REDUCING IMPEDIMENTS TO PRESCRIBED BURNING OPPORTUNITIES:
THE IMPORTANCE OF COLLABORATIVE RELATIONSHIPS BETWEEN
LAND MANAGERS AND AIR QUALITY REGULATORS
______
A Thesis
Presented
to the Faculty of
California State University, Chico
______
In Partial Fulfillment
of the Requirements for the Degree
Master of Arts
in
Geography
______
by
Ursula L. Parker
Spring 2018
REDUCING IMPEDIMENTS TO PRESCRIBED BURNING OPPORTUNITIES:
THE IMPORTANCE OF COLLABORATIVE RELATIONSHIPS BETWEEN
LAND MANAGERS AND AIR QUALITY REGULATORS
A Thesis
by
Ursula L. Parker
Spring 2018
APPROVED BY THE DEAN OF GRADUATE STUDIES AND VICE PROVOST FOR RESEARCH:
______Sharon Barrios, Ph.D.
APPROVED BY THE GRADUATE ADVISORY COMMITTEE:
______Don L. Hankins, Ph.D. Don L. Hankins, Ph.D., Chair Graduate Coordinator
______Diane E. Schmidt, Ph.D.
PUBLICATION RIGHTS
No portion of this thesis may be reprinted or reproduced in any manner unacceptable to the usual copyright restrictions without the written permission of the author.
iii ACKNOWLEDGEMENTS
I attribute my love for the natural environment to my grandfather, who worked for the
United States Forest Service (USFS) on the Lolo National Forest in northwestern Montana.
When he married my grandmother, they spent the first six months of their marriage living at a fire lookout in the Lolo in the region of the “Big Burn”. While researching the history of fire suppression, I came across a historical photo of two USFS employees looking over the Lolo
National Forest, and I began to realize why I feel such a strong connection to this issue.
I would like to thank my employer, the Butte County Air Quality Management
District, for providing me with a vocation that I know in my heart I was meant to pursue and
giving me the latitude to conduct this research. I am also grateful to the Butte County Fire Safe
Council (BCFSC), where members’ passion for protecting the public from the devastating
impacts of wildfire helped encourage my interest in prescribed burning. Through our work
together at the BCFSC, I had the good fortune to get to know Don Hankins. Don’s enthusiasm
for prescribed burning is infectious, and early on, he gently encouraged me to take University
classes, which ultimately brought me to this research topic. Don’s passions secured a grant to
bring students to Australia to learn about the effects of bushfire and to experience indigenous
burning techniques. I was fortunate enough to be one of the students who went with Don. It was
a life-changing experience for me personally, and I will always be grateful to Don for the
opportunity that he provided so generously. I appreciate the kindness, openness and generosity
that Don has shown; he is one of the nicest people I know.
I would also like to acknowledge LaDona Knigge; were it not for LaDona’s
compassion, I doubt that I would not have reached this point in my journey. Additionally, I owe
a huge thank you to Diane Schmidt, whose Collaborative Management class was essential to this
iv paper’s conclusions and suggested plans of action. Her willingness to be on my committee and meet with me multiple times to provide guidance and gentle direction was just what I needed at just the right time. I will always be grateful for the many things that I learned from Diane.
Were it not for the exuberance of my friend and colleague, Ann Hobbs, I may never have discovered this research topic. Ann’s passion for the perspective of air quality regulators to be included in discussions about prescribed burning has been the single greatest driving force towards the development of the thesis for this paper, and I admire her tremendously.
I am very appreciative of the interview subjects and participants in this study; without their willingness to take their time to provide their insights and experiences, I would not have been able to further my investigation. I would like to think that merely by my pursuing this topic that I started the discussion about the need for collaboration.
Finally, I would like to thank my friends and family. I am so grateful that Vic and
Leona Fisher have always been so supportive and wrote the letter of recommendation that was the beginning of this journey. My husband, Tom, never stopped supporting my efforts and graciously picked up so many of the duties that I had to forego in the years I spent pursuing this degree. His gentle encouragement and genuine pride in my work was so needed and I am very lucky to have him as my life partner. And lastly, and most importantly, I want to thank my son,
Morrison, for giving me the biggest reason of all to finish what I started.
v TABLE OF CONTENTS
PAGE
Publication Rights…………………………………………………………………… iii
Acknowledgments…………………………………………………………………… iv
List of Tables and Figures…………………………………………………………… viii
Abstract……………………………………………………………………………… xi
CHAPTER
I. Introduction ...... 1
Background ...... 1 Statement of the Problem ...... 2 Purpose of the Study ...... 3 Limitations of the Study...... 4 Definitions...... 5
II. Literature Review...... 6
California and Fire ...... 6 History of Federal Fire Suppression Policy……………………. . 8 History of Federal Fire Management – Wildland Fire Use...... 10 History of Air Quality Policy…………………………………... 13 Population Increase in the Wildland User Interface……...... 16 Wildfire Costs…………………………………...... 17 Constraints on Prescribed Burning: Policy and Funding...... 20 Constraints on Prescribed Burning: Physical/Operational...... 21 Constraints on Prescribed Burning: Perception/Awareness...... 22 Constraints on Prescribed Burning: Air Quality Regulations….... 23 The Value of Collaboration……………………………………… 27
III. Methodology ...... 30
Design of the Investigation ...... 30 Treatment and Population ...... 30 Data Analysis Procedure ...... 33
vi CHAPTER PAGE
IV. Results and Discussion ...... 35
Interview Results ...... 35 Regional Land Manager Survey Results...... 36 National Land Manager Survey Results ...... 48 Regional Air Quality Regulator Survey Results ...... 62 National Air Quality Regulator Survey Results...... 70 Discussion of the Findings ...... 77
V. Summary, Conclusions and Recommendations ...... 86
Summary ...... 86 Conclusions ...... 91 Recommendations ...... 93
References ...... 96
Appendices
A. Survey Instrument ...... 107 B. Interview Consent Forms ...... 108 C. Interview Questions ...... 114 D. Surveys ...... 118
vii LIST OF TABLES AND FIGURES
TABLE PAGE
1. Regional Land Managers Impediments to Prescribed Fire ...... 44
2. Regional Land Managers Suggestions to Reduce Impediments to Prescribed Fire (n=43) ...... 48
3a. National Land Managers Impediments to Prescribed Fire ...... 57
3b. National Land Managers Impediments to Prescribed Fire (continued) ...... 58
4. National Land Managers Suggestions to Reduce Impediments (n=86)...... 61
5. Regional Air Quality Regulators Reasons for Denial of Prescribed Burns . 66
6. Regional Air Quality Regulators Suggestions to Reduce Impediments on Prescribed Burning (n=16) ...... 70
7. National Air Quality Regulators Reasons for Denial of Prescribed Burns .. 72
FIGURE
1. Distribution of Survey Responses from Regional Land Managers (n=33) ...... 37
2a. Regional Land Managers Burn Methods (n=90) ...... 38
2b. Regional Land Managers Burn Methods by Agency (n=90) ...... 39
2c. Regional Land Managers Average Annual Acres Burned (n=31) ...... 40
3. Regional Land Managers Satisfaction Regarding Prescribed Burns (n=30) ...... 40
4. Regional Land Managers Relationships with Air Quality Regulators (n=32) ...... 41
5. How Often Regional Land Managers are Denied a Request to Burn (n=32) ...... 42
viii FIGURE (CONTINUED)
6. Regional Land Managers Distribution of Types of Comments Regarding Burn Denials Reported (n=21) ...... 43
7. Regional Land Managers Collaborative Efforts (n=31) ...... 45
8a. Regional Land Managers Support for Collaborative Engagement (n=31) ...... 46
8b. Regional Land Managers Support for Collaborative Engagement by Agency (n=31) ...... 47
9. Distribution of Survey Responses from National Land Managers (n=68) .. 50
10a. National Land Managers Annual Acres/Burn Methods (n=50) ...... 51
10b. National Land Managers Annual Acres/Burn Methods by Agency - State Agencies and USFS (n=33) ...... 51
10c. National Land Managers Annual Acres/Burn Methods by Agency - State Agencies and USFS (n=17) ...... 52
11. National Land Managers Satisfaction Regarding Prescribed Burns (n=68) ...... 53
12. National Land Managers Relationships with Air Quality Regulators (n=67) ...... 54
13. How Often National Land Managers are Denied a Request to Burn (n=67) ...... 55
14. National Land Managers Distribution of Types of Comments Regarding Burn Denials (n-22) ...... 56
15. National Land Managers Collaborative Efforts (n-66) ...... 59
16a. National Land Managers Support for Collaborative Engagement (n=62) .. 60
16b. National Land Managers Support for Collaborative Engagement by Agency (n=62) ...... 60
17a. Regional Air Quality Regulators Distribution of Types of Agricultural Burns Allocated (n=81) ...... 63
ix FIGURES (CONTINUED)
17b. Regional Air Quality Regulators Average Agricultural Burn Acres Allocated Annually (n=9) ...... 64
18. Regional Air Quality Regulators Number of Prescribed Burns Authorized Annually (n=9) ...... 64
19. How Often Regional Air Quality Regulators Denied Requests for a Prescribed Burn (n=16) ...... 65
20. Regional Air Quality Regulators Reports of Prescribed Burns that Created Negative Impacts (n=34) ...... 67
21. Regional Air Quality Regulators Professional Relationship with Agricultural Burners (n=91) ...... 67
22. Regional Air Quality Regulators Management Support for Prescribed Burning (n=17) ...... 68
23. Level of Collaboration Between Regional Air Quality Regulators and Communities Affected by Prescribed Burns (n=15) ...... 69
24. Regional Air Quality Regulators Opinions About Public Acceptance of Smoke and the Need for More Education (n=15) ...... 69
25. National Air Quality Regulator Distribution of Types of Agricultural Burns Allocated (n=25) ...... 70
26. National Air Quality Regulators Reports of Prescribed Burns that Created Negative Impacts (n=10) ...... 73
27. National Air Quality Regulators Professional Relationship with Agricultural Burners (n=28) ...... 74
28. National Air Quality Regulatory Management Support for Prescribed Burning (n=7) ...... 75
29. Level of Collaboration Between National Air Quality Regulators and Communities Affected by Prescribed Burns (n=7) ...... 76
30. National Air Quality Regulators Opinions About Public Acceptance of Smoke and the Need for More Education (n=7) ...... 77
x
ABSTRACT
REDUCING IMPEDIMENTS TO PRESCRIBED BURNING OPPORTUNITIES:
THE IMPORTANCE OF COLLABORATIVE RELATIONSHIPS BETWEEN
LAND MANAGERS AND AIR QUALITY REGULATORS
by
Ursula L. Parker
Master of Arts in Geography
California State University, Chico
Spring 2018
As more frequent and intense wildfires affect landscapes in the western United States, particularly in California, more and more people are choosing to relocate from cities to communities adjacent to wildlands. It has been estimated that up to ninety-five percent of firefighting costs, amounting to more than three billion dollars in 2014, are from protection of private property in such communities. Prescribed fire is an effective and fiscally responsible means of reducing hazardous fuels in wildlands. Some land managers are frustrated because the number of acres that they are able to treat with prescribed fire continues to fall short of what they believe will reduce wildfire risk and view air pollution law and policy as one of the top constraints to prescribed burning. Air quality regulators, faced with the challenge of balancing protection of public health from smoke while respecting that prescribed burns reduce the risk of future extreme air quality impacts from wildfire, are caught in the middle.
xi This study sought to examine the issues contributing to constraints on prescribed burning through interviews and surveys with land managers and air quality regulators to understand why the impediments exist, with a focus on the geographic region of Northern
California. The study found that while there was diversity among the attitudes and experiences of the participants in that region, the majority of land managers, especially the USFS respondents, believed that they were denied requests to burn by air quality regulators because of a lack of understanding or flexibility. At the same time, air quality regulators largely believed that land managers were not taking advantage of available burn days and most of the regulators were advocating for ways to increase, rather than inhibit, the land managers’ opportunities to burn.
For important prescribed burn projects to be successful, land managers and air quality regulators must work together to build a collaborative culture. The findings of this research suggest that in Northern California, burn denials are the driver of land managers’ dissatisfaction and distrust of air quality regulators. The findings also suggest that there is a need for collaboration to increase the levels of cooperation and understanding. By focusing on shared goals and acting as partners in projects instead of as agencies with competing interests, land managers and air quality regulators can together more effectively increase the pace and scale of beneficial fire management.
xii CHAPTER 1
INTRODUCTION
Background
For over a century, historical and current land uses and fire suppression policies enacted by the federal government have resulted in a buildup of fuels in the forest that has increased the intensity of fire. In addition, due to a warming climate, the fire season has been beginning earlier and has been lasting longer (Westerling et al. 2006; Skinner 2014). Further, wildfires in most of the western United States in the last decade have been the largest and the most destructive fires in their history (Tidwell 2013). Exacerbating the problem, in recent years, an increasing number of Americans are moving from cities to communities which meet or intermingle with the forest (called the Wildland User Interface, or WUI), putting themselves and fire fighters in danger (Toman et al. 2011; Dombeck et al. 2004).
All of these factors have contributed to a progressively increasing cost of fire
suppression, from costing a little over five hundred and forty million dollars in 2000 to more
than three billion dollars in 2014 (Tidwell 2014; Krantz 2015). The diversion of funding to
supplement the suppression budget for agencies such as the United States Forest Service (USFS)
directly reduces the budget for other programs, often those that involve activities designed to
improve forest health and reduce the potential for future wildland fire, including prescribed
burning operations (USFS 2015). Without funding for prescribed fire treatments, fuels continue
to build up, creating a never-ending scenario of intense wildfire, fire suppression at great cost,
and lack of funding to proactively address the problem.
1 Prescribed burning operations are constrained by many factors in addition to budgets.
The most challenging constraint to land managers is the limited time in which prescribed burns can safely and effectively be conducted, called “burn windows” (Quinn-Davidson and Varner
2012). Land managers in Northern California ranked air quality regulations as the second highest constraint, while it was ranked as the lowest constraint in a national survey conducted in this study.
Air quality regulators, who desire to support prescribed burning with a view towards a
long term gain of a reduction in large scale and long term smoke impacts from wildfire incidents,
face concerns over public outcry from the short term smoke impacts in those communities most
affected by the smoke, ironically, the same communities that directly benefit from prescribed
burn projects (Procter 2014; J. Kennedy 2014; A. Hobbs 2015).
Statement of the Problem
One of the most cost-effective and efficient means of reducing hazardous fuels is
through the planned application of fire, known as prescribed burning. Although there are many
factors affecting the quantity and quality of prescribed burning that is able to be completed each
year, air quality regulators are identified as one of the top impediments to land managers’ efforts
to reduce fuels through prescribed burning out of a concern about smoke from fires (Ribe and
Inalsbee 2011). In a recent survey conducted in Northern California, land managers identified
air quality regulations as the second highest impediment to prescribed burning (Quinn-Davidson
and Varner 2012). Air quality regulatory agencies, responsible for protecting the public from air
pollution, provide the final “go” or “no go” decision for a prescribed burn, and must consider the
affect of smoke on downwind sensitive populations. While many air quality regulators
2 understand the need for prescribed burning as a means of reducing fuels and decreasing the potential for a great deal of smoke from a wildfire later, the potential for air quality issues or concerns about impacts to the public can negatively affect a “go” decision. There is great potential for animosity between land managers planning a prescribed burn and the air quality regulators to whom they rely upon for approval for the burn.
Misunderstandings between land managers and air quality regulators can create
distrust and can inhibit the ability of the two groups to work together to provide a consistent
message to the public. For important prescribed burn projects to be successful, land managers
and air quality regulators must work together to build a collaborative culture. By focusing on
shared goals and acting as partners in projects instead of as agencies with competing interests,
land managers and air quality regulators can together more effectively increase the pace and
scale of beneficial fire management.
Purpose of the Study
This study uses information available from previous studies to establish a greater
understanding of the complexity of the issue to outline potential solutions. The study examines
literature on the historical use of fire and fire suppression policy, studies on constraints to
prescribed burning, and studies on public perceptions and tolerance of prescribed burning and
smoke. The relationship between land managers and air quality regulators, specifically as it
relates to collaboration in an effort to promote prescribed burning, is the main focus of this study.
Interviews and surveys of air quality regulators and land managers were performed to gain
greater insight into missed opportunities for collaborative relationships between the groups and
3 where there might be opportunities for the establishment of a community of practice. Northern
California was chosen as the area in which the study concentrated, but because of broader interest generated by the study, surveys were also distributed to a variety of air quality regulators and land managers throughout the US. The analysis of this data provides greater insight into the broader perceptions of organizations to help develop a greater understanding of the issues so constraints on prescribed burning might be lessened through the building of a collaborative culture.
