WRAP Policy Fire Tracking Systems Draft December 9, 2002

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WRAP PolicyFire Tracking SystemsDraftDecember
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)