AIR QUALITY POLICY ON
AGRICULTURAL BURNING
RECOMMENDATION FROM THE
AGRICULTURAL AIR QUALITY
TASK FORCE
TO
U.S. DEPARTMENT OF
AGRICULTURE
November 10, 1999
Executive
Summary
The AAQTF Agricultural Burning Policy recommends States/Tribes adopt a Smoke Management Program (SMP) to reduce the public health and welfare impacts of using burning in support of agricultural production. The SMP is implemented through an Agricultural Burning Manager (ABM)—the air quality agency or designated authority responsible for managing agricultural burning at the state, local, or tribal level. The policy is founded on two basic principles: (1) allow the use of fire as an accepted management practice, consistent with good science, to maintain agricultural production; and (2) protect public health and welfare by mitigating the impacts of air pollution emissions on air quality and visibility. The recommended SMP is two-tiered. De minimis fires, as established by the ABM, are exempt.
Tier One: Tier 1 is a voluntary program for areas where agricultural burning rarely causes or contributes to air quality problems. The SMP establishes conditions (time of day and year, meteorological conditions, safety parameters, type of burn, maximum number of acres, etc.) under which agricultural burning can occur. It is essentially a permit by rule.
Tier Two: Tier 2 is a more structured program than Tier 1 and is designed for areas where agricultural burning contributes to Particulate Matter National Ambient Air Quality Standards violations or visibility impairment in Class I Federal areas. (Areas set aside under the Clean Air Act to receive he most stringent protection from air quality degradation.) The SMP would include a process for authorizing/granting approval for agricultural burns and establish criteria for burn/no-burn decisions. Detailed permitting requirements such as a real-time meteorological assessment for bun decisions, air quality monitoring, public notification, and enforcement requirements would likely be included in a Tier 2 SMP.
The policy also recommends additional research in the following areas: the ability to predict downwind concentrations of particulate matter utilizing various modeling techniques; evaluating the applicability of current sampling techniques to agricultural burning; determining accurate emission factors; evaluating techniques to reduce emissions of material determined detrimental to human health and visibility; and developing alternatives to agricultural burning.
I. DEFINITIONS
II. PURPOSE
III. SCOPE AND APPLICATIBILITY
IV. BACKGROUND
A. Role of Fire in Agriculture
B. Summary of Selected Agricultural
Burning Practices
C. Air Quality Considerations
D. Current Regulations at State and
Local Levels
E. Visibility Impairment
V. DESCRIPTION OF POLICY
VI. SMOKE
MANAGEMENT PROGRAM (SMP)
A. Tier I Smoke Management Program
(Tier 1SMP)
B. Tier II Smoke Management Program
(Tier 2 SMP)
1. Authorized to Burn
2. Reducing Air Pollutant Emissions
3. Smoke Management Program
Components
4. Producer/Public Education and
Awareness
5. Surveillance and Enforcement
6. Program Evaluation
VII. RESEARCH
NEEDS
A.
Dispersion Modeling
1. Localized
2. Long-range or Airshed
B.
Emissions Factors
C.
Emission Reduction Techniques
D.
Health Effects
E.
Sampling
F.
Gas Emission Rate
G.
Alternatives to Burning
Agricultural Burning: Burning in the open of vegetative materials from
the production and harvesting of crops and animals for the purpose of marketing
for profit, or providing a livelihood. This practice is generally used to
reduce crop residue, stimulate yield, control diseases, reduce unwanted plant
species, or otherwise maintain the productivity of agricultural lands.
Burning of small areas of
land adjoining crop and rangeland for fire, weed, and disease control, etc.
would fall under the definition of de minimis fires.
Agricultural Burning Manager: The Air Quality Agency or designated authority
responsible for managing agricultural burning at the state, local or tribal
level.
Agricultural Land: Land that includes croplands, rangelands (public or private), pasture
and other lands on which crops or livestock are produced (P.L. 104-127, Sec.
1240A). This includes land enrolled in the Conservation Reserve Program.
Air Quality Agency: The regulatory body responsible for managing the air
quality protection program for a state, local or tribal government.
Air Quality: The characteristics of the ambient air (all locations accessible to the
general public) as indicated by concentrations of the six air pollutants for
which national standards have been established, i.e., particulate matter (PM),
sulfur dioxide (SO2), nitrogen dioxide (NO2),
ozone (O3), carbon monoxide (CO) and lead (Pb), and by visibility in
mandatory Class I Federal areas. For the purposes of this policy,
concentrations of particulate matter are taken as the primary indicators of
ambient air quality.