Limitations of the Study
This study is limited to perceptions of those individuals who were interviewed or included in the survey. Although care was taken to avoid biasing the results of the study by interviewing similar-minded individuals, because of the nature of how contacts are made (e.g., networking with like-minded colleagues at conventions), there may have been some unintended bias in the selection of the interviewees. Survey recipients for the study included a representative mix of private and government land managers and air quality professionals in
Northern California (“Regionally”) who participate in different collaborative groups and who actively conduct prescribed burning. Some groups, such as tribal entities and private landowners, were unintentionally not well represented in this study. The study is considered a
“snowball survey,” and recruitment for the respondents to the survey gained momentum, such that interest was generated amongst some survey respondent’s colleagues nationally. This interest was not expected or solicited; aside from the bias inherent in a snowball survey, there was no bias by the researcher.
4 Definition of Terms
• APCD or AQMD– Air Pollution Control/Air Quality Management District
• ARB – Air Resources Board (or California Air Resources Board)
• BLM – Bureau of Land Management
• Cal Fire – Formerly California Department of Forestry and Fire Protection (CDF)
• EPA – Environmental Protection Agency
• NGO – Non-governmental Organizations
• NPS – National Park Service
• PM – Particulate matter
• PM 2.5 – Particulate matter 2.5 microns in size or smaller (also referred to as “fine
PM”)
• PM 10 – Particulate matter 10 microns in size or smaller (also referred to as “coarse
PM”)
• US – United States
• USDA – United States Department of Agriculture
• USFWS – United States Fish and Wildlife Service
• USFS – United States Forest Service
5
CHAPTER II
LITERATURE REVIEW
California and Fire
Fire is an important part of the ecological cycle in California’s wildlands, so much so that the vegetation is considered fire-adapted and in some cases, fire dependent. California’s
Mediterranean climate, characterized by cool, wet winters followed by warm, dry summers, provide perfect conditions for wildfire (McElvey et al. 1996). Native Americans in California depended on fire for protection of their villages, for hunting game animals, for protection from snakes, for managing cultural artifacts and basketry materials, for improving visibility, for signaling and warfare, and for cultivation of desired vegetation for food and cultural purposes
(Anderson 2006, 417-421; Lewis 1973, 79).
Studies have determined that throughout prehistory much of California burned every year. As much as four and one half million acres of land in California were burned annually by both natural ignition (lightning) and by intentional ignition by Native Americans prior to the arrival of European explorers (Anderson 2006, 417; Collins and Stephens 2007; Stephens et al.
2007). During this period fire return intervals were frequent with fires being smaller and less intense because the land burned regularly (McElvey et al. 1996; Collins and Stephens 2007;
Stephens et al. 2007). Fires maintained the smaller trees and shrubs, preventing them from becoming ladder fuels and allowed for the structure of the forest to become fire resilient
6 (McElvey et al. 1996). The fuels did not have the chance to accumulate and mortality of large trees was minimized.
The history of fire suppression policies in America can be traced back to the early settlers who arrived without a culture of burning to tend the landscape; their homeland had long ago been cleared by their ancestors for grazing and crop tending (Arno 2014). European settlers changed fire regimes in California from the time of their arrival by first excluding fire, and then later, by suppressing fire (Stephens and Sugihara 2006, 431-432; Ryan et al. 2013). Fire exclusion, which allowed for the accumulation of fuels and the overcrowding of forests with smaller trees and shrubs began with the arrival of European explorers who first arrived in
California in the mid to late 1700s (Kelsey 1986; Stephens and Sugihara 2006, 431). In the late
1700s, missionaries began the practice of cattle ranching and horticulture activities and implemented the first fire suppression policies (Stephens and Sugihara 2006, 432). During the
Gold Rush in the 1850s, logging supported the rapid population growth as fuel for heating, fuel for powering steam engines and industrial production, as well as the timber needed to construct railroads to bring ever more people to California (Stephens and Sugihara 2006, 433; Ryan et al.
2013).
Some early settlers found value in indigenous fire techniques, using fire for hunting
and pasturage, but as the population moved into what were once rural wildlands, suppression
became more common (Pyne 1981). As more people moved to the North American west, the
tradition of burning decreased, and stands of timber became a commodity to protect. Following
large fires in the late 1800s and early 1900s which burned nearly ten million acres and killed
approximately 2,500 people, federal fire policy was established (Stephens and Sugihara 2006,
433).
7 Smoke, like fire, has evolved from being a regular and a natural part of the
environment in California, to a seemingly unnatural occurrence. Fire suppression merely delays
fuels from burning, often more intensely, at a later time and causes a “fire deficit” which in turn
creates a landscape that is prone to larger and more severe fires every year as well as a “smoke
deficit” (Kaufmann 2004; Ribe and Ingalsbee 2011). Smoke from fires has been estimated to
have decreased seven fold compared to pre-settlement era (pre-1800) when skies were
consistently more smoky and hazy (Ribe and Ingalsbee 2011). Often, a prescribed burn creates
heightened concern amongst residents who have become accustomed to blue skies without
smoke except during wildfire events. When the smoke from the prescribed burn become visible,
many residents have concerns that seeing the smoke means either their property is under threat or
that their health is being harmed. Smoke from presettlement fires has been estimated to have
resulted in annual emissions of approximately 1.5 million tons of coarse particulate matter
(PM 10 ) (Stephens et al. 2007, 211). This evidence supports the reports of low-intensity burning; high intensity forest fires contribute to emissions measuring approximately 1.2 million tons of
PM 10 per day (ARB 2013). In fact, a single wildfire can release hundreds of times the pollution
released by a refinery in an entire year (PRI 2003).
History of Federal Fire Suppression Policy
The development of the government agency that would eventually become the USFS came about over time. The federal policy of suppressing fires on public lands was initiated when the US Army was given the responsibility for managing Yellowstone, America’s first national park, in 1886 (Stephens and Ruth 2005; Stephens and Sugihara 2006, 433; Agee 1974; van
Wagtendonk 2007; Ryan et al. 2013; Pyne, 1981). The Army, originally ordered to the park to
8 protect it from squatters and other undesirable residents, ended up fighting a forest fire that was purposely set by rebellious locals (Yellowstone Insider 2018). In 1891, the Army was tasked with managing Yosemite and Sequoia as well, including suppressing fires (Stephens and
Sugihara 2006). In 1898, a national forest fire policy for the newly created “National Forests” was initiated by the agency’s Chief, Gifford Pinchot (Stephens and Ruth 2005). The Transfer Act of 1905, the first independent forestry bill to become law, transferred sixty three million acres to be overseen by the USFS (Stephens and Sugihara 2006, 433; Ryan el al. 2013; Haines and Sando
1969; Pyne 1981).
A large fire in northwestern US in 1910 convinced the USFS to create the first federal wildland fire protection policy. The fire, called, “The Great Idaho fire,” also called, “The Big
Blowup,” burned over three million acres of private and federal land (including as estimated seven and one half billion board feet of timber), killed 78 firefighters, and destroyed several towns. (Pyne 1981; Stephens and Sugihara 2006, 433). The USFS, eager to salvage its reputation and save itself from bankruptcy if Congress decided to not continue to fund the agency, was put on the defensive (Pyne 1981). Little did USFS administrators or the public know that “The Big Blowup” would go on to become “the creation myth” on which to justify nearly a century of national fire exclusion policy (Pyne 2010).
Fire control efforts became more sophisticated as technology became available for
use as a fire-fighting tool. The USFS started using aircraft in California for fire detection in
1917, and in the 1920s attempted to drop water and foam on fires in five-gallon tin cans, paper
bags, and in eight-gallon oak beer kegs attached to a parachute (USFS 2008). The
mechanization of fire control, complete with parachuting smoke jumpers, became possible
following World War II due to a surplus of military equipment and personnel trained for their
9 missions (Pyne 1981). In addition, lookout towers, originally constructed to spot enemy planes during the war, were put into use as fire lookouts (Buck Rock Foundation 2015).
Public support of fire exclusion and suppression efforts was encouraged through the
use of a public education campaign that capitalized on the public’s emotions of the time. In
1930, USFS posters proclaimed, “Your children will need timber. Grow trees, save them from
fire,” which evolved during the middle of World War II in 1943 to a message ordering the
public, “Don’t blind our pilots with smoke,” with an image of Hitler in an inset at the bottom
along with a message, “Our carelessness – their secret weapon – Prevent Forest Fires” (USFS
2015). Another early poster from this propaganda era proclaims, “Death Rides the Forest when
Man is Careless,” with an image of the grim reaper atop a horse riding out of a burning forest
that he has ignited (Kaufmann 2004). In 1942, Walt Disney Company’s motion picture,
“Bambi” was released to the public, featuring scenes of animals fleeing a forest fire, increasing
public awareness and fear of forest fires. The Walt Disney Company let the USFS use Bambi’s
image on a poster in 1944 as part of the USFS’s suppression/forest fire prevention campaign.
The new posters were hugely successful; however, because the rights to Bambi belonged to the
company, USFS had to choose a new mascot. Smokey Bear, and the longest-running public-
service campaign in the U.S., was born (Timiraos 2007). To date, Smokey Bear is recognized as
among the most powerful and enduring icons of public service advertising (Earle 2000; Ballard
et al. 2012).
History of Federal Fire Management – Wildland Fire Use
Although prescribed fire was common on private lands to increase forage for
livestock on rangeland, its use as a tool to manage wildlands by government agencies wasn’t
10 accepted until the 1960s. Aldo Leopold, considered by many to be the father of wildlife ecology and the United States' wilderness system, recognized prescribed fire as essential to the management of wildlife habitat; Leopold (1933, pg vii) stated, “the five critical tools of game management are the ax, the match, the cow, the plow, and the gun.” At the request of the U.S.
Secretary of Interior, Leopold produced a study in 1963 on ecosystem management, including the impact of fire suppression on wildlife habitats. The study, called the "Leopold report", highlighted the adverse affect that fire suppression policies had on wildlife habitats (Leopold et al. 1963; Stephens and Ruth 2005).
Wildland fire use policies were expanded after the acceptance of the “Leopold report”. The National Wilderness System was created in 1964, and new policies were developed which promoted wildland fire use in remote forested areas (Pyne 1981; Stephens and Ruth
2005). In the late 1960s, the National Park Service officially recognized fire as a natural process and allowed lightning fires in some areas to burn under prescribed conditions (Van Wagtendonk
2007). The USFS followed suit in 1974 and changed its policy from fire control to fire management, allowing lightning fires to burn in wilderness areas, giving the program various names including, “Let Burn,” “Prescribed Natural Fire,” and more recently, “Wildland Fire
Use,” followed by appropriate managed response (Van Wagtendonk 2007).
The public’s support of wildland fire use was tested in 1988 when a naturally-ignited fire consumed over a million acres of Yellowstone National Park. The fire was a stark reminder of the unpredictability and occasional futility of fire-control policies, and federal managers were forced to evaluate policies and their relative effectiveness in an effort to improve them
(Dombeck et al. 2004). A federal Wildland Fire Policy was developed in 1995 to reduce the threat of catastrophic wildland fire through proactive goals and actions (Hesseln and Rideout
11 1999). The Fish and Wildlife Service, Bureau of Land Management, and Bureau of Indian
Affairs began implementing similar fire use programs in the late 1990s and early 2000s to provide for firefighter and public safety while contributing to ecosystem sustainability (Van
Wagtendonk 2007).
The recognition of fire as a natural process became a part of written policy in 2001
when the Wildland Fire Policy was revised in 2001. The revision was deemed necessary due to
the complexity of fire in the WUI and included policies that required additional coordination
between federal, state, local and tribal land and fire managers (NIFC 2009). In 2000, The
National Fire Plan , and the Ten-Year Comprehensive Strategy set forth a long-term,
multibillion-dollar effort with an increase of funding from one hundred eight million to four
hundred one million dollars in its first fiscal year (GAO 2003; Stephens and Ruth 2005).
Seventy percent of the funding from the National Fire Plan had been directed to fire
suppression, not fuels management (Stephens and Ruth 2005).
The perception that fuels management projects were slowed or halted by appeals processes and lengthy judicial review timelines prompted the promulgation of the Healthy
Forests Initiative (HFI), in 2002 (Stephens and Ruth 2005). Much of the same policies proposed by the HFI were enacted as the Healthy Forests Restoration Act in 2003 (HFRA 2003), but other new policies, such as requiring that at least fifty percent of the dollars allocated to HFRA projects be used to protect communities at risk of wildland fire, were also included (Stephens and
Ruth 2005). The HFRA requires the streamlining of the regulatory processes to increase the efficiency of forest restoration through selective thinning and prescribed burning (Stephens and
Ruth 2005). Selective thinning combined with prescribed surface fuel burning has been proven to be an effective method for preventing crown fire and minimizing fire severity and therefore
12 can be effective at reducing the potential for severe fire spreading into WUI areas (Symons et al.
2008). Even with the support of legislature, progress towards reducing fire hazards as set forth in the HFRA was hampered by multiple constraints. The HFRA has been criticized for being politically motivated and focuses on the simple reduction of fuels, rather than reducing potential fire behavior effects (Stephens and Ruth, 2005).
In 2009, Congress passed the Federal Land Assistance, Management, and
Enhancement (FLAME) Act, calling on federal land managers to develop a joint wildland fire
management strategy (Tidwell 2013). The efforts by participants resulted in the National
Cohesive Wildland Fire Management Strategy (National Strategy, also referred to as Cohesive
Strategy ), which was developed in 2009-2010 through a “three-phased approach to planning, risk
analysis, and collaboration by federal, state, local and tribal governments and non-governmental
partners and public stakeholders” (Forests and Rangelands 2014). The National Strategy defined what wildland fire management meant to parties involved, defined the goals and challenges relating to wildfire, including how to appropriately respond to wildfire and when to manage ignitions, where risk could be averted, particularly in the protection of communities in the WUI, and set priorities toward achieving the goals established (Forests and Rangelands 2014). The most current revision to the National Strategy was published in 2012, and is referred to as “a bold new national approach to the increasingly complex reality of wildland fire and land management, and fire response” (WGA 2018).
History of Air Quality Policy
Due to concerns regarding public health, air quality regulatory agencies have been
monitoring pollution since the late 1960s in California. The federal EPA was established
13 following amendments to the Clean Air Act (CAA) in 1970. The amendments also required the establishment of National Ambient Air Quality Standards (NAAQS) adopted to protect public health and welfare by determining limits of acceptable pollution (EPA 1998). Emissions from all types of sources contribute to chronic air pollution problems, especially in California, where the sheer number of people (over 37 million), geography and climate negatively affect the creation and dispersion of pollutants (EPA 1998; ARB 2014; U.S. Census Bureau 2014). In
California, the ARB requires local air quality regulators to oversee the attainment of NAAQS in their respective regions.
Air pollution can be transported long distances and settle in areas where it was not
originated. Concern regarding visibility at national parks, such as the Grand Canyon, became
heightened after the adoption of the CAA (Green and Gebhart 1997). Amendments to the CAA that were adopted in 1990 addressed these concerns by mandating the establishment of the Grand
Canyon Visibility Transport Commission (GCVTC) under the Regional Haze Rule (RHR) to perform visibility assessments to study the interstate transport of air pollutants into the Grand
Canyon (Kennedy 2014; NPS 2016). The RHR requires states to develop and implement visibility protection plans (smoke management plans) to reduce anthropogenic (man-made) air pollution that causes visibility impairment through coordination with federal land managers and other interested parties. (Kennedy 2014; NPS 2016; FEJF 2005).
The success of the GCVTC in improving air quality conditions led to the formation of a partnership that still remains active today. The Western Regional Air Partnership (WRAP) is a collaboration between federal land managers, states and tribal entites, established in 1997 to focus on air quality improvement in the West (WRAP 2015). One of the early duties of the
WRAP was to develop smoke management plans to fulfill RHR legal requirements (FEJF 2005).
14 The WRAP approved a policy document in 2001 that determined the “natural” and
“anthropogenic” sources of fire emissions that contribute to regional haze, with emissions from wildfire and Native American cultural fire considered as “natural” sources, and emissions from agricultural fire as “anthropogenic” to properly categorize emissions for inventory purposes
(FEJF 2005).
