheric stability, mixing heights, and transport winds. Burning during periods of good vertical dispersion or burning at slower rates will dilute smoke through greater volumes of air.

Emission reduction - Effective firing techniques and the proper scheduling of burns can minimize smoke output per unit area burned. Effective firing techniques include 1) backing fires which tend to minimize the inefficient smoldering phase, 2) burning when the duff and larger fuels are too wet to burn, producing less emissions, 3) increased utilization, i.e., remove more slash material from the burn site, 4) mop up as soon as possible to minimize the smoldering phase of the fire, 5) expand the burning season, 6) keep soil out of dozer piles and windrows, and 7) cover piles to keep fuels dry.

Winds and atmospheric stability are the two most important meteorological factors in an effective smoke management program. Smoke management forecasts usually include forecasts of transport winds and mixing heights. Many NWS offices forecast transport winds, which are defined as the mean wind speed and direction of all winds within the mixing layer. Some NWS offices forecast free air winds at predetermined levels in the atmosphere. The Seattle Fire Weather Office forecasts free air winds at 3 thousand, 5 thousand, and 7 thousand feet.

Local winds such as valley/slope winds or land/sea breezes are also important considerations in all smoke management forecasts. Local winds often become the transport winds, especially when winds above the fire become light, or at night when radiational cooling causes a surface-based inversion to form in the boundary layer, resulting in very low mixing heights.

Local downslope/downvalley winds can also cause residual smoke to drain downvalley into populated areas overnight. This is especially important for prescribed fires in the mopup or smoldering stage, since emissions from a smoldering fires are twice that of a flaming fire.

Atmospheric stability (a measure of the tendency for mixing in the vertical) determines the volume of air through which smoke will mix and therefore, it's concentration in the atmosphere. Most NWS offices forecast mixing heights which are defined as the height above the surface through which relatively vigorous mixing will take place in the vertical due to convection. Mixing heights are based on the intercept of a lifted parcel of air with the upper air sounding. Some offices forecast a Ventilation Index which is the product of the mixing height and the transport wind speed. A few NWS offices - mainly those in the Southern Region - forecast Pasquill Stability Categories which combine surface winds speeds with solar insolation and cloud cover to arrive at six stability categories ranging from A (extremely unstable) to F (moderately stable).


Please refer any questions or comments about this web site to: john.werth@noaa.gov