Ambient Air: That portion of the atmosphere, external to buildings, to which the
general public has access.
AP-42: The Environmental Protection Agency’s compilation of air pollutant
emission factors for stationary point, area and mobile sources. An emission
factor is a representative value that attempts to relate the quantity of a
pollutant released to the atmosphere with an activity associated with the
release of that pollutant. Emission factors are then used to estimate the
magnitude of a source’s pollutant emissions.
Class I Federal Area: An area set aside under the Clean Air Act (CAA) to
receive the most stringent protection from air quality degradation. Mandatory
Class I Federal areas are: (1) international parks; (2) national wilderness
areas which exceed 5,000 acres in size; (3) national memorial parks which
exceed 5,000 acres in size; and, (4) national parks which exceed 6,000 acres
and were in existence prior to the 1977 CAA amendments. The extent of a
mandatory Class I Federal area includes subsequent changes in boundaries, such
as park expansions.
De Minimis Fires: The maximum number of acres and/or tons of fuel allowed to be burned
without a Smoke Management Program as established by the Agricultural Burning
Manager on a case-by-case basis.
Indian Land: Indian land in this document refers to Indian country which is: (1) all
land within the limits of any Indian reservation under the jurisdiction of the
United States government, notwithstanding the issuance
of any patent and, including rights-of-way running through the reservation; (2)
all dependent Indian communities within the borders of the United States whether
within the original or subsequently acquired territory thereof, and whether
within or without the limits of a state; and, (3) all Indian allotments, the
Indian titles to which have not been extinguished, including rights-of-way
running through the same. [See 18 U.S.C. 1151.]
National Ambient Air Quality Standards (NAAQS): Standards for maximum
acceptable concentrations of pollutants in the ambient air to protect public
health with an adequate margin of safety and to protect public welfare from any
known or anticipated adverse effects of such pollutants, e.g., visibility
impairment, soiling, materials damage, etc., in the ambient air.
Particulate Matter (PM): Any airborne material, except uncombined water,
which exists as a solid or liquid at standard conditions, e.g., dust, smoke,
mist, fumes, or smog and can be divided into the following:
a. PM2.5: Particles with an
aerodynamic diameter less than or equal to a nominal 2.5 micrometers;
b. PM10: Particles with an
aerodynamic diameter less than or equal to a nominal 10 micrometers (including
PM2.5);
c. Fine-Mode: Generally referred to as PM2.5;
d. Coarse-Mode: Generally referred to as PM10-PM2.5;
e. Ultra-Fine Mode: Generally referred to as equal to PM1 and
below.
Pasture Land: Land used primarily for the production of adapted, introduced, or
native forage plants for livestock grazing. Pasture land may consist of single
species in a pure stand, grass mixture or a grass-legume mixture. Culture
treatment in the form of fertilization, weed control, reseeding, or renovation
is usually a part of pasture management in addition to grazing management.
Native pasture is included.
Prescribed Fire: Any fire ignited by management actions to meet specific objectives,
i.e., managed to achieve resource benefits.
Prevention of Significant Deterioration (PSD): A requirement in the CAA
which establishes the maximum allowable increases in ambient air concentrations
of selected air pollutants above baseline concentrations in designated Class I,
Class II or Class III areas.
Rangeland: Land on which the climax vegetation (potential natural community) is
predominantly grasses, grass-like plants, forbs, or shrubs suitable for grazing
or browsing. Including natural grasslands, savannas, many wetlands, some
deserts, tundra, and certain forbs and shrub communities. It also includes
areas seeded to native or adapted introduced species that are managed like
native vegetation.
Regional Haze: Generally, concentrations of fine particles in the atmosphere
extending up to hundreds of miles across a region and promoting noticeably hazy
conditions; wide-spread visibility impairment, especially in mandatory Class I
Federal areas where visibility is an important value.
Smoke Management Program (SMP): Establishes a basic framework of procedures and
requirements for managing smoke from fires that are managed for resource
benefits. The purposes of SMP's are to mitigate smoke intrusions into populated
areas and public safety hazards, e.g., on roadways and at airports, to prevent
deterioration of air quality and NAAQS violations; and, to address visibility
impacts in mandatory Class I Federal areas in accordance with the regional haze
rule.
State Implementation Plan (SIP): A CAA required document in which States adopt
emission reduction measures necessary to attain and maintain the NAAQS and to
meet other requirements of the CAA.
Volatile Organic Compounds (VOCs): Any organic compound that participates in
atmospheric photochemical reactions, which are measured by a reference method,
an equivalent method, or an alternative method. Some compounds are specifically
listed as exempt due to their negligible photochemical reactivity [see 40 CFR
51.100]. Photochemical reactions of VOCs with oxides of nitrogen and sulfur can
produce ozone and particulate matter.
Wildfire: An unwanted wildland fire.
Wildland: An area where development is generally limited to roads, railroads,
power lines and widely scattered structures. The land is not cultivated, i.e.,
the soil is disturbed less frequently than once in 10 years, is not fallow, and
is not in the USDA’s Conservation Reserve Program (CRP). The land may be
neglected altogether or managed for such purposes as wood or forage production,
wildlife, recreation, wetlands or protective plant cover.
Wildland Fire: Any non-structural fire, other than prescribed fire, that occurs in the
wildland. Note: wildland fires
include unwanted (wild) fires and naturally ignited fires that are managed
within a prescription to achieve resource benefits.
II. PURPOSE
The Agricultural Burning Policy recommendations have been prepared in response to implementing provisions of the Clean Air Act (CAA) and the concerns of agricultural producers to retain the valid use of fire as a management tool in support of agricultural production. Fire has continued to be a management tool used by private and public land owners/producers for agricultural production and land management and, therefore, has a long-standing context in the planning and regulation requirements of Air Quality Agencies or Agricultural Burning Managers.
This Agricultural Burn Policy addresses two public policy goals: (1) to allow the use of fire as an accepted management practice, consistent with good science, to maintain agricultural production on agricultural land; and, (2) to protect public health and welfare by mitigating the impacts of air pollution emissions on air quality and visibility.
This policy provides
guidance on reducing air pollution impacts caused by burning in support of
agricultural production. It identifies a two-tier approach to the regulation of
agricultural burning by Agricultural Burning Managers. This two-tier approach
recognizes the large range of agricultural burning practices and their
contribution to regional air quality.
The process used to develop
this policy involves a multi-stakeholder approach. The USDA Agricultural Air
Quality Task Force has developed recommendations using a consensus approach as
outlined in a Memorandum Of Understanding (MOU) between the Secretary of
Agriculture and the U.S. EPA Administrator (see Attachment I). The USDA
Agricultural Air Quality Task Force includes representation from agricultural
producers, air quality researchers, agricultural industry representatives,
medical researchers and state air quality and USDA staff.
III. SCOPE AND
APPLICABILITY
The EPA does not directly
regulate the practice of agricultural burning within a state or on Indian
lands. The EPA's authority is to
enforce the requirements of the CAA. The CAA requires States and Tribes to
attain and maintain the National Ambient Air Quality Standards (NAAQS) adopted
to protect public health and welfare. This policy incorporates recommendations
that States/Tribes implement smoke management programs (SMPs) to reduce the
public health and welfare impacts of agricultural burning. It further
recommends that SMPs be composed of a two-tier system as described in the Smoke
Management Program in Section V.
This policy does not apply
to wildland fires, or burning at residential, commercial, or industrial sites,
or burning of construction debris. Wildland fires are addressed in the EPA's
Interim Air Quality Policy on Wildland and Prescribed Fires.
This policy applies to the
valid use of fire as a management tool in support of agricultural production.
In addition, this policy addresses the impacts of air pollutant emissions as
described by the NAAQS, on public health and welfare from agricultural burning
practices. The NAAQS establish primary and secondary benchmarks for emission
limitations for six criteria pollutants deemed by the EPA to endanger public
health and welfare. The primary standards prescribe the maximum permissible
concentration of a pollutant in the ambient air before it begins to impact
public health. Secondary standards specify the level of pollutant concentrations
that protect public welfare from any known or anticipated adverse effect(s).
The pollutants addressed by the NAAQS include sulfur dioxide, particulate
matter, carbon monoxide, ozone, nitrogen dioxide and lead.
Emissions from agricultural
burning practices include: particulate matter with an aerodynamic diameter less
than or equal to a nominal 2.5 micrometers (PM2.5); particles with
an aerodynamic diameter less than or equal to a nominal 10 micrometers (PM10),
nitrogen oxides (NOx); volatile organic compounds (VOCs); and,
carbon monoxide (CO). Emissions from agricultural burning may also have an
impact on ambient ozone concentrations.
IV. BACKGROUND
A. Role of Fire in
Agriculture
Fire has been an integral
part of agricultural management as long as man has systematically grown crops.
Modern technologically based agriculture still utilizes burning and for some
crops it is the only economical means available to deal with residue.
The reasons for burning vary. The most common reasons are to reduce pre- and post-harvest vegetation that interferes with harvest, tillage or subsequent seedbed preparation. Burning is used for pest and weed control and lowers the need for supplemental herbicide and pesticide treatments. For example, the occasional burning of pruning and other vegetative debris are important controls for pest and disease in the orchard industry. Certain crops require burning to stimulate new growth and trigger higher yield, e.g., blue grass varieties, and strongly influence the economic sustainability of the grass seed industry. Burning is also used periodically to reduce fire hazard, e.g., on rangelands, weed infestation, and clogging of ditches and irrigation canals.
The following summary of crop burning practices and
approximate acres burned are based upon the Technical Report submitted by
Louisiana Commissioner of Agriculture and Forestry, Bob Odom, and attachments
provided by Assistant Commissioner of Soil and Water (Louisiana Department of
Agriculture and Forestry) Bradley E. Spicer. Dr. Jerry Lemunyon of Arlington,
Texas compiled data on the burning of croplands with the assistance of
USDA-NRCS staff.[1]
B. Summary of Selected
Agricultural Burning Practices
Sugarcane
Burning of sugarcane prior
to harvest is utilized to deal with the approximately 30% residue portion of
the plant. Of 50 tons of sugarcane about 15 tons of residue needs to be burned
and there is no currently profitable or effective way to deal with this large
volume of residue by mechanical means. Controlled cane burning allows more
efficient harvesting in the field, controls insect problems and improves sugar
quality and recovery in the factory. Harvesting burned cane results in less
soil being brought to the mill; reduced fuel consumption in transporting less
material; less water in washing the crop prior to milling; and, less waste,
i.e., water, soil and trash, to recycle at the mill site. Reducing transport
within the field lessens soil compaction and minimizes tillage, resulting in
less damage to the soil structure and improved germination during the next crop
cycle. Approximately 96% of the 890,000 acres of sugarcane grown in Florida,
Louisiana, Hawaii, and Texas require burning.
Deciduous Fruits, Nuts, Grapes, Berries, etc.
Commercial crops grown on
trees, vines, and bushes require pruning after crop harvesting. While the
residue can be chopped or shredded for many crops, soil incorporation would
damage shallow root systems. After the residue has dried, burning can be an
effective means of disposal. Burning is also utilized as an effective means of
disease control on new prunings to control secondary pests in the older residue
and for phytosanitary emergencies.
In some areas smudge pots
are used for frost protection in sensitive blooming species, but are being
replaced by alternative frost protection systems, such as wind machines or
sprinkler applications.
Burning of orchard residue
is not the only means of disposal available. Approximately 5% of the 4.7
million acres of these crops are burned annually (Odom, 1997).
Rice
Significant acres of rice
straw have been traditionally burned after harvest. This practice is declining
due to air quality concerns and the development of techniques to incorporate
rice straw into the soil. Burning may still be necessary for certain pest
control and mechanical tillage does add to the cost of operation.
Approximately 20% of the 3.1
million acres of rice grown in Arkansas, Louisiana, California, Texas,
Mississippi, and Missouri is burned annually.
Small Grains
In many parts of the
country, small grain stubble is burned. The reasons for burning vary but
generally fall into the category of residue removal, reducing the number of
tillage operations for subsequent planting and periodic disease control, e.g.,
Cephalosporium. Alternative practices to burning are increasingly being
utilized including short-stem varieties, minimum tillage practices and removal,
i.e., baling of excess straw. Some additional costs may be incurred to the
farming operation by these alternative practices, but on the other hand, there
are benefits such as making it more feasible to use no-till seeding technology
that reduce production costs.
Over 70 million acres are in small grain production in the United States. Not all States adequately track acres burned, but a conservative estimate of acres burned annually, is 7 to 8 million acres.
Rangeland and Pasture
Prescribed fire is used on
rangeland and pasture to control undesirable plant species (particularly woody
species), restore natural grassland communities, improve the quality and
quantity of forage for livestock and wildlife, improve grass cover to protect
the soil from erosion, and improve water yield from seeps and springs, among
other things. Available alternatives such as mechanical brush control and
chemical treatments (herbicides) can be expensive and detrimental to the
environment given the large acres needing treatment.
Of the 1.9 billion acres of
land in the contiguous United States, rangeland and pasture land account for
about 725 million acres. Of this, about 200 million acres of rangeland are
federally owned (525 million acres of private rangeland and pasture land); in
contrast to United States cropland that is essentially all privately owned.
Currently, there are not good estimates on how much private rangeland and
pasture are burned annually. In Kansas, ranchers burn between 3 and 4.5 million
acres each year. NRCS has estimated that nationally about 18 million acres of
private rangeland and pasture need to be burned each year.
Grass Seed
Burning of grass seed fields
is a long-standing practice that effectively removes residue, controls disease
and stimulates tillering and flower formation that leads to higher yields.
Grass seed production occurs in limited areas of suitable soil and climate,
i.e., within the interior core area of the Pacific Northwest. Burning of grass
fields is carried out in late summer and fall and is highly visible in those
regions. Due to public pressure, grass burning is being phased out in
Washington. Because of differing and changing regulatory policies, some
inter-state movement of the grass seed industry is beginning to take place and
in some instances, is happening at a fairly significant pace.
Alternative measures to
grass burning include residue removal and shorter crop cycles. In addition,
breeding programs are trying to develop new varieties that maintain yields
without burning. Approximately 400,000 acres of grass seed fields are burned
annually in the United States.
Miscellaneous Agricultural Activities, Corn and Other Row Crops, CRP,
Ditch Cleanout, Land Clearing, etc.
Burning is occasionally used
in other agricultural management practices. The Conservation Reserve Program
(CRP) allows burning as an approved practice to decrease unwanted biomass or
control pests. Burning is used extensively in small areas for wildfire control,
weed and pest control in ditches, adjacent non-crop land areas and occasional
minor land clearing. The individual acreage is small and the practice is often
invaluable as an alternative to herbicide use on agricultural land and near
watercourses. The NRCS estimates that approximately 2 million acres of CRP land
is burned annually; about 2.5 million acres of non-crop land adjacent to
agricultural operations is burned annually.
Summary
There are over 295 million acres of cropland harvested annually in the United States. Burning is used on approximately 3% (8.9 million acres) each year. Of the 600 million acres of grazing land in the continental United States, about 18 million acres need to be burned annually. An additional 2 million acres of CRP land and 2.5 million acres of irrigation ditches and other non-crop agricultural land areas require burning each year.
Burning of vegetative matter associated with agricultural
land management produces emissions of PM10 and PM2.5. In
addition, burning results in emissions of nitrogen oxides, carbon monoxide and
organic compounds. The components and quantity of emissions depend on a variety
of factors including type of fuel burned, fuel moisture content, ignition
techniques, fuel conditions and temperature of combustion. The concentration of
particulate matter in the air is also strongly influenced by local
meteorological conditions including the low-level lapse rate, stability of the
overlying atmosphere and velocity of transport winds above the surface.
Prior to 1987, the NAAQS for
particulate matter focused on “Total Suspended Particles” including particles
as large as 100 micrometers in diameter. The EPA revised the standards in 1987
to focus control on PM10 in response to new science showing that it
was the smaller particles capable of penetrating deeply into the lungs that
were associated with the most adverse health effects. (Criteria Document - U.S.
EPA, 1996a, p. 13-1). In 1997, the EPA set a “fine” particulate matter standard
and is required to review and revise this standard, as necessary, along with
all particulate matter standards by 2002.
D. Current Regulation
at State and Local Levels
In many States (the south, southwest, intermountain west) agricultural burning is a long-standing vital practice that generally occurs in rural regions with low population densities. In general, these States regulate agricultural burning in the form of a "permit-by-rule" system. The Agricultural Burning Manager establishes a set of requirements under which burning can take place. These commonly include burner demographic information, crop type, acreage, etc., and permissible burning conditions, e.g., time of year, time of day, meteorological conditions, local notification, et al. If these conditions are met, the burning is allowed without any on-site ambient monitoring. Some states require written permits, while others do not. In other States, an Agricultural Burning Manager may determine if the daily meteorological conditions are appropriate to declare a burn or no-burn condition. A large proportion of agricultural burning is currently controlled under these types of regulatory processes where there is limited impact on urban airsheds.
In other States, e.g.,
California, Oregon, Eastern Washington, agricultural burning may impact urban
airsheds. Although agricultural smoke is highly visible, its contribution to
ambient concentrations of pollution in urban areas has not been objectively
determined. Some States have regional airsheds that are prone to serious air
stagnation conditions, e.g., the Willamette, Sacramento and San Joaquin
Valleys. In these regions, agricultural burning may be a significant
contributor to particulate matter. As a result, these States have curtailed
and/or seriously regulated agricultural burning.
In doing so, an Air Quality
Agency may identify local, regional or tribal Agricultural Burning Managers to
establish detailed permitting requirements for burning, such as a SMP. The
purpose of the SMP is to mitigate smoke intrusion and public safety hazard into
populated areas by establishing procedures and requirements for agricultural
burns being managed for resource benefits. The SMP should prevent a significant
deterioration of air quality and prevent NAAQS violations. The Agricultural
Burning Manager in these States will generally include specific permitting
requirements for burners and may also specify a real-time meteorological
assessment for burn decisions, air quality monitoring procedures, public
notification, enforcement requirements and a detailed program assessment.
In some States, the local
county or city government is encouraged to establish an air pollution
authority, which may have far more stringent guidelines for agricultural
burning than the Air Quality Agency. Some Air Quality Agencies use a
“permit-by-rule” system. In short, the type and extent of burning requirements
mandated at the state and local levels are broad ranging and responsive to the
needs of a particular state or region, in addition to not unduly burdening the
agricultural industry.
E. Visibility
Impairment
Visibility is an important
public welfare consideration because of its significance to the enjoyment of
daily activities in all parts of the country. The scattering and absorption of
light by particles and gases affect visibility conditions. High relative
humidity can also affect visibility. Increasing humidity in the presence of
airborne fine particulate matter is a factor in reducing visibility. Protection
of visibility as a public welfare consideration is addressed through the
secondary particulate matter NAAQS. Congress has established a national goal
for visibility protection and remediation for mandatory Class I Federal areas.
Currently, 156 national parks and wilderness areas have this designation.
The burning of vegetative
matter associated with agricultural land management produces a range of
particulate emissions and ozone precursors. Therefore, it has the potential to
impact visibility in mandatory Class I Federal areas.
In 1980, the EPA published
regulations (40 CFR 51.300) requiring the consideration of effects on
visibility by nearby source(s) in mandatory Class I Federal areas. On July 1,
1999 the EPA’s final regional haze rule was published (64 FR 35713). It
establishes a program to facilitate the integration of emission management
strategies for regional haze with SIP components that address emissions of NOx,
SO2,VOCs and PM2.5. The rule strongly encourages
multi-state regional planning efforts to address the haze issue and Air Quality
Agencies are moving forward with this effort.
V. DESCRIPTION OF
POLICY
This policy recommendation
regarding agricultural burning that is managed for resource benefit encourages
collaboration between owners/producers and Agricultural Burning Managers. The
goals of the Agricultural Burning Policy are to: (1) allow fire to function as
a valid tool for agricultural production; and, (2) protect public health and
welfare by minimizing smoke impacts. Agricultural Burning Managers are urged to
solicit information from private agricultural owners/producers on plans to use
fire for resource management, to encourage appropriate alternative treatments,
and to assist them in evaluating the potential air quality impacts of alternatives
to meet particular management objectives.
Agricultural owners/producers are urged to: (1) consider the air quality impacts from fire and take appropriate steps to minimize those impacts; (2) consider appropriate alternative treatment and uses; and, (3) participate in the development and implementation of SMPs. This policy recommends a two-tier approach in the development of a SMP.
The EPA will allow
Agricultural Burning Managers flexibility in their approach to regulating fires
managed for agricultural resource benefits. Agricultural Burning Managers are
not required to change their existing fire management policies/regulations if
they adequately protect air quality. The following incentives exist for
Agricultural Burning Managers to implement a SMP that includes the basic
components outlined in this policy. The main incentive is that as long as the
daily and annual PM2.5 and PM10 NAAQS are not violated by
sources reasonably attributed to agricultural burning, the SMP is considered a
voluntary action and does not have to be adopted into the SIP. Another
incentive is the commitment that the EPA may use its discretion not to
designate an area as nonattainment for particulate matter when fires reasonably
attributable to agricultural burning contribute to violations of the
particulate matter NAAQS if the fires were conducted under an approved Tier 2
SMP. If high concentrations of particulate matter arise from fires reasonably
attributed to agricultural burning, the Agricultural Burning Manager will be required
to review the adequacy of the SMP in cooperation with agricultural
owners/producers and make appropriate improvements.
VI. SMOKE MANAGEMENT PROGRAM (SMP)