Other partnerships at the same time were also taking shape in an effort to increase the pace and scale of prescribed burning. In the middle 1990s, federal land manager directors
(USFS, BLM, NPS) developed fire policies which highlighted the need to increase prescribed burning in the US in response to the deteriorating health of the country’s forests (Kennedy 2014).
California air quality regulatory agencies responded to the concern about increased emissions from prescribed burning by establishing a collaborative relationship between agency staff and federal land managers called the Interagency Air and Smoke Council (IASC) (Kennedy 2014).
The IASC has been effective in bringing these communities of practice together to increase the pace and scale of prescribed burning while reducing the potential for smoke impacts.
Both land managers and air quality regulatory agencies have worked together to develop strategic plans for prescribed burns that focus on minimizing smoke impacts to the public
(Kennedy 2014). A daily conference call (called the “1300 call,” as it is at 13:00 each day) was also initiated to assist in decision making as part of the smoke management plan “prescription” and is attended daily by ARB meteorology staff to provide information on dispersion of pollutants and patterns of weather affecting smoke movement (Procter 2014). The IASC has been successful in bringing together stakeholders to act together to have input on important policy prior to its development and enactment. Prior to establishing policies still in place regarding the requirements of prescribed burning, the ARB used the IASC group to review rules
15 regarding prescribed burning, called “Title 17” (Kennedy 2014). This formal policy regarding agricultural burning, replaced the the “interim policy,” adopted by EPA in 1988 (Procter 2014).
One of the things that IASC revised was the policy, “Title 17,” to include details regarding prescribed burning and added the term, “fire use” in 2001 (Kennedy 2014; Procter 2014).
Following the continued increase of wildfires and concerns about smoke impacts, the California
Air Response Planning Alliance (CARPA) group formed as an effort to provide assistance with wildfire and smoke messaging coordination amongst public health officials and provide emergency response training and aid with deployment of air quality monitors during wildfire events (Procter 2014).
Population Increase in the Wildland-User Interface
California wildfires, which have been more extreme in recent years, endanger not only the lives and properties of individuals in the fire’s path (including fire fighting agencies), but also those downwind from the fire. The challenge to those land managers looking to reduce the fire behavior of fuels in forests is compounded by the continual expansion of the population living in the wildland urban interface (WUI) (Tidwell 2013; Long et al. 2017). Since 1990, the
U.S. has experienced an unprecedented conversion-growth rate of 3 acres per minute, 4000 acres per day and close to 2 million acres per year of conversion (IAWF 2013). One estimate suggests that 12.5 million U.S. homes were within the WUI in 2000, a 52 percent increase over 1970
(Theobald and Romme 2007). According to studies cited in the 2013 USFS General Technical
Report (RMRS-GTR-299), more than one-third of all housing units in the continental U.S. are located within the WUI, and the trends suggest that these numbers will continue to grow
(Tidwell 2013).
16 The continued expansion of development into the WUI is particularly alarming because wildfires threaten people and their property at a greater rate in those areas than in areas with less inherent risk. With an increase in home construction in the WUI, federal agencies are focusing more of their firefighting efforts on protecting human lives and property (Dombeck et al. 2004). There is a growing concern that local governments and their constituents are not doing enough to protect communities at risk by limiting construction of homes in the WUI and enacting building requirements which can reduce the flammability of structures (Dombeck et al.
2004).
While the increase in population in the WUI puts increasing pressure on land managers to mitigate fire risk at a much greater cost to these agencies, it also increases the need for public outreach to effectively communicate with the public and build support for a prescribed fire program (McDaniel 2014). While it is easy to assume that newcomers to the WUI are less tolerant to smoke or have less knowledge about fire, studies show that newcomers are often more open to fire education and information than long term residents (McDaniel 2014). The general public has a much better understanding than ever before about the ecological role of fire and the risks of living in the WUI, however, a critical factor is trust in the competence of the responsible agency (McDaniel 2014).
Wildfire costs
The cost to fight wildfire to protect infrastructure, life and property is staggering.
Over the last ten years in the US, on average over $1.5 billion annually has been spent suppressing fire (reported acres average 6,848,092 per year) (National Interagency Fire Center
2015). In many cases, suppression cost figures capture only the immediate costs for wildfire
17 suppression (Dale 2009). The economic loss to a community affected by wildfire, typically in a forested area frequented by summer vacationers, can be huge. For example, it has been estimated that the areas surrounding Yosemite lost $3.25 million in tourist spending during the
2013 Rim fire and subsequent Yosemite closure (Hecht 2013). Erosion and flooding following a wildfire can negatively affect watersheds which provide valuable water supplies to communities often far away (Dale 2009; Buckley et al. 2014).
A full accounting considers near and long-term costs, including healthcare costs from air quality impacts, injuries and fatalities, impacts to watersheds and ecosystems (from both fire and post-fire flooding and erosion), impacts to infrastructure (highways, airports, and railroads), and the cumulative affect on the local and national economies, including rising insurance rates
(Dale 2009). Restoration costs can also mount; the Sierra Nevada Conservancy recently earmarked $1 million toward Rim Fire restoration, which is fraction of the tens of millions that are likely to be spent on restoration in the years to come, whether in salvage logging or tree planting (Howard 2014).
One cost that is difficult to quantify is the cost of health impacts from wildfire smoke.
Each year, wildfires emit huge quantities of fine PM (less than 2.5 microns in diameter, referred to as “PM 2.5 ”), carbon dioxide, precursors of ozone (the most widespread and persistent urban
pollution problem, according to the EPA (2015)), and other harmful pollutants into the
atmosphere (Wildfire Guide 2008; Engel 2013). PM 2.5 , in particular, is extremely harmful to
health because the finer particles can be inhaled deep into the lungs and can enter the
bloodstream. Sensitive populations, such as the young, old, and those with weak respiratory or
immune systems are particularly at risk due to declines in air quality during a wildfire (Dale
2009). The chemicals in wildfire smoke are similar to pollution generated by industrial sources
18 of air pollution (factories, cars, etc.) currently regulated by air quality laws (Engel 2013; ARB
2014). Fine particles are respiratory irritants, and exposures to high concentrations can cause persistent cough, phlegm, wheezing, and difficulty breathing (EPA et al. 2016). Short term exposures to fine particles can also affect healthy people, causing respiratory symptoms, transient reductions in lung function, and pulmonary inflammation, with the more serious effects of exposure to smoke include reduced lung function, bronchitis, exacerbation of asthma and heart failure, and premature death due to the aggravation of pre-existing respiratory and cardiovascular disease (EPA et al. 2016). It is estimated that 9,000 people in California die prematurely each year as a result of exposure to PM2.5 (ARB 2014).
Air quality impacts from wildfire can be extreme, especially in localized areas
downwind from the fire. In 2002, a large high intensity fire, the McNally Fire in the Sequoia
National Forest in California, burned over 150,000 acres. Air quality levels measured during the
fire violated federal PM 10 standards four times and California PM 10 standards 164 times
(Cisneros et al. 2012). Smoke from the fire was transported hundreds of kilometers, even crossing state lines, affecting air quality regionally (Cisneros et al. 2012). Scientists measuring air quality data during the Rim wildfire, which burned 257,000 acres in the Stanislaus National
Forest and Yosemite National Park in 2013, reported daily emissions during the active fire period measured in the thousands of tons of PM 10 with peaks of greater than 12,000 tons (Tarnay
2014). To provide some perspective, per the California ARB, the average price paid per transaction per ton of PM 10 offsets was $28,710 (ARB 2012). The Rim Fire released the equivalent of the annual greenhouse gas emissions from 2.3 million cars.
Wildfires can increase levels of ozone pollution by releasing nitrogen oxides and
hydrocarbons into the atmosphere, which can form ozone further downwind as a result of
19 chemical reactions in sunlight. Wildfires and wildfires managed for resource benefit also generally occur during the summer months when the formation of ozone pollution is already at its peak and stagnant air traps smoke close to the ground, preventing it from dispersing into the atmosphere (Engel 2013). One of the benefits of prescribed burning is the potential for ozone emissions savings; prescribed burns are typically conducted in the fall and spring months when ozone formation potential is low.
There is no way to protect the public from the health effects of wildfire smoke beyond general safety measures, and certainly no way to regulate the emissions from a wildfire.
It has been estimated that medical costs due to exposure to wildfire smoke can range from $8.00 per day to as high as $80.00 per day per person for wildfires with longer impacts (Lahm 2014).
Although the economic costs associated with the adverse health effects of wildfire-smoke exposure can be an important consideration in wildfire management, there are surprising few research studies examining the issue (Kochi et al. 2010). Moeltner et al. (2013) determined that wildfire smoke can cause considerable health costs, in the magnitude of several million dollars per fire season for the Reno/Sparks, Nevada area alone.
Constraints on Prescribed Burning: Policy and Funding
Agencies and the scientific community have made progress in recognizing that infrastructure and strong institutional dogma of fire suppression has created the very problem of increased severity of wildfires. The legacy of treating fire as a dangerous and destructive force has made agencies slow to translate improved scientific understanding into on-the-ground management changes (Dombeck et al. 2004). As a result, half the year is spent in widespread talk about the need to reintroduce fire into fire-adapted and fire-resilient ecosystems, but the
20 other half of the year is spent suppressing all wildfire at substantial economic cost (Dombeck et al. 2004). Although there is an understanding that “restoring fire-adapted ecosystems with a focus on treatments” requires the use of prescribed fire (planned ignition) and “responding appropriately to wildfire” means wildland fire use (unplanned ignition), Thomas Tidwell, the
USFS Chief, admits that his agency still suppresses over 90 percent of all wildfire ignitions
(Engel 2013).
Tidwell is concerned about the effect that the budgetary constraints due to fire suppression efforts is having on the level of staffing within the agency. Tidwell expressed these concerns to the US Senate in 2013 (Tidwell 2013). Suppression of fires has been so costly that financial transfers within the agency have been necessary (totaling $2.7 billion), pulling funding from other USFS programs, impacting the ability to “conduct stewardship work on national forests” and also affecting related programs and agencies reliant upon those programs (Tidwell
2013).
The USFS’s goal of restoring fire to the landscape is one that faces obstacles.
Scientists and academics often debate and study the intensity of fire to return the ecosystem a
“normal” state and how the fire affects tree mortality and other physical conditions in the
landscape (Menning 2007). The reality of on-the-ground prescribed burning is not how effective
the treatment will be; it is, instead whether physical (operational), societal, and institutional
roadblocks will allow a fuels treatment project to get off (or in this case, on) the ground (Cleaves
et al. 2000; Menning 2007).
21 Constraints on Prescribed Burning: Physical/Operational
Physical and operational constraints on prescribed burning, which are limitations in the field that restrict the amount of burning that can be done, are the most common constraints on prescribed fire. Climate and weather, which affect the “burn window” is the most challenging such constraint in California, particularly in the northern region (Quinn-Davidson and Varner
2012). California’s mild winters and long, hot summers can limit the time (“window”) in which it is safe to burn – somewhere between the time when fuels are no longer too dry (escape and extreme fire behavior) nor too wet (failure in achieving goals) (Menning 2007; Quinn-Davidson and Varner 2012). It is not uncommon to have approval for a burn, only to have the burn called off due to change in weather conditions.
One of the ways that the levels of staffing have been affected by budgetary constraints from suppression costs is a reduction in staffing who are trained to conduct prescribed burns. Budgets for agencies such as the USFS are stretched thin by suppression costs that have become so great, the agencies are required to transfer funds from programs, such as prescribed burning, to cover the costs (Tidwell 2013). Budget constraints often limit staffing during times of the year when wildfire is not a concern locally, but leaves few field personnel to conduct a prescribed burn when the burn window is favorable. Resources can also be depleted when staff are reassigned to fight wildfires burning in other parts of the US.
Constraints on Prescribed Burning: Perceptions/Awareness
It is important to include the public as a stakeholder when making decisions about a burn project. Land managers may put considerable effort into understanding the physical potential of an action and economic efficiency, but may not consider their project’s social
22 acceptability, which can negatively affect the project’s success (Shindler et al. 2002; Menning
2007; McDaniel 2014). The hurdle to gaining public support for the reintroduction of historic fire regimes at a landscape scale is a social constraint (Dombeck et al. 2004, Yoder et al. 2003;
Menning 2007). These may take a variety of forms such as concern over perceived risks, intolerance of physical conditions (smoke or aesthetics), limited agency budgets, agency resource allocations and priorities that emphasize other goals, and a lack of broad social acceptance (Menning 2007).
The public has an interest in the outcome of a prescribed burn and often have incentives that may not be readily apparent to land managers who do not collaborate in the community. For example, when incentives, such as reduced rates for property insurance, are provided to homeowners who support or practice prescribed burning, it can server to further enhance collaborative relationships (Vogt et al. 2004).
Informing the public about a prescribed burn and planning the burn so as to not interfere with large public events is important. Case in point: in September of 2009, smoke from a 800-acre prescribed burn conducted by the USFS in Central Washington resulted in unhealthy levels of pollution for five hours during the Central Washington State Fair (Brunner and Bernton
2015). Complaints to the agency overseeing the air quality concerns (Department of Natural
Resources) poured in, including some who were “highly politically connected” (Brunner and
Bernton 2015). Although the burn might have been considered a “failure” by some, during a wildfire in the same area three years later, it became a fire break to firefighting crews (Brunner and Bernton 2015).
Progress toward gaining public acceptance of prescribed burning is essential to the success of a burning project that might be met with public objections. Earning the public’s “buy-
23 in” by being honest and open, by inviting the public’s participation and input through meetings and field trips, and by being considerate of local needs and attitudes while also being “forthright about the difficulty in defining desired condition goals” are some are effective ways to change attitudes and build trust (Menning 2007; McDaniel 2014).
Constraints on Prescribed Burning: Air Quality Regulations
Although many studies show that land managers believe that air quality regulatory agencies constrain burning opportunities, emissions data supports that prescribed burning presents a quantifiable reduction in emissions when compared with wildfire emissions. Some research has concluded that air quality regulatory agencies are concerned that their agency will exceed of air quality standards and will deny a prescribed burn request if there is concern about emissions (Cleaves et al. 2000; Ribe and Ingalsbee 2007; Engel 2013). An assessment of the
2012 annual emissions data for all prescribed burning in California, including that from wildland fire use, shows a total average of nearly 50.5 tons of PM 2.5 emissions per day. When compared with residential wood combustion (fireplaces and woodstoves) during the same period, the totals were nearly identical. Wildfires, for comparison, emitted over 391 tons of PM 2.5 per day on average. Given the inevitability of wildfire and predictions that it will increase in severity in the years to come, air quality regulatory agencies should support prescribed burning to reduce the risk of high intensity wildfire.
Limited resources at the air quality management agency level can negatively influence the amount of support that staff are able to give to the prescribed burning program.
Each of the thirty five air quality regulatory agencies (districts) within California operate under their own budget. Additionally, some air quality regulatory agency’s fee structure for their burn
24 programs does not support cost recovery, and therefore, decisions regarding allowing a prescribed burn on a marginal burn day may default to a “no” decision because of the time and resources involved (Broughton 2015). With education, however, air quality regulatory staff can be made aware of the benefits of allowing prescribed burning, as the vegetation management is similar to other agricultural operations; the debris must be dealt with in a responsible manner
(Hobbs 2015).
Although federal rules allow for air quality regulatory agencies to request an exemption from regulatory standards on pollution emitted during a wildfire event, the process for doing so cumbersome and challenging, especially for agencies with limited resources. Some studies have suggested that one of the ways that air quality regulatory agencies and land managers can work together to allow prescribed burning or wildland fire use is to utilize the
“Exceptional Events” (EE) Rule (Ribe and Ingalsbee 2007; Engel 2013). Some have argued that there is a need to change the current federal policy which does not allow for exceedances of air quality standards from a prescribed burn. Regulators argue that the EE process is not streamlined or efficient, and it is very labor intensive to put together a petition for an EE; restricting the amount of smoke being emitted in the first place is far easier than justifying the emissions after the fact (M. Broughton 2015; A. Hobbs 2015).
As confusing as it is for air quality regulatory agencies to put together a petition for
an EE, it may be even more difficult for the EPA to evaluate them. Following the 2008 fires in
California, when over one million acres burned in over 4,000 wildfires, a total of 435 “packages”
of EE submissions came into the regional EPA office to be evaluated (Kennedy 2014). There
has historically been no standard procedure for the EE submissions, and regulatory agencies used
25 different tools to analyze emissions data, which made the challenge of evaluating them even more difficult (Kennedy 2014).
Air quality regulators are challenged by concerns about impacts to the public as a result of “nuisance” smoke from prescribed burns, and can be frustrated when health impacts from smoke are not perceived as a concern by land managers. Air quality regulatory agencies and land managers are at odds regarding the definition of “nuisance” (Engel 2013; Ribe and
Ingalsbee). Air quality regulators are primarily focused on the nuisance as it relates to impacts to public health and visibility impairment (regional haze), while land managers are concerned about risk to public safety from reduced visibility (EPA 1998; Ribe and Ingalsbee 2007). Special consideration, however, is given to emissions from “natural” sources as defined in the WRAP
(FEJF 2005). Smoke management plans prepared by land managers are intended to not only provide emission estimates and conditions for ignition, but are also intended to mitigate the health impacts and nuisance and public safety hazards posed by smoke intrusions into populated areas (EPA 1998). Prescribed fires are provided authorization to proceed when there is a lesser chance that the population of the community will be impacted. The opportunity for public acceptance and tolerance of smoke must come from the relationships between stakeholders and the land managers who are doing the burning, as confirmed by researchers with the Joint Fire
Science Program (McDaniel 2014).
Land managers in northern California seem to be at odds with air quality regulatory
agencies and rank air quality regulations as a top impediment. Quinn-Davidson and Varner
(2012) surveyed 59 northern California land managers and ranked twelve impediments to
prescribed burning. They found air quality regulations to be the second greatest impediment
following narrow burn windows as the top impediment to prescribed burning. The impediments
26 were as follows, in order of their ranking: narrow burn window, air quality regulations, lack of adequate personnel, environmental laws, residential area near burn, lack of adequate funding, liability, fuel loading, planning costs, public opinion, preference for alternative strategies, burn unit preparation, and insurance limitations (Quinn-Davidson and Varner 2012).
While the Quinn-Davidson and Varner study provides useful insight into prescribed fire constraints, there is additional room for refinement. Specifically, air quality regulatory agencies were not a participant in the study, and the reasons why air quality regulations were viewed as an impediment were not examined. For example, burn windows, which were identified as the top constraint, occur during the same time of year (typically in the fall) when other sources of air pollution, such as woodstove/residential wood combustion, combine with seasonal inversions to result in deteriorating air quality conditions and become a factor in burn day allocations, which is not discussed in the study. Additionally, the study did not recognize air quality regulators as a key participant in future efforts to address impediments.
The Value of Collaboration
For prescribed burn projects to be successful, they must involve all stakeholders, including the public. Collaborative action with clear, open and honest communication builds trust, respect, approval, autonomy and cooperation within a community (Straus 2002). Although many of the past studies regarding impediments or constraints on prescribed burning have indicated that air quality regulations are a major constraint, some studies have reported that the drivers of the public’s intolerance of smoke is a lack of trust in the agencies conducting the burning (Menning 2007; McDaniel 2014). The studies report that public safety, planning and smoke management are important considerations, but public communication is perhaps the most
27 important component for successful burn programs (McDaniel 2014). Building trust, establishing credibility and communicating fire issues with the public is an investment in active forest management that will pay off in the long-term (McDaniel 2014).
Although they may not specifically spell out the need for collaboration, upper-level managers, such as Cal Fire Director, Ken Pimlott, understand its importance. According to
Straus (2002), if you have to get the support and agreement of others before you can take action of some kind, then you are collaborating. At a Northern California Prescribed Fire Council
Meeting in 2014, Director Pimlott, addressed the group, saying, “Until we can get the public behind us to accept the smoke in the air, we are going to have problems. Education of the public, beginning with legislators, is key.”
A consideration that must be made when considering the public as a stakeholder is that tolerance of smoke from prescribed fires is influenced by several factors, including personal values (personal health, property, economics), environmental values, and agency trust (Blades and Hall 2011). While one might believe that, “people need to be okay with smoke in the air”
(Pimlott 2014), the reality is that one in three households has someone with respiratory issues, and 26 million people in the US have asthma (Lahm 2014). Concerns regarding the negative health affects to sensitive populations such as the elderly have an increasingly important role in smoke management (Blades and Hall 2011).
Responding to a need to have a collaborative community to discuss the need to minimize smoke impacts from prescribed burning, the National Wildfire Coordinating Group
(NWCG ) was organized in the 1970s and provides a forum in which stakeholders can share innovative ideas to help solve problems (NWCG 2018). In February 2018, the NWCG published the “Smoke Management Guide for Prescribed Fire,” which contains information on prescribed
28 fire smoke management techniques, air quality regulations, smoke monitoring, modeling, communication, public perception of prescribed fire and smoke, climate change, practical meteorological approaches and smoke tools (NWCG 2018).
The deployment of Air Resource Advisors (ARAs), who are trained to coordinate messages regarding the monitoring and modeling data with personnel in the field and the public, during a wildfire event, is an example of innovation that has come from collaborating with stakeholders (USFS 2018). The USFS’s Wildland Fire Air Quality Response Program
(WFAQRP) was created to “directly assess, communicate, and address risks posed by wildland fire smoke to the public as well as fire personnel” (USFS 2018).
Studies such as a recent study on the emissions from wildfires managed for resource benefit show the value in collaboration. The USFS, by investing in research to better understand the impact of smoke from wildfires, is finding ways to reduce threats to public health as a result of wildfire smoke, especially during large burns (Long et al. 2017). In addition to addressing the strategies for performing larger-scale burns while minimizing smoke impacts, the study emphasizes managing fire based on actual smoke monitoring data, public education and outreach, using ARAs and changing the fee structure for prescribed burns (Long et al. 2017).
29 CHAPTER III
METHODOLOGY
Design of the Investigation
The main objective of this study was to reduce impediments to prescribed burning by identifying opportunities for collaborative relationships between land managers and air quality regulators. A previous study by Quinn-Davidson and Varner (2012) examined constraints on prescribed fire by surveying land management organizations in Northern California. The surveys ranked air quality regulations as the second greatest impediment to prescribed burning but provided the perspective of only land managers in evaluating the constraints. An examination of the constraints as viewed by both land managers and air quality regulators provided an opportunity to identify common goals and align the groups in such a way as to proactively approach fuels management policies as a collective unit. In this way, more effective fuels management projects might be achievable, resulting in the reduction of negative fire behavior and improving forest health and the environment.
Treatment and Population
This study was conducted using several steps, including a literature review, interviews, surveys, and data analysis. The literature review was conducted first to understand the background and history of the problem. Areas studied included fire history, policies and regulations, public perceptions, the costs and benefits of wildfire/wildland fire use, smoke and health risks, policies and regulations and constraints. This first step provided a foundation upon which to ask more thoughtful questions and find common ground on issues that were examined.
30 Survey instruments were developed from the initial issues drawn from the literature review and were used in the selection of interview questions as well as the selection of interview subjects. Interview questions, included in the Appendix, were prepared prior to the interviews.
The majority of the interview participants’ were separated into three categories. The first category of questions was pointed toward understanding the structure of the interview subject’s organization and the potential impediments in obtaining (or providing) burn approval. The second category of questions was designed to understand the relationship that the interview subject had with other agencies and the third category was designed to understand their relationship with the public. Two federal land managers, one state regulator and one local regulator were chosen for interviews, as well as two academics. The interviews of the academics were focused on research in their field of study. Interviews were performed in person and via phone between December 2014 and April 2015 with the following persons:
• John Kennedy, retired from California EPA, Pacific Southwest Region 9, San
Francisco, California (in person, December 12, 2014);
• Dr. Christine Eriksen, Research Fellow, Australian Centre for Cultural
Environmental Research and Centre for Environmental Risk Management of
Bushfires, University of Wollongong, New South Wales, Australia (in person,
December 12, 2014);
• Dr. Scott Stephens, Professor of Fire Science, University of California, Berkeley
(in person, December 12, 2014);
• Jeremy Strait, Fuels Officer, BLM, Redding Field Office, California (in person,
January 31, 2015);
31 • Mike Broughton, National Smoke Management Specialist, USFWS, Denver,
Colorado (via phone, February 12, 2015); and,
• Ann Hobbs, Air Quality Specialist, Placer County APCD, Auburn, California (via
phone March 12, 2015).
Transcripts of the interviews were prepared and used along with information gathered during the literature review to design two surveys, one for distribution to land managers and the other to air quality regulatory staff. Each survey was developed by using Survey Monkey® and consisted of ten questions each, distributed via email to potential survey respondents. The surveys are included in the Appendix.
The survey that was developed for the land managers asked open-ended questions such as: 1) If you have been denied a request to burn by the air district or have met opposition to planning a prescribed burn, please comment as to why you think your burn was opposed and what you think could have been done differently. 2) Do you have any comments or suggestions that might improve the ability of your agency or organization to conduct more prescribed burning? To help make the survey more efficient, other questions allowed for comment but asked predominantly closed-ended questions such as: 1) Do you have a good working relationship with your local air district staff? 2) Rank the following choices in terms of the most likely to prohibit your ability to conduct prescribed burning (scale of 1 to 10 with 10 being the least likely). The choices of impediments that were used in the ranking question was derived from the survey conducted by Quinn-Davidson and Varner (2012).
Like the land manager survey, the air quality regulatory agency survey asked open- ended questions such as: 1) Do you think that the public would be more inclined to accept a certain level of smoke in the air (assuming that it was not affecting their health) if there was
32 more education and outreach? And do you think that a greater acceptance from the public would equate to your allocating more burning than you allocate currently? 2) Do you have any comments or suggestions that might improve the ability of your agency or organization to allocate more prescribed burning? As in the land manager survey, other questions allowed for comment but were predominantly closed-ended questions such as: 1) Would you consider your agency as one that is supportive of prescribed burning? 2) Rank the following choices in terms of why you would deny a prescribed burn (scale of 1 to 10 with 10 being the least likely).
The surveys were distributed via email in April 2015 using a variety of contacts that were available: all Northern California air quality management district offices, invitees to a meeting of air quality regulatory staff and land managers (ALM) in Sacramento, California, members of IASC, and another regional smoke management/prescribed burn collaborative group, Northeast Air Alliance (NEAA), as well as to all the USFS fuels staff in California and to the California Fuels Committee, which the NPS and BLM participate in as well. Recipients of the email were encouraged to forward the survey to other interested parties, which further expanded the outreach. Very early on in the process, it was discovered that interest in the study had expanded to other regions, even as far away as Southeastern Florida, and the study population was adjusted to allow for a wider field of responses. Lastly, survey emails were sent to members of the National Wildfire Coordinating Group (NWCG) Smoke Managers Group, with members throughout the US.
Data Analysis Procedures
Although it is not known how many people received an invitation to complete the
survey, a total of 168 surveys were returned between April 16, 2015 and September 24, 2015. A
33 survey was deemed “incomplete” and was not used in the data analysis if five or more of the ten questions were skipped by the respondent. A total of 43 surveys were incomplete and were excluded for this reason.
The data from the 125 completed surveys was entered into four separate Microsoft
Excel® spreadsheets and mean ratings were calculated for each variable. Figures and tables were created to visually present data derived from the mean ratings and aid in analysis. Overall mean ratings were calculated for each impediment (n=10) for the generation of Tables 1, 3a, 3b and 5 and 7. Further detail regarding the analysis of the results is provided below in Chapter IV.
A summary of the study, its limitations and weaknesses, as well as conclusions and recommendations, including future research recommendations are provided in Chapter V.
34 CHAPTER IV
RESULTS AND DISCUSSION
Interview Results
Both of the federal land managers who were interviewed were aware of the differences in California versus other regions of the country because of increasing wildfire severity issues, limited resources, and issues with pollution impacts on a larger population base.
They felt that they had a good relationship with air quality regulatory agencies, and also saw the need for that relationship to be collaborative with the agencies with whom they interacted with.
Differences among agencies with respect to their process for prescribed burning became apparent during the interviews, in large part because of the types of burning that different agencies conduct. 1 Attitudes within different agencies regarding public outreach seemed to be similar
(cultural), with variability by location. The ability of an agency to employ support staff, such as
an outreach coordinator, positively affected the agency’s outreach efforts.
Both of the air quality regulatory professionals chosen to be interviewed for this study had a long history of involvement in the smoke management programs in California and were well aware of the efforts made to work with stakeholders on both the land management side and air quality regulatory side to develop policies and programs that positively promoted prescribed burning. Finding a way to allow for increasing prescribed fire to proceed while making room for the inevitable air quality impacts, while minimizing impacts to public health was a key focus for both. It was noted that for dedicated staff to be able to make this happen, a commitment on the
1 USFWS tends to burn in grassland and brush, which results in a single day burn with minimal smoldering, while the USFS burns in heavier fuels in forested regions with multi-day burns and smoldering, which gets into valleys and creates public nuisance issues. 35 part of the local air quality regulatory agency was needed, and both interview subjects acknowledged that there was room for continued growth in the collaborative efforts on both the land manager and regulatory sides.
The two academic professionals who were interviewed for this study further supported the need for collaboration between agencies. Both of the academics had experience in studies of indigenous burning and one academic noted that traditions have been lost, but that people continue to try to nurture the relationship between culture and land. One of the academic professionals shared their concerns that society accepts the false sense of the protection that is offered by fire agencies without regard to the long-term ramifications of fire protection.
Regional Land Manager Survey Results
Of the 45 surveys received, only 33 surveys were considered complete for this study.
Survey respondents reported they had been involved in prescribed burning for an average of 17
years. The majority (55 percent) of the surveys completed for this study were submitted by
USFS staff, but surveys were also received from Cal Fire, BLM, NPS, and USFWS. One survey
was received from a private timber company, one from a private landowner, and four surveys
were received that did not have a clear agency affiliation and were labeled as, “Other”. The
distribution of the respondents to the regional land manager survey, obtained from Question 1, is
seen in Figure 1.
36 Figure 1: Distribution of Survey Responses from Regional Land Managers (n=33) Other (n=4) Private 12% Landowner (n=1) 3% Private Timber (n=1) 3% USFS (n=18) USFWS (n=1) Cal Fire (n=4) 3% BLM (n=2)USFS (n=18) 55% NPS (n=2) NPS (n=2) 6% USFWS (n=1) Private Timber (n=1) BLM (n=2) Private Landowner (n=1) 6% Other (n=4)
Cal Fire (n=4) 12%
Source: Regional Land Manager Surveys
In the second question, 30 of the 33 survey respondents provided the types of burn methods used by their agency. Out of a total 2 of 32,615 average annual acres, the majority (65 percent) of the acres were burned using pile burn methods. Broadcast burning methods were used to burn 31 percent of the acres on average. The total distribution of types of burn methods used is shown in Figure 2a.
2 Total burn acres were estimated based on the reported total average burn acres and percentages of burn methods reported by each respondent who provided data. One survey submitted by the NPS was excluded because the data provided was inconsistent, two surveys did not have data. 37 Figure 2a: Regional Land Managers Burn Methods (n=30)
14,000
11,997 12,000 10,568 9,353 10,000 Hand pile M/L pile 8,000 Broadcast Other burn 6,000
Annual Acres Burned 4,000
2,000 697
- All Land Managers
Source: Regional Land Manager Surveys M/L=Machine/Landing
As shown in Figure 2b, USFS and Cal Fire, the two agencies representing the majority (67 percent) of the survey data, used the hand pile burning method more frequently (39 percent of acres treated on average) than other methods of burning. Broadcast burning was reported as the method used to treat over half (51 percent) of the average annual acres reported by other 3 agencies. The majority of survey respondents (74 percent) burned primarily timber
and/or mixed conifer, with the remaining respondents burning a mixture of 50 percent timber or
less with chaparral, grasses and other vegetation.
3 Other agencies represented are BLM (n=2), USFWS (n=1), NPS (n=1), Private Timber (n=1), Private Landowner (n=1), California Tahoe Conservancy (n=1), and Other (unclassified) (n=3) 38 Figure 2b: Regional Land Managers Burn Methods by Agency (n=30)
16 Cal Fire 414 (n=4) 136 429 Other burn 180 Broadcast All Other 1,963 RLMs M/L pile 946 (n=10) 767 Hand pile
501 USFS 8,191 (n=16) 8,271 10,801
- 2,000 4,000 6,000 8,000 10,000 12,000 Average Annual Acres Burned
Source: Regional Land Manager Surveys M/L=Machine/Landing
When asked if they met their objectives with burning (Question 3), the majority of respondents (77 percent) reported that they were very pleased and only two of 30 respondents reported that they were “disappointed” and met few of their objectives (as seen in Figure 3).
39 Figure 3: Regional Land Managers Satisfaction Regarding Prescribed Burns (n=30)
Skipped question 1 Extremely disappointed 0 Very disappointed 0 Other (generally negative) 1 Disappointed-met few 2 Other (generally positive) 3 Somewhat pleased 4 Very pleased 20
Source: Regional Land Manager Surveys
The quality of relationships that land managers reported having with air quality regulatory agencies was quite good in most cases, but some saw a need for improvement. When asked to rate the quality of the relationship that they had with their local air quality regulatory agency (Question 4), all of the respondents provided information, and the majority (69 percent) reported having an excellent working relationship with local air quality regulators as shown in
Figure 4.
40 Figure 4: Relationship with local air quality regulatory staff (n=32)
3% 3% 3% Excellent relationship
Pretty good but needs improvement 22% It's okay but strained/unsupportive
69% Frustrated/adversarial
Other: Depends on air district or individual
Source: Regional Land Manager Surveys
When asked how often they were denied a request to burn (Question 5), all of the respondents provided feedback. Sixty percent of the respondents stated that less than ten percent of their requests to burn were denied, with 16 percent of the group never having been denied a burn. Four USFS respondents and one USFWS respondent were denied up to 20 percent of their requests, and one USFS respondent was denied up to 30 percent of their requests, as seen in
Figure 5.
41 Figure 5: How Often Regional Land Managers are Denied a Request to Burn (n=32)
Other >30% 20-30% 10-20% <10% N/A, never denied
0 2 4 6 8 10 12 14 16 Number of responses
Source: Regional Land Manager Surveys
Survey respondents were asked to comment as to why they thought their burn was opposed (if applicable) and what they could have done differently (Question 6). The 21 responses received were analyzed and characterized into three categories: 1) meteorological or dispersion issues (33 percent), 2) lack of flexibility or understanding by air quality regulatory agency (57 percent), and 3) no input or positive feedback (10 percent). Figure 6 below shows the distribution by agency of the categories of comments.
42 Figure 6: Distribution of types of comments regarding burn denials (n-21)
Private Timber
Other No comment/Positive
CA Tahoe Conservancy Lack of USFWS Flexibility/Understanding
Cal Fire Meteorological/Dispersion
NPS
BLM
USFS
0% 10% 20% 30%
Source: Regional Land Manager Surveys
The seventh question in the survey asked the respondents to rank ten constraints previously identified by Quinn-Davidson and Varner (2012). A total of 31 respondents answered this question. Narrow burn windows were ranked as the highest constraint on average for all survey participants with 39 percent suggesting a narrow burn window being the highest perceived constraint, followed by air quality regulations at 23 percent (see Table 1).
43 Table 1: Regional Land Manager Impediments to Prescribed Fire Scale of 1-10 (10 least likely) - Mean ratings (standard deviations) Cal All USFS Fire NPS BLM USFWS TC PT Other Impediment (n=31) (n =17) (n=4) (n=2) (n=2) (n=1) (n=1) (n=1) (n=3) Public opinion/ 5.4 5.6 5.3 3.5 6.0 4.0 3.0 8.0 6.3 public complaints (2.7) (2.8) (3.3) (3.5) (0) (0) (0) (0) (3.1) Planning costs 6.5 6.3 7.8 5.5 6.0 5.0 0 9.0 6.7 (2.9) (3.1) (1.0) (3.5) (2.8) (0) (0) (0) (4.9) Fuel loading - size 5.7 6.0 6.0 6.5 3.0 10 .0 5.0 3.0 4.0 of proposed burn (2.5) (2.7) (1.8) (2.1) (0) (0) (0) (0) (2) Liability –escaped 5.7 6.2 6.5 9 1.0 8.0 1.0 1.0 4.0 fire (2.8) (2.2) (2.6) (0) (0) (0) (0) (0) (3) Lack of Adequate 6.1 6.2 8.3 4.5 2.5 9.0 0 10 .0 3.3 Funding (3.1) (3.1) (1.7) (3.5) (0.7) (0) (0) (0) (1.5) Residential Area 5.3 5.5 4.8 4.0 4.0 6.0 4.0 5.0 6.3 near burn (2.2) (2.3) (3.6) (0) (0) (0) (0) (0) (1.5) Environmental 6.0 5.6 4.0 8.0 6.0 7.0 7.0 7.0 8.7 laws (2.9) (3.1) (1.4) (2.8) (5.7) (0) (0) (0) (1.2) Lack of adequate 5.5 5.9 3.3 5.0 7.0 3.0 6.0 4.0 5.3 personnel (2.4) (2.6) (1.5) (2.8) (2.8) (0) (0) (0) (2.1) Air quality 4.1 3.7 4.5 3.5 6.5 2.0 2.0 6.0 5.3 regulations (2.7) (2.6) (3.0) (2.1) (0.7) (0) (0) (0) (4.5) Narrow burn 3.5 3.5 1.0 5.5 3.0 1.0 8.0 2.0 5.0 window (3.0) (2.7) (0) (6.4) (2.8) (0) (0) (0) (3.6) TC= California Tahoe Conservancy PT = Private Timber Company Source: Regional Land Manager surveys
The eighth question in the survey asked participants if they interacted with the communities in which they conducted burning in, and to what extent. Figure 7 shows that while the majority (41 percent) of the respondents regularly attend meetings, 25 percent of those who completed the survey interacted very little, if at all.
44 Figure 7: Regional Land Managers Collaborative Efforts (n-31)
No, not really 6% 6% Every once in a while I attend a meeting 19% 19% I regularly attend meetings
9% I host events/collaborate
I live in the community/regularly engage 41% Other positive collaborative actions
Source: Regional Land Manager surveys
The last multiple-choice question (Question 9) posed to regional land managers asked if they felt their organization supported community involvement and is shown in Figure 8a, below. Just over a third of land managers (36 percent) who participated in the survey felt that there was a lot of support for collaborative efforts, with the same percentage agreeing that budget cuts and priorities scaled it back a lot. Ten percent felt that it was no longer a priority, but that it had been in the past, and six percent did not think it was a concern to their agency.
45 Figure 8a: Regional Land Management Support for Collaborative Engagement (n=31)
3% Yes, a lot of support 3% 6% Budgets scaled it back 6% 36% Not prioirty, but it used to be
10% I don't think it's a concern
Other: Generally supportive
Other: Generally unsupportive 36%
Other: Neutral/not determined
Source: Regional Land Manager surveys
An analysis of the responses by agency showed some disparity; the responses received from the USFS was similarly distributed as the overall results, but other agencies, reported support with more significant disparity. Of the four responses from Cal Fire, for example, two reported that there was a lot of support for community involvement, while one reported that it wasn’t a priority like it used to be, and another reported that they didn’t believe it was a concern to the agency. Figure 8b, below, displays the results by agency.
46 Figure 8b: Regional Land Management Support for Collaborative Engagement, by Agency (n=31)
CA Tahoe Conservancy
USFWS
Other
Private Timber (n=1)
NPS (n=2)
BLM (n-2)
Cal Fire (n=4)
USFS (n=17)
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% Other: Neutral/not determined Other: Generally unsupportive Other: Generally supportive I don't think it's a concern Not prioirty, but it used to be Budgets scaled it back Yes, a lot of support
Source: Regional Land Manager surveys
The last question included on the regional land manager surveys (Question 10) asked for comments or suggestions that might improve the ability of their agency to conduct more prescribed burning, provided that they believed there was a need for improvement. Of the 33 surveys, nine respondents skipped this question and two replied that no improvement was needed. Of the remaining 23 respondents, answers were summarized and put into categories based on the feedback provided as shown below in Table 2.
47 Table 2: Regional Land Managers Suggestions to Reduce Impediments to Prescribed Fire (n=43) 12 Air quality regulatory agencies need to be more educated/supportive, allow burning on marginal burn days/more burn days, burn during fire season
4 Funding needed
4 More support from upper management
4 Need for more public education/support, including legislative
3 Liability needs to be reduced
2 Increase personnel, increase training/retain seasonal workforce outside of fire season to conduct prescribed burns.
1 “More snow”
1 “Diversity is the priority, nothing else matters”
1 Relaxation of policies/land tenure patterns
2 No improvement needed
9 Skipped question (one respondent was unable to answer question)
Source: Regional Land Manager surveys
National Land Manager Survey Results
A total of 92 national land manager surveys were received, however, 24 surveys were excluded due to incompleteness using the same criteria as that used for the regional land manager surveys (greater than four skipped questions). A large portion (48 percent) of the national land managers who reported their years of experience (42 of the 68 completed surveys) had been involved in prescribed burning for over 20 years.
48 The surveys did not include questions for respondents to specify which state they did their work in, but it was noted from some of the answers in the survey that several areas of the country were represented; state agencies in the Southeast (Florida, North and South Carolina), the South (Texas and Louisiana), and the Midwest (Illinois and Pennsylvania) submitted surveys for the study. Other responses came from agencies with offices located in Washington and
Nebraska. A much different distribution of surveys was received from the national survey responses. Unlike the regional land manager surveys, the national USFS surveys only represented 13 percent of the surveys (the third largest category). The largest categories of responses from the national land manager surveys were from non-governmental agencies and private landowners. This is not surprising, given that there is much discussion amongst professionals in the smoke management sector about the fact that much of the burning in other parts of the US, especially the south, are private landowners. A figure showing the distribution of the national land manager surveys is shown below in Figure 9.
49 Figure 9: Distribution of Survey Responses from National Land Managers (n=68) Prescribed Fire NPS Dept of Consultant 2% Defense Private Timber 2% 2% 2% Other unspecified 4% State Agency University 12% 4% BLM 10%
USFWS Private landowner 6% 17%
USFS 13%
NRCS 3% Unspecified NGO County Gov't Agency 20% 3%
Source: National Land Manager surveys
In the second question, regional land managers were asked what types of burn
methods were used by their agency (hand pile, machine/landing pile, broadcast or other), the
average acres burned and percentage of types of vegetation. Because the national surveys were
collected, it also illustrated some differences between prescribed burning in Northern California
and burning done elsewhere in the country. Only 50 of the 68 completed surveys complete data
to be used in the study for a comparative analysis. Out of a total 4 of 4,263,577 average annual
acres, the majority (67 percent) of the acres were burned using broadcast burn methods. Pile
burning methods were used to burn 29 percent of the acres on average, nearly all hand piles (only
3 percent of the total piles burned were landing piles). Unlike the regional land manager
4 Total burn acres were estimated based on the reported total average burn acres and percentages of types of burn methods reported by each respondent who provided data. 50 surveys, conifer burning was not reported as the dominant vegetation type that was burned.
Burning was divided fairly evenly between mixtures of conifer/hardwood/oak woodland and grass/prairie. The total distribution of average annual acres and the burn methods used is shown in Figure 10a, and the annual acres separated by agency are shown in Figures 10b and 10c.
Figure 10a: National Land Managers Annual Acres/Burn Methods (n=50) 3,500,000
2,872,576 3,000,000
2,500,000 Hand Pile 2,000,000 M/L Pile Broadcast 1,500,000 Other Annual Acres Burned Acres Annual 1,095,607 1,000,000
500,000 134,734 160,660 - All National Land Managers Source: National Land Manager surveys M/L=Machine/Landing
51 Figure 10b: National Land Managers Annual Acres/Burn Methods by Agency Except State Agencies and USFS (n=33)
Private 1,200 56,560 Landowner 15,855 (n=9) 14,620
12,000 Other NGO (n=9) 59,360 16,055 Broadcast 15,320 M/L Pile 2,600 17,200 Hand Pile BLM (n=4) 4,350 4,450
All Other 20,060 51,896 Agencies 8,274 (n=11) 10,702
- 10,000 20,000 30,000 40,000 50,000 60,000 70,000 Average Annual Acres Burned
Source: Regional Land Manager Surveys M/L=Machine/Landing
Figure 10c: National Land Managers Annual Acres/Burn Methods by Agency - State Agencies and USFS (n=17)
89,300
USFS 301,560 (n=9) 75,700
114,815 Other Broadcast M/L Pile 35,500 Hand Pile State 2,386,000 Agencies (n=8) 14,500 935,700
- 500,000 1,000,000 1,500,000 2,000,000 2,500,000 3,000,000
Average Annual Acres Burned
Source: National Land Manager Surveys M/L=Machine/Landing 52
All of the 68 national land managers surveys contained answers for Question 3, which asked how pleased the land manager was with the outcome of recent burning activities. Nearly all of the respondents reported overall positive outcomes from their prescribed burns, except for one (see Figure 11).
Figure 11: National Land Managers' Satisfaction Regarding Prescribed Burns (n=68)
Other: N/A - no acreage recently 2 Other: Generally Positive 2 Other: Negative, Limited burn…1 Extremely disappointed 0 Very disappointed 0 Disappointed-met few objectives 0 Somewhat pleased 14 Very pleased 49
Source: National Land Manager Surveys
When asked in Question 4 if they have a good working relationship with local air regulators, many of the national land managers noted that this did not apply to them, as they do not work with air quality regulatory agencies directly. Some of the land managers make their own air quality decisions, following the guidelines of their burn prescriptions. Other land managers follow burn day decisions made by the local fire department. 37 percent of the respondents who do work with air quality regulatory agencies felt that their relationship was
“excellent”. Over half of the 67 responses indicated that there was room for improvement. None of the responses indicated an adverse relationship (see Figure 12).
53 Figure 12: National Land Managers' Relationships with Air Quality Regulatory Agencies (n=67)
2% Excellent relationship 3% Pretty good, but…I don't think they understand my point of view It's okay... but I don't think they're fair 28% 37% reasonable Other: Neutral
Other: N/A/Agency doesn't work with air reg agencies
6% Other: I deal with multiple air reg agencies, response varies 5% 19% Other: Pretty good/excellent, I understand their point of view but wish they could do more
Source: National Land Manager Surveys
When asked how often they were denied a request to burn in Question 5, 16 percent of the 67 respondents reported that they did not need approval from an air quality regulatory agency at all. Several of the respondents commented that they followed guidelines and don’t burn when they are out of prescription; this likely indicates that they, too, do not need to seek approval from an air quality regulatory agency. Of those who did have a need for approval from air quality regulatory agencies, nearly half (49 percent) of the national respondents stated that they had never been denied a request (see Figure 13).
54 Figure 13: How Often National Land Managers are Denied a Request to Burn (n=67)
Other: Decrease in acreage, not a denial Other: Generally Negative Other: We follow guidelines/don't burn when… Other: No air quality regulatory agency oversight >30% 20-30% 10-20% <10% N/A, never denied 0 5 10 15 20 25 30 35 Number of responses
Source: National Land Manager Surveys
Survey respondents were asked to comment as to why they thought their burn was opposed (if applicable) and what would have been done differently (Question 6). The 22 responses received were analyzed and characterized into five categories, two of which were the same as the regional land manager surveys: (1) meteorological or dispersion issues (50 percent) and (2) lack of flexibility or understanding by air quality regulatory agency (23 percent). The other categories, added to accommodate the different responses from national land manager surveys were: (3) fire danger/wildfire drove denial (14 percent), (4) risk avoidance/politics (9 percent), and (5) need for private landowners to be educated (five percent). Figure 14 shows the distribution by agency of the categories of comments.
55 Figure 14: National Land Managers Distribution of Types of Comments Regarding Burn Denials (n-22)
Other
Consultant
NRCS
NGO
Private Landowner Need for private landowners to be educated University Fire Danger/Wildfire drove denial
USFWS Risk Avoidance/Politics
USFS Lack of Flexibility/Concern
BLM Meteorological/Dispersion
State Agency
0 2 4 6
Source: National Land Manager Surveys
The seventh question in the survey asked the respondents to ranked ten constraints.
64 of the 68 national land manager respondents completed this question. Narrow burn windows were ranked as the highest constraint on average for all survey participants with 33 percent suggesting a narrow burn window being the highest perceived constraint, followed by lack of adequate funding and lack of adequate personnel (tied) at 13 percent (see Tables 3a and 3b).
56 Table 3a: National Land Managers Impediments to Prescribed Fire Mean Ratings (standard deviations), Scale 1-10 with 10 being the least likely to be an impediment Private State All NGO Landowner USFS BLM Agencies USFWS Other Impediment (n=64) (n=13) (n=11) (n=9) (n=7) (n=7) (n=3) (n=3) Public opinion/ 5.5 5.3 5.5 6.3 5.1 4.2 7.0 7.0 Public complaints (2.8) (2.8) (2.8) (3.7) (2.7) (2.9) (2.0) (2.0) Planning costs 6.3 7.4 6.9 6.1 4.2 7.4 6.0 8.0 (2.7) (2.3) (2.4) (3.6) (2.3) (1.8) (3.6) (2.8) Fuel loading - size 5.3 4.8 4.1 5.4 6.6 5.0 4.7 6.7 of proposed burn (2.7) (2.9) (2.0) (2.5) (2.8) (2.3) (4.6) (2.5) Liability - escaped 4.9 3.9 4.1 6.2 5.2 5.7 5.3 3.0 fire (2.4) (2.3) (2.4) (3.0) (1.5) (2.3) (1.2) (2.6) Lack of Adequate 4.7 5.4 6.4 3.3 4.0 5.6 2.0 5.3 Funding (2.9) (3.1) (2.7) (2.2) (3.4) (3.0) (1.0) (3.1) Residential area 5.2 4.3 6.1 5.7 5.5 3.0 8.0 5.7 near burn (2.6) (2.0) (2.7) (3.0) (2.9) (1.8) (0.0) (3.2) Environmental 6.2 6.7 4.7 5.8 6.3 7.1 8.3 5.0 laws (2.6) (2.1) (3.5) (2.2) (3.2) (2.3) (1.2) (2.6) Lack of adequate 4.7 4.1 5.0 5.4 5.6 5.3 6.0 4.7 personnel (2.8) (2.1) (3.1) (2.7) (3.5) (2.9) (3.5) (4.7) Air quality 6.9 6.1 6.6 6.7 6.7 8.2 6.0 4.5 regulations (2.6) (3.2) (2.9) (2.2) (3.4) (1.8) (1.0) (0.7) Narrow burn 3.4 2.6 4.9 4.0 4.1 2.4 1.7 3.0 window (2.7) (2.3) (3.2) (2.9) (3.0) (2.1) (1.2) (2.0) Source: National Land Manager surveys
57
Table 3b: National Land Managers Impediments to Prescribed Fire (continued). Mean ratings (standard deviations), Scale 1-10 with 10 being the least likely to be an impediment. County Consult - Dept of Private All University Gov't NRCS ant NPS Defense Timber Impediment (n=64) (n=3) (n=2) (n=2) (n=1) (n=1) (n=1) (n=1) Public opinion/ 5.5 8.5 4.0 9.0 5.0 2.0 1.0 - Public c omplaints (2.8) (0.7) (0.0) (0) (0) (0) (0) - Planning costs 6.3 4.0 8.0 4.0 4.0 5.0 - 1.0 (2.7) (2.0) (0.0) (0) (0) (0) - (0) Fuel loading - size 5.3 6.0 8.5 4.5 10.0 8.0 5.0 2.0 of proposed burn (2.7) (3.6) (2.1) (0.7) (0) (0) (0) (0) Liability - escaped 4.9 4.0 7.6 3.0 7.0 9.0 8.0 3.0 fire (2.4) (1.0) (2.8) (0) (0) (0) (0) (0) Lack of adequate 4.7 3.0 6.0 6.0 1.0 1.0 - 4.0 funding (2.9) (1.4) (0.0) (0) (0) (0) - (0) Residential area 5.2 7.0 4.0 5.0 9.0 3.0 4.0 5.0 near burn (2.6) (0.0) (1.4) (2.8) (0) (0) (0) (0) Environmental 6.2 8.5 5.0 5.0 8.0 6.0 6.0 6.0 laws (2.6) (0.7) (2.8) (4.2) (0) (0) (0) (0) Lack of adequate 4.7 2.3 1.5 3.0 3.0 4.0 3.0 7.0 personnel (2.8) (2.3) (0.7) (2.8) (0) (0) (0) (0) Air quality 6.9 7.3 9.5 10.0 6.0 10.0 7.0 8.0 regulations (2.6) (2.3) (0.7) (0) (0) (0) (0) (0) Narrow burn 3.4 2.0 1.5 1.5 2.0 7.0 2.0 9.0 window (2.7) (1.0) (0.7) (0.7) (0) (0) (0) (0) Source: National Land Manager surveys
A total of 66 respondents answered Question 8, which asked about the national land managers’ level of regular collaboration with the public in areas when prescribed burning is being conducted. The majority of respondents (71 percent) collaborate in some way in the communities where they conduct prescribed burning, as seen in Figure 15.
58 Figure 15: National Land Managers Collaborative Efforts (n- 66)
I don't really interact 11% 15% Every once in a while I attend a meeting
14% I regularly attend meetings 27% I host events, collaborate frequently
18% I live in the community, engage regularly 15% Other types of interactions
Source: National Land Manager surveys
The last multiple-choice question posed to national land managers asked if they felt their organization supported community involvement. A total of 62 of 68 respondents provided information. Nearly one half felt there was a lot of support for collaboration and one quarter of the land managers agreed that budget cuts and priorities scaled back participation. Very few reported that they did not think that community involvement was a concern to their agency.
Results are shown in Figure 16a (overall results) and Figure 16b (comparison of results by agency) below.
59 Figure 16a: National Land Managers Support for Collaborative Engagement (n=62)
2% 3% 3% Yes, a lot of support, I'm provided time and resources for it There's support, but budget cuts and 6% priorities have scaled it back a lot It seems like it's not a priority anymore, but it used to be 15% 48% I don't think it's a concern that my agency has Other: Generally positive
23% Other: Variable priority across state/agencies Other: N/A
Source: National Land Manager surveys
Figure 16b: National Land Managers Support for Collaborative Engagement by Agency (n=62)
Other Unspecified Other: N/A Defense
NPS Other: Variable priority across Rx Fire Consult state/agencies University Other: Generally positive Private Landowner NRCS I don't think it's a concern that NGO my agency has County Govt It seems like it's not a priority USFS anymore, but it used to be USFWS There's support, but budget cuts BLM and priorities have scaled it back a lot State Agency Yes, a lot of support, I'm -1 1 3 5 7 provided time and resources for Number of responses it
Source: National Land Manager surveys
60 The last question included on the national land manager surveys (Question 10) asked
for comments or suggestions that might improve the ability of their agency to conduct more
prescribed burning, provided that they believed there was a need for improvement. Of the 68
surveys, 21 respondents skipped this question and nine replied that no improvement was needed.
Of the remaining 37 respondents, answers were summarized and put into twelve categories based
on the feedback provided and are shown in Table 4 (note: several respondents offered multiple
suggestions, resulting in a greater number of answers to the survey question than respondents).
Table 4: National Land Managers Suggestions to Reduce Impediments (n=86) 10 The public and public officials need to be more educated/supportive
9 Increased funding needed
7 Need more trained personnel
6 Collaboration between agencies
4 Work with air regulatory agencies to accomplish more burning in a shorter time period 4 Improved ability in general; one response stated that California is difficult to accomplish large scale burning "due to poor air quality" 3 Liability coverage
3 Need more internal support within agency
2 Need leadership training for private landowners so they can burn confidently
2 Just DO IT, also increase prescribed burning on private lands
2 Burn during burn season instead of (just) shoulder seasons
1 Environmental regulations (migratory birds) need to be re-evaluated to provide longer burn windows 10 No improvement needed or not applicable
21 Skipped question
Source: National Land Manager surveys
61 Regional Air Quality Regulator Survey Results
A total of 22 of the regional air regulator surveys were completed and returned
through Survey Monkey®. Only 17 of the surveys were included in the study because five
surveys were incomplete (greater than four skipped questions). In an effort to keep the survey
results candid and the responses anonymous, the survey did not ask respondents to indicate what
air quality regulatory agency the participant worked for, so this data is not included in the study.
In the first question in the survey, air quality regulators were asked the average acreage allocated for burning and the types of vegetation burned by percentage (Question 1).
The categories provided for the survey participant to choose from included “agricultural pile”
(orchard pruning waste), “field crop burn” (wheat, corn, rice, etc.), “administrative burn” (levees or roadsides), and prescribed burns, both piles and broadcast burns. All of the respondents provided distribution type information. Burning of all types appeared to be fairly well distributed, as shown in Figure 17a, below.
62 Figure 17a: Regional Air Quality Regulators Distribution of Types of Agricultural Burns Allocated (n=81)
14
12 Agricultural Piles Field Crops 10 Administrative Prescribed Burn Piles 8 Prescribed Burn Broadcast 6
Number Number ofResponses 4
2
0 0-19% 20-39% 40-59% 60-79% 80-100%
Source: Regional Air Quality Regulator surveys
Only nine respondents provided the annual burn acres and eight provided specific information on the vegetation type. An average of 6,200 acres per year was reportedly allocated by air quality regulators, with a mixture of primarily conifer and brush, with grassland, oak, and chaparral or forest understory, as the primary vegetation types. A distribution of the burn acres that were allocated is shown below in Figure 17b.
63 Figure 17b: Regional Air Quality Regulators Average Agricultural Burn Acres Allocated Annually (n=9)
11% 11% <500 acres 11% 500 - 2,000 acres 22% 2,000 - 5,000 acres 5,000 - 10,000 acres >10,000 acres 45%
Source: Regional Air Quality Regulator surveys
During the 2014/2015 burn season, most of the 16 respondents to this question reported having authorized more than 20 prescribed burns (Question 2). Two survey participants provided further detail; one respondent said that they authorized 248 prescribed burns, and another authorized 917 prescribed burns. Figure 18 shows the responses.
Figure 18: Regional Air Quality Regulators Number of Prescribed Burns Authorized Annually (n=16)
25% 1-5 0% 6-10 0% 11-20 More than 20 75%
Source: Regional Air Quality Regulator surveys
64 When asked how often they deny a request to prescribed burn (Question 3), all but two of the 16 respondents stated that they had denied a burn less than 10 percent of the time; one stated they have not denied a burn, and one denied a request between 10 and 20 percent of the time. The question did not apply to one survey participant. The results are shown in Figure 19, below.
Figure 19: How Often Regional Air Quality Regulators Denied Requests for a Prescribed Burn (n=16)
6% 6%
Does not apply - I have not denied a burn (yet) Less than 10% of the requests Between 10 and 20% of the requests
88%
Source: Regional Air Quality Regulator surveys
Question 4 in the survey asked the regional air quality respondent to rank ten constraints. A total of 20 of the 22 respondents completed this question. Thirtyfive percent of the participants identified concerns about health impacts to people from breathing smoke in a nearby community as the highest constraint, followed by concerns about fuel loading (too large of a burn for conditions) and smoke impacts causing exceedance of air quality standards. (see
Table 5).
65
Table 5: Regional Air Quality Regulators Reasons for Denial of Prescribed Burns Standard (n=15) Ranked from 1 -10, with 10 being the least likely reason Mean Deviation Public opinion - Concern about complaints 4.6 2.4 Lack of resources to do smoke modeling or evaluate impacts 7.1 2.1 Fuel loading - too large of a burn/too large for conditions 4.3 2.8 Liability - concerns about escapes 4.9 2.6 Concerns about smoke impacts - exceedance of PM standards 3.4 2.3 Concerns about smoke impacts - exceedance of ozone standards 6.2 2.6 Concerns about health impacts to people in nearby community 2.7 3.0 Lack of adequate outreach to inform potentially affected communities 6.5 2.0 Inadequate alternative treatments or justification for burn 5.4 2.6 Lack of experience or resources to file for exceptional event if needed 7.0 2.2 Source: Regional Air Quality Regulator surveys
All of the regional air quality regulators who provided a response to Question 5 (14 of
the 17 participants), reported they had a prescribed burn cause complaints about smoke impacts,
but only half of those complaints were associated with health effects and half caused an
exceedance of air quality standards that was traceable to the prescribed burn. In addition, 43
percent of the air quality regulators reported having prescribed burns found to be in violation of
air quality regulations (see Figure 20).
66 Figure 20: Regional Air Quality Regulators Reports of Prescribed Burns that Created Negative Impacts (n=34)
Yes, exceedance of air quality standards that were traceable to the prescribed burn 7
Yes, violations of regulations 6
Yes, smoke impacts involving health effects to the public 7
Yes, complaints about smoke impacts, but no severe health effects reported 14
Source: Regional Air Quality Regulator surveys
All of the regional air quality regulators completed Question 6 and reported that they had the strongest relationship of all with federal land managers. There were four isolated “poor” and “very poor” responses. The results of Question 6 are shown below in Figure 21.
Figure 21: Regional Air Quality Regulators Professional Relationship with Agricultural Burners (n=91) 12 10 Orchardists 8 Crop Farmers 6 Land Managers (Federal) 4 Land Managers (State) 2 Land Managers (Private) 0 Land Managers (NGOs) Excellent Good Professional Poor Very poor Land Managers (Tribes) relationship relationship relationship relationship relationship (know by (friendly) (no frills) (lack of (adversarial first name) trust) positions)
Source: Regional Air Quality Regulator surveys
67 A total of 17 respondents answered Question 7, which asked about the air quality regulators’ support level for prescribed burning. The majority (59 percent) of the respondents reported that their agency is “very supportive” of prescribed burning; they attend conferences, meetings, and host events, and say they have a good understanding of the benefits of fire (see
Figure 22).
Figure 22: Regional Air Quality Regulators Management Support for Prescribed Burning (n=17)
Other: Neutral, see need for prescribed burning, but concerned about smoke impacts to communities 1
Other: Very much supportive as long as it doesn't interfere or impede with PM in our air quality zone 1
Not very supportive/little support for prescribed burning 0
We allocate burning when conditions are faborable, but don't allocate much time to the program; we 2 aren't really focused on the benefits of burning.
The agency is generally supportive 3
Yes, I consider the agency very supportive 10
Source: Regional Air Quality Regulator surveys
A total of 15 respondents answered Question 8, which asked about the air quality regulators’ level of regular collaboration with the public. The majority (60 percent) of the respondents reported that they really don’t interact and only infrequently attend meetings (see
Figure 23).
68 Figure 23: Level of Collaboration Between Regional Air Quality Regulators and Communities Affected by Prescribed Burns (n=15)
No, I don't really interact 7% 6% 27% Every once in a while I will attend a meeting
27% I regularly attend meetings
33% I host events and collaborate
Source: Regional Air Quality Regulator surveys
A total of 15 respondents answered Question 9, which asked the air quality regulators about public acceptance of smoke and the need for more education. The majority (47 percent) of the respondents agreed that if there was more education and outreach, people would have a better appreciation for the need for prescribed burning (and would accept seeing smoke), which would equate to their allocating more burning than currently was allocated. 40 percent said it would not change their concerns about smoke impacts (See Figure 24).
Figure 24: Regional Air Quality Regulators Opinions About Public Acceptance of Smoke and the Need for More Education (n=15)
I think people should be educated, but it wouldn't 6 change my concerns about health impacts
I think there needs to be a focus on education to gain 2 political acceptance
Yes, I think that if people had a better 7 appreciation…I'd be able to allocate more
Source: Regional Air Quality Regulator surveys 69
Comments from regional air quality regulators regarding improvements that would
reduce impediments on prescribed burning in Question 10 are summarized in Table 6.
Table 6: Regional Air Quality Regulators Suggestions to Reduce Impediments on Prescribed Burning (n=16) Land managers need to be more flexible, have more resources, and use burn windows more effectively 3 Smoke impacts from neighboring jurisdictions 2 Collaboration and public outreach 2 Training 1 Increased funding 1 Prescribed burning needs to be a priority/ acknowledged as a tool to fight wildfire 1 I think this survey is biased towards more burning. I think regulators should be neutral and not promote burning. 1 Currently no improvement needed 1 Source: Regional Air Quality Regulator surveys
National Air Quality Regulator Survey Results
A total of nine national air quality regulator surveys were returned as completed, but only seven were included in this study; two surveys were “incomplete”. Figures were only used when enough data made the graphic representation purposeful.
The distribution of burn acres by type, the first question asked of the seven national air quality regulatory respondents, is shown below in Figure 25. Respondents were also asked to provide the average annual acres burned for prescribed burning and predominant vegetation types. Only four of the seven survey respondents provided this information and it varied widely;
20 acres of pinyon pine and juniper, 5,841 acres of pines and sagebrush, 55,000 acres of cropland, and 63,782 square feet of orchard vegetative waste.
70 Figure 25: National Air Quality Regulators Distribution of Types of Agricultural Burns Allocated Annually (n=25)
4.5
4 Agricultural Piles 3.5 Field Crops
3 Administrative Prescribed Burn Piles 2.5
2
1.5
1 Number Number ofResponses 0.5
0 0-19% 20-39% 40-59% 60-79% 80-100%
Source: National Air Quality Regulator surveys
Air quality regulators were asked how many prescribed burns they authorized in the burn season 2014-2015 and asked if this was representative of a typical year. Of the six responses, two regulators reported allocating between one and five burns the previous burn season (2014-2015). Four regulators reported 20 prescribed burns during the previous burn season, with one reporting a total of 2013 and the other reportedly allocated over 500
“agricultural burns”.
All seven respondents answered Question 3. When asked how often (if applicable) they had denied a request from a land manager to conduct a prescribed burn, two respondents stated they had not yet denied a burn and five stated they had denied less than ten percent of the requests. Comments included, “Burns have never been completely denied. Wyoming works 71 with burners and may require a smaller pile or broadcast burn to be conducted in lieu of denying a burn.”
The fourth question in the survey asked the national air quality regulator to rank ten constraints. 15 of 17 respondents completed this question. Concerns about health impacts to people from breathing smoke in a nearby community was the highest constraint, on average 35 percent of all survey participants, followed by concerns about smoke impacts causing exceedance of air quality standards (see Table 7).
Table 7: National Air Quality Regulators Reasons for Denial of Prescribed Burns Standard (n=7) Ranked from 1 -10, with 10 being the least likely reason Mean Deviation Public opinion - Concern about complaints 4.0 3.6 Lack of resources to do smoke modeling or evaluate impacts 6.0 4.6 Fuel loading - too large of a burn/too large for conditions 6.3 2.5 Liability - concerns about escapes 5.0 0.0 Concerns about smoke impacts - exceedance of PM standards 4.0 3.4 Concerns about smoke impacts - exceedance of ozone standards 4.5 1.7 Concerns about health impacts to people in nearby community 1.7 1.1 Lack of adequate outreach to inform potentially affected communities 4.5 3.1 Inadequate alternative treatments or justification for burn 5.0 2.6 Lack of experience or resources to file for exceptional event if needed 6.5 3.5 Source: National Air Quality Regulator surveys
When asked in Question 5 if a prescribed burn had caused impacts to the public, violated air quality regulations or caused an exceedance of air quality standards, all seven participants answered the question. Four stated that they had had burns that they had received complaints about, but only two were reported as health effects from the smoke, one report of exceedances of air quality standards that were traceable to the prescribed burn and one report of violations of regulations (see Figure 26, shown below).
72 Figure 26: National Air Quality Regulators Reports of Prescribed Burns that Created Negative Impacts (n=10)
We have flagged emissions inventory data because 1 of fire impacts
Presscribed burn became wildfire 1
Yes, exceedance of air quality standards that were 1 traceable to the prescribed burn
Yes, violations of regulations 1
Yes, smoke impacts involving health effects to the 2 public
Yes, complaints about smoke impacts, but no severe 4 health effects reported
Source: National Air Quality Regulator surveys
The air quality regulators were asked in Question 6 about their professional relationships with burn permit holders. All seven national air quality regulators answered this question and, like the regional land managers, overall reported the strongest relationships with federal land managers; nearly all relationships were “excellent”. The majority (74 percent) of the national air quality regulators relationships were reported as “good,” or “excellent” (see
Figure 27).
73 Figure 27: National Air Quality Regulators' Professional Relationship with Agricultural Burners (n=28) 4
3 Orchardists Crop Farmers 2 Land Managers (Federal) Land Managers (State) 1 Land Managers (Private)
0 Land Managers (NGOs) Excellent Good Professional Poor Very poor Land Managers (Tribes) relationship relationship relationship relationship relationship (know by (friendly) (no frills) (lack of trust) (adversarial first name) positions)
Source: National Air Quality Regulator surveys
When asked if they would consider their agency as one that is supportive of prescribed burning in Question 7, three of the seven respondents reported that their agency is
“very supportive” of prescribed burning; they attend conferences, meetings, and host events, and say they have a good understanding of the benefits of fire (see Figure 28).
74 Figure 28: National Air Quality Regulators Management Support for Prescribed Burning (n=7)
We do not take position on advocating for burning; we require that all burns meet regulatory 1 requirements
There is little support for prescribed burning 0
Not very supportive, don't allocate much 0 time/worry about smoke impacts
We allocate burning when conditions are faborable, but don't allocate much time to the 1 program and we aren't really focused on the…
The agency is generally supportive 2
Yes, I consider the agency very supportive 3
Source: National Air Quality Regulator surveys
A total of seven respondents answered Question 8, which asked the national air quality regulators about their level of regular collaboration with the public, specifically those communities in which prescribed burning is allocated. The majority (43 percent) of the respondents reported that they really don’t interact and only infrequently attend meetings (see
Figure 29). One respondent answered that they allocate burning when conditions are favorable, but don’t allocate much time to the program, and one other respondent did not take a position.
The remaining two respondents felt their agency was generally supportive.
75 Figure 29: Level of Collaboration Between National Air Quality Regulators and Communities Affected by Prescribed Burns (n=7)
14% No, I don't really interact
43% Every once in a while I will attend a meeting
I live in the community and 43% volunteer, network and collaborate regularly
Source: National Air Quality Regulator surveys
A total of seven respondents answered Question 9, which asked the national air quality regulators about public acceptance of smoke and the need for more education. The results are somewhat split; three of eight of the respondents agreed that if there was more education and outreach, people would have a better appreciation for the need for prescribed burning (and would accept seeing smoke), which would equate to their allocating more burning than currently was allocated. Two respondents stated said it would not change their concerns about smoke impacts, and two others did not think they would be able to allocate any more burning, regardless of the public’s acceptance (See Figure 30).
76 Figure 30: National Air Quality Regulators Opinions About Public Acceptance of Smoke and the Need for More Education (n=7)
I think there is an adequate amount of education 0 currently
I don't think I would be able to allocate any more 2 burning than I do currently, regardless
I think people should be educated, but it wouldn't 2 change my concerns about health impacts
Yes, I think that if people had a better 3 appreciation…I'd be able to allocate more
Source: National Air Quality Regulator surveys
Only one national air quality regulator survey respondent provided suggestions/ comments in Question 10, stating that they did not feel their agency was hindering the allocation of prescribed burning; they believed the impediments were (inadequate) funding and lack of
“manpower” on behalf of the land management agencies.
Discussion of the Findings
The data collected in this study shows diversity among the attitudes and experiences of the participants. Some of the survey participants did not feel that air quality regulations were an impediment to their work, while other participants were highly frustrated by the barriers that air quality regulators created between them and the work they were trying to do. A regional land
77 manager with BLM restated the problem perfectly, “Air district seeks to reduce smoke and the agency seeks to treat maximum acres - not always a happy medium.”
Land Managers Do Not Burn Aggressively Enough in Northern California
Hundreds of thousands of acres in Northern California are in need of fuels management, yet the number of acres that land managers burn each year falls far short of what is needed. While land managers’ counterparts in other parts of the US reported burning on average
85,271 acres per year, regional land managers were reporting burning an average of 1,087 acres per year. National land managers use broadcast burning as the primary method for fuels reduction; 67 percent of the burn acres are treated with broadcast burning, versus 29 percent in piles. In Northern California, the ratio is nearly the opposite, with broadcast burning comprising
31 percent of the burning with the majority (67 percent) of the burning being done in piles.
Based on this study, the USFS manages more land in Northern California than other participants, and their methods (at the regional level) were even more dependent on pile burning than other regional land managers (69 percent pile burning). It will be difficult to increase the pace and scale of prescribed burning in Northern California without committing to a more aggressive approach of fuels management such as what has been adopted in other parts of the country.
The National Land Managers Perception of Constraints
During this study, the findings from the earlier study by Quinn-Davidson and Varner
(2012), which identified narrow burn windows as the highest constraint and air quality
regulations as the second highest constraint on prescribed burning in Northern California, were
validated. This study also surveyed national land managers and found that nationally, narrow
78 burn windows were also ranked as the highest constraint, but lack of adequate funding and lack of adequate personnel tied as the second highest constraint. Further, air quality regulations are ranked as the lowest constraint by national land managers in this study.
The data indicate that air quality regulations are less of an impediment to national air
quality regulators because they are denied a burn less often. When asked if they have a good
working relationship with local air regulators (Question 4), over one quarter (28 percent) of the
national land managers stated that this did not apply to them; they reported that they do not work
with air quality regulatory agencies directly. Some of them reported that they make their own air
quality decisions following the guidelines of their burn prescriptions, and others follow burn day
decisions made by the local fire department. Many (37 percent) of the national respondents felt
that their relationship with air quality regulators was excellent, 19 percent felt their relationship
was pretty good but needed improvement, and 5 percent felt it was okay but strained and
unsupportive. None of the responses indicated an adverse relationship.
When national land managers were asked how often they were denied a request to
burn, of those who did have a need for approval from air quality regulatory agencies, nearly half
(49 percent) of the national respondents stated that they had never been denied a request. Those
national land managers who were denied a burn characterized the reasons for their burn denials
into five categories: meteorological or dispersion issues (50 percent), lack of flexibility or
understanding by air quality regulatory agency (23 percent), fire danger/wildfire drove denial (14
percent), risk avoidance/politics (9 percent), and need for private landowners to be educated (five
percent).
79 Burn Denials - the Driver of Dissatisfaction and Distrust
In contrast to national land managers, the vast majority (69 percent) of regional land managers report having an excellent working relationship with local air quality regulators with similar statistics as the national land managers; 22 percent felt their relationship was pretty good but needed improvement, and 3 percent felt it was okay but strained/unsupportive. One regional land manager said that it depended on the air quality regulatory agency staff with whom they were dealing with and another said that their relationship with air quality regulators was adversarial. When asked how often they were denied a request to burn, unlike their national counterparts, only 16 percent of the regional land managers had never been denied a burn and 60 percent of the land managers stated that less than ten percent of their requests to burn were denied. Four USFS respondents and one USFWS respondent were denied up to 20 percent of their requests, and one USFS respondent was denied up to 30 percent of their requests. Survey respondents were asked to comment as to why they thought their burn was opposed and what they could have done differently. The 21 responses received were analyzed and characterized into three categories: meteorological or dispersion issues (33 percent), lack of flexibility or understanding by air quality regulatory agency (57 percent), and no input or positive feedback
(10 percent).
Air quality regulators did not report burn denials with as much frequency as land managers had reported, but acknowledged that they do deny some requests. When asked how often they deny a prescribed burn request, one (six percent) regulator stated they had never denied a burn, one (six percent) stated they had denied burn requests between 10 and 20 percent of the time, and all but two air quality regulators (88 percent) stated that they had denied a burn less than 10 percent of the time. None of the air quality regulators stated that they denied burn
80 requests in excess of 20 percent of the time. When the seven national air quality regulators who participated in the study were asked how often (if applicable) they had denied a request from a land manager to conduct a prescribed burn, two (29 percent) stated they had never denied a burn and five (71 percent) stated they had denied less than ten percent of the requests. The national land managers did not report denying burns in excess of ten percent of the requests. One national regulator added, “Burns have never been completely denied. Wyoming works with burners and may require a smaller pile or broadcast burn to be conducted in lieu of denying a burn.”
The number one reason regional air quality regulators gave for denying a burn was due to concerns about health impacts to people from breathing smoke in a nearby community.
When prescribed burns do result in complaints from the public, half of those complaints were associated with health effects from the smoke and half of the complaints resulted in exceedances of air quality standards that were traceable to the prescribed burn. One survey respondent commented that because of smoke that triggers health problems such as asthma or chronic lung disease, they call several known individuals within their jurisdiction who have known health issues to advise them of upcoming prescribed burns so they can make plans to protect themselves. This indicates that rather than a lack of understanding, the regulators are advocating for the burn to proceed.
Divergent Perceptions of Impediments
One of the survey questions in this study asked both the air quality regulators and
land managers for their suggestions for reducing prescribed burning impediments. The
differences in these suggestions further illustrates the disparity in perception of what the
81 impediments are. The land managers’ suggestions are provided in Tables 3 and 5 and the air quality regulators’ suggestions are shown in Table 7. Most (28 percent) of the regional land manager’s suggestions to reduce impediments are related to reducing air quality regulatory- imposed impediments (not enough burn days). The most often suggested area for improvement by national land managers was better education to the public and/or public officials, comprising
20 percent of the national land manager suggestions, compared to seven percent of the regional land manager suggestions. Other suggestions from both regional and national land managers included increased funding and trained personnel, support from upper management, more public and political/legislative education and support, and reduction of liability. One USFS survey participant admitted that the USFS was struggling with litigation concerns, adding, “It
(prescribed burning) is not the top priority within the agency.”
Air quality regulators’ perspectives of the impediments varied, but most were supportive of efforts to increase opportunities for the land managers to burn. In their comments about what can be done to improve the ability of their agency or organization to allocate more prescribed burning, two air quality regulators commented regarding a concern about smoke crossing jurisdictions and impacting the public. One regulator was frustrated that smoke from agricultural burns upwind (and outside of their jurisdiction) will negatively impact the prescribed burn projects in their jurisdiction. Three comments reflected a perception that regional land managers were not using their burn windows or requesting enough ignitions and were “limited by factors other than air quality”. One regulator stated that land managers will historically plan a couple of large-scale burns that require a longer burn window and more resources and lose a lot of burn days when the burn windows are shorter. Two air quality regulators identified the importance in collaboration, and one noted that the public is often ignorant regarding the
82 relationship between fuels and wildfire, adding, “Unfortunately, the Smokey Bear ad campaigns were so successful that many people still think that all fire is bad.” One air quality regulator stressed that prescribed burning needs to be a priority and acknowledged as a tool to fight wildfire, and that funding was needed to increase prescribed burning. One air quality regulator pointed out that they thought that the survey was biased toward more burning, stating, “I think regulators should be neutral and not promote burning”. The one comment received from a national air quality regulator was that they did not feel their agency was hindering the allocation of prescribed burning; they believed the impediments were (inadequate) funding and lack of
“manpower” on behalf of the land management agencies.
Support for Collaboration
Literature reviewed in this study reported the value of collaboration, stressing that
public communication as one of the most important components for prescribed burn programs to
be successful. Two of the ten questions in both the land manager and air quality regulator
surveys were asked to evaluate the level of collaboration that were conducted by the agencies
participating in the study and also to determine if their agency’s management supported
collaborative activities. While the majority (41 percent) of the regional land managers regularly
attend meetings, 25 percent of those who completed the survey interacted very little, if at all, in
the communities where they conduct prescribed burning. The lack of collaboration may be
related to the support provided to the regional land managers by their management; just over a
third of land managers (36 percent) who participated in the survey felt that there was a lot of
support for collaborative efforts, with the same percentage agreeing that budget cuts and
83 priorities scaled it back a lot. Ten percent felt that it was no longer a priority, but that it had been in the past, and six percent did not think it was a concern to their agency.
In contrast with their regional counterparts, the majority of national land manager respondents (71 percent) collaborate in some way in the communities where they conduct prescribed burning. Nearly one half felt there was a lot of support for collaboration and one quarter of the land managers agreed that budget cuts and priorities scaled back participation.
Very few reported that they did not think that community involvement was a concern to their agency.
Fiftynine percent of the respondents reported that their agency is “very supportive” of prescribed burning; they attend conferences, meetings, and host events, and say they have a good understanding of the benefits of fire. This is interesting given 60 percent of the regional air quality regulators indicated they really don’t interact and only infrequently attend meetings.
When asked if the public would have a better appreciation for the need for prescribed burning
(and would accept seeing smoke) if there was more education and outreach, 47 percent of the respondents agreed, and 40 percent said it would not change their concerns about smoke impacts.
Fourteen percent believed there should be a focus of education on a specific geographic area to gain political acceptance, which would make a huge difference in their ability to support prescribed burning.
The majority (43 percent) of national air quality regulators reported that their agency
is “very supportive” of prescribed burning; they attend conferences, meetings, and host events,
and say they have a good understanding of the benefits of fire. The same majority (43 percent)
also stated that they don’t interact in communities in which prescribed burning is allocated and
only infrequently attend meetings. The majority (38 percent) of the respondents agreed that if
84 there was more education and outreach, people would have a better appreciation for the need for prescribed burning (and would accept seeing smoke), which would equate to their allocating more burning than currently was allocated. Twentyfive percent said it would not change their concerns about smoke impacts, and 25 percent did not think they would be able to allocate any more burning, regardless of the public’s acceptance.
85
CHAPTER V
SUMMARY, CONCLUSIONS,
AND RECOMMENDATIONS
Summary
The challenges facing both land managers and air quality regulatory agencies are complex, particularly in California. The last century of excluding fire from forests has allowed fuels to build up to the point of becoming an inferno when ignited. These extreme fires threaten to burn at such high intensities as to sterilize whole sections of forest and put lives and property in danger. The population base has increased, and building in the landscape adjacent to wildlands has increased as well, putting even greater pressure on fire agencies and land management agencies to extinguish fires.
Hundreds of thousands of acres in Northern California are in need of fuels management, yet the number of acres that land managers burn each year falls far short of what is needed. While land managers’ counterparts in other parts of the US reported burning on average
85,271 acres per year, regional land managers reported that they were burning an average of
1,087 acres per year. While national land managers use broadcast burning as the primary method for fuels reduction, treating 67 percent of the burn acres with broadcast burning, in
Northern California, only 31 percent of the acres are treated with broadcast burning. It will be difficult to increase the pace and scale of prescribed burning in Northern California without
86 committing to a more aggressive approach of fuels management such as what has been adopted in other parts of the country.
In California, the ARB requires local air quality regulators to oversee the regulation of stationary sources of air pollution and all open burning activities, including prescribed burning. California is the most populated state in the US, with over 37 million people, and its geography and climate negatively affect the creation and dispersion of pollutants. While the majority of air quality regulatory agencies understand the need for prescribed burning as a means of reducing fuels which decreases the potential for a great deal of smoke from a wildfire later, air quality regulators can deny a request to burn due to air quality issues or concerns about impacts to the public. There is great potential for animosity between land managers planning a prescribed burn and the air quality regulators to whom they rely upon for approval for the burn.
Burn Denials - the Driver of Dissatisfaction and Distrust
During this study, the findings from the earlier study by Quinn-Davidson and Varner
(2012), which identified narrow burn windows as the highest constraint and air quality regulations as the second highest constraint on prescribed burning in Northern California, were validated. This study also surveyed national land managers and found that nationally, narrow burn windows were still ranked as the highest constraint, but lack of adequate funding and lack of adequate personnel tied as the second highest constraint. Further, air quality regulations are ranked as the lowest constraint by national land managers in this study. The data from this study indicates that air quality regulations are less of an impediment to national air quality regulators because they are denied burn opportunities less often and believed their impediments were directly related to meteorological or dispersion issues most of the time.
87
Most regional land managers are denied a burn less than ten percent of the time and some are never denied, but a small percentage of the burns are denied more frequently; for one regional land manager in this study, as much as 30 percent of the burn requests were denied.
Regional land managers reported believing that their burn denials were more likely due to a lack of flexibility or understanding by air quality regulatory agency more often than due to meteorological or dispersion issues. Air quality regulators in this study did not report as many denials as what was reported by land managers, and none reported denying burning more than 20 percent of the time. This may be a limitation in the study; only 17 regional air quality regulator surveys were accepted as complete compared to 33 regional land manager surveys. Based on the findings of the study, often it is the experience that the land managers have with one isolated individual that will affect their relationship with the agency.
Divergent Perceptions of Impediments
The number one reason regional air quality regulators gave for denying a burn was due to concerns about health impacts to people from breathing smoke in a nearby community, followed by concerns about smoke impacts causing an exceedance of air quality standards. Half of the complaints that air quality regulators receive from the public regarding smoke were verified to have caused negative health effects or result in exceedances of air quality standards that were traceable to the prescribed burn. Nearly half (43 percent) of the air quality regulators reported that prescribed burns have been found in violation of air quality regulations, including burning without authorization or a permit, not reporting re-ignitions and burning piles with large
88 stumps and dirt (both cause smoldering, sometimes for days, weeks, or even months, depending on the size of the pile).
Land managers in Northern California suggested that increasing number of burn days was one of the top ways that impediments to prescribed burning might be reduced. Air quality regulators’ perspectives of the impediments varied, but most were supportive of efforts to increase opportunities for the land managers to burn. Many regional air quality regulators reflected a perception that regional land managers were not using their burn windows or requesting enough ignitions and were “limited by factors other than air quality”. One regulator stated that land managers will historically plan a couple of large-scale burns that require a longer burn window and more resources and lose a lot of burn days when the burn windows are shorter.
Support for Collaboration
Misunderstandings between land managers and air quality regulators can create distrust and can inhibit the ability of the two groups to work together. While the majority of the regional land managers regularly attend meetings, 25 percent interacted very little, if at all, in the communities where they conduct prescribed burning. The lack of collaboration may be related to the support provided to the regional land managers by their management; just over a third of land managers felt that there was a lot of support for collaborative efforts. The majority of the air quality regulators respondents reported that their agency is “very supportive” of prescribed burning; they attend conferences, meetings, and host events, and say they have a good understanding of the benefits of fire, but most really don’t interact with people in the communities where prescribed burning is planned, and only infrequently attend meetings.
89 Collaboration with air quality regulators and land managers to protect sensitive populations and deliver a consistent and clear message regarding the value of prescribed burning as well as the inherent risks is very important. The work of the land manager and the air quality regulator directly affects both parties; it is in their best interest to support one another. There are many organizations, such as IASC, at a regional level, and NWCG, at a national level, and participation in groups that have a common shared goal, such as a Tree Mortality Task Force, that provide forums for those partnerships to build. It is important to recognize that the work of both the air quality regulator and the land manager also has a great capacity to impact the lives of the public, whether positively or negatively; prescribed burning is a valuable tool but must be respected. To not include the public as a stakeholder in the discussion would be irresponsible.
Attendance at local fire safe council meetings, town hall meetings, wildfire preparedness fairs, and attending field trips and tours on proposed burn units provide for opportunities land managers and air quality regulators to network and share ideas with the communities that they serve.
There are other collaborative efforts already underway. During the preparation of this paper, the California Air Pollution Control Officers Association (CAPCOA), who represents the executive officers of the 35 air quality regulatory offices in California, released their Policy
Statement on Prescribed Burning. This Policy has several recommendations, which are rewritten here as a direct copy of the policy:
1. Air districts are to be recognized as a stakeholder in any proposals to increase the
pace and scale of prescribed fire; 2. Air districts, ARB, land managers, and other
stakeholders should continue discussing opportunities to increase prescribed burning
through better use of technology, including modeling software, traditional portable
90 air quality monitoring, or newer low cost sensor technology; 3. Air districts,
especially rural air districts with minimal staffing, should receive financial,
equipment, and training support to allow for increased staffing as the use of
prescribed fire increases; 4. Continues and expanded funding for woodsmoke
reduction programs can reduce the daily emission load from home wood heating,
which would allow for expanded burn windows; 5. Land managers and stakeholders
should increase outreach to communities affected by wildfire and prescribed fire to
increase public understanding and acceptance of prescribed fire.
Conclusions
Burn Denials - the Driver of Dissatisfaction and Distrust
This study has identified that regional land managers, particularly those with the
USFS, believed that their burn denials were more likely due to a lack of flexibility or understanding by air quality regulatory agencies more often than due to meteorological or dispersion issues. On average, all of the land managers ranked air quality regulations as the second greatest impediment to prescribed burning.
In contrast, national land managers viewed burn denials as a consequence of poor dispersion or weather conditions and ranked air quality regulations as the lowest impediment to prescribed burning.
Air quality regulators were mostly supportive of efforts to conduct prescribed burning, understood its benefits, and were empathetic to the needs of the land manager. The concern that was raised by the regulators was related to the protection of public health from the
91 smoke that resulted from the burn. Provided that a burn decision was not likely to negatively impact public health, the air quality regulator was unlikely to deny a request to burn.
Divergent Perceptions of Impediments
While regional land managers felt that they would improve their ability to burn the most if they were provided additional burn days, many regional air quality regulators reflected a perception that regional land managers were not using their burn windows or requesting enough ignitions and were “limited by factors other than air quality”. One regulator stated that land managers will historically plan a couple of large burns that require a longer burn window and more resources and lose a lot of burn days when the burn windows are shorter.
Air quality regulations may be perceived as an impediment to prescribed burning, but this does not necessarily have to be viewed negatively. Air quality regulations protect public health, and although land managers in some other states do not deal directly with an air quality regulatory agency, they still need to consider the effect that the smoke generated from a prescribed burn would have on a downwind population. The difference is that they are the ones making the decisions rather than an outside agency. It is clear that to the regional land manager, the impediment that appears to be the barrier is the air quality regulator, whereas the impediment is actually meteorology/dispersion.
Support for Collaboration
It will be difficult to increase the pace and scale of prescribed burning in Northern
California without committing to a more aggressive approach of fuels management such as what has been adopted in other parts of the country. To be able to coordinate an effort to increase
92 prescribed burning in Northern California, it is essential that land managers and air quality regulators increase their capacity to collaborate. Most of the survey respondents in this study recognized the strength of the positive relationships with the other agency, and many were sensitive to one another’s position. There were some respondents who reported negative experiences, and this diminished their opinion of the other group as a whole. There is capacity for land managers and air quality regulators to learn to be more collaborative, which will reduce the distrust and animosity and increase the levels of cooperation between the groups.
Land managers and air quality regulatory agencies have been involved in collaborative groups since the 1970s, and continue to find innovative ways of communicating the group’s collective needs, increasing their capacity. Successes such as the use of Air Resource
Advisors during wildfire events and collaborative work on revisions to a widely used “Smoke
Management Guide for Prescribed Fire,” are examples of how these groups can contribute to the community as a whole. More recently, the CAPCOA Policy on Prescribed Burning, described above in the Summary, shows a commitment to increasing the pace and scale of prescribed burn projects while protecting public health and reducing emissions through public outreach and funding for woodsmoke reduction programs, increased levels of staffing and training, and better use of technology, including modeling software, air quality monitoring and sensors.
Opportunities for land managers and air quality regulators to develop collaborative skills such as the CAPCOA Policy on Prescribed Burning demonstrates the power of collaborative action, which over time, will continue to build the strength of the relationship between land managers and air quality regulators.
93 Recommendations
Burn Denials - the Driver of Dissatisfaction and Distrust
Air quality regulations protect public health, and air quality regulators are tasked with considering the effect that the smoke generated from a prescribed burn has on a downwind population. One of the drivers of trust and misunderstanding is a lack of foundational knowledge. The ARB has taught a smoke management course in the past that provided a forum for new air quality regulatory staff to learn about prescribed burning and interact with the land managers within their jurisdiction. The class has not been taught in over ten years. If ARB does not intend to teach the course, air quality regulators and land managers could design their own course and meet together to discuss the nature of their work. This would go a long way to initiating an interest in collaboration.
One of the trainings that a course described above could include is information on air pollution modeling and transport. Air quality regulatory agencies and land managers could learn the models together and be able to truly “talk the same language” when decisions are made later regarding a burn plan or prescription. These kinds of trainings directly assist in alleviating the constraint of burn denials as a driver of dissatisfaction because decisions about a burn approval could be made with more certainty.
Divergent Perceptions of Impediments
Trying to reduce potential fire effects from fuels that have built up from a century of fire suppression is a tremendous task. Budgets that are stretched thinner and thinner with every wildfire make it difficult to try to plan on taking future action with any certainty. In this study,
94 regional land managers believed that they would benefit from additional burn days, while air quality regulators were frustrated that the land managers were not making use of available burn days already. While air quality regulators have some understanding about the impediments placed on land managers, many may not have a clear understanding of what goes into the burn plan, which often takes months or even years to develop. Many air regulators never see these burn plans and cannot appreciate all of the considerations that must be made long before a burn request is made. Air quality regulators and land managers who have a full understanding of the constraints on both groups will work more cooperatively with one another and will be less likely to have a presumption about the other’s intent.
Support for Collaboration
This study identified that most air quality regulatory respondents felt that management strongly supported their collaborations but that they rarely went to the communities where burning was to occur. On the other hand, land managers reported diminished support for collaborative efforts, but still were quite active in their communities. It is essential that management support their staff, especially from smaller regulatory agencies or land management agencies, to regularly engage with others. Collaborative efforts will help the two groups to focus on their shared goals rather than the differences between them. Open and frequent communication will, over time, build trust and respect. Opportunities to engage already exist, whether it is a Fire Safe Council meeting or a training conference, an annual meeting or quarterly conference call with a collaborative group such as NWCG or IASC, or a tour of the prescribed burn unit that is being planned. All of these forums provide a chance to interact, engage, and get to know one another, which ultimately benefit all.
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106 APPENDIX A: SURVEY INSTRUMENTS
1. What is the structure of the organization? Who makes burn decisions and what is the flow of the process? Do you understand the structure of the other entity’s organization? (example: if interviewing an air quality regulator, I would ask if they understood the structure of the Forest Service’s organization). 2. How well does the air quality regulator know land managers within his or her district and vice versa? Have you been to any events/workshops/conferences with them? Have you ever gotten to know one another personally? If it were the weekend, would you know how to get in touch with someone from the other organization? 3. Have there been any issues between the organizations? If yes, what were they? What could have been done differently (both sides)? 4. Do you trust and/or respect the land manager/air district regulator with whom you work with? Do you think that they are transparent and/or consistent? If yes, why? If not, why not? Do you think that they trust and/or respect you? Why/why not? 5. Do you think that your organization is transparent and/or consistent? If yes, why? If not, why not? How do you think your organization is perceived by the other? Why? 6. Do you think that you have a positive relationship with the communities in which you work? If yes, why do you think so and what are you doing to continue to promote that? If no, do you have ideas as to how you might improve the relationship (if even desired)? 7. Is there anything that you wish was different or that you think would make your ability to get your job done more efficiently (as it relates to fuels reduction)? 8. Do you think that air quality regulations are a constraint to getting prescribed burning done? Why or why not? 9. Why did you get into your line of work? 10. What is your favorite part of your job? Why? Least favorite? Why?
107 APPENDIX B-1: INTERVIEW CONSENT FORM Scott Stephens
108 APPENDIX B-2: INTERVIEW CONSENT FORM Christine Eriksen
109 APPENDIX B-3: INTERVIEW CONSENT FORM John Kennedy
110 APPENDIX B-4: INTERVIEW CONSENT FORM Jeremy Strait
111 APPENDIX B-5: INTERVIEW CONSENT FORM Mike Broughton
112 APPENDIX B-1: INTERVIEW CONSENT FORM Ann Hobbs
113 APPENDIX C-1
Land Managers Interview Questions, Mike Broughton and Jeremy Strait
Structure of organizations: 1. What is your job title and how does your job affect a burn decision?
2. In order to get approval for a burn, what does you organization have to do? Please list the steps in order. If it isn’t known to you or isn’t clear, please state so.
2. Would you say that your organization is set up to perform the maximum amount of burning on a burn day, or do you see limitations on the amount of burning that can be done? If there are limitations, what are they?
Relationships with regulatory agencies: 3. Do you have a working relationship your local air district? What is the name of the person with whom you file a smoke management plan with?
4. Do you think that air quality staff try to understand “your side”? Do they attend conferences, meet with you and/or try to help you achieve your burning goals?
5. Do you have a way of getting in touch of your air district/staff after hours? Would they be available to you?
6. Have you ever been denied a burn request or asked to extinguish a burn? If yes, why and what happened? Any other issues?
7. Do you think that your experience is similar with or different than other agencies like yours? Why or why not?
Relationship with the public: 8. Do you think that you have a positive relationship with the communities in which you work? If yes, why do you think so and what are you doing to continue to promote that? If no, do you have ideas as to how you might improve the relationship?
9. Do you get information on people sensitive to smoke (elderly, health issues, etc.) who live in the communities near where you burn? If yes, where do you get that info and do you let them know when you are burning? If yes, how do you do that?
10. Has your organization ever worked with an air district or other agency to conduct informational or town hall-type meetings to let a community know about a pending prescribed burn project? Would you support such efforts?
114 APPENDIX C-2
Air Regulator Interview Questions, John Kennedy
1. Do you think that policies need to change in order to allow for more prescribed burning?
2. How do you think that EPA can help make the process for exceptional events less cumbersome?
3. What can you tell me about changing PM2.5 and Ozone values? There is a perception that regulators only care about numbers and don’t understand the on-the-ground experience. Would you say this is fair?
4. At a recent conference I was at, a presenter commented several times that the Clean Air Act was a flawed law. Tell me what you think about this/tell me more about the Clean Air Act to explain why the presenter might think this.
115 APPENDIX C-3
Air Quality Regulator Interview Questions, Ann Hobbs
Structure of organization: 1. What is your job title and how does your job affect a burn decision?
2. In order to give approval for a burn, what does you organization have to do? Please list the steps in order. If it isn’t known to you or isn’t clear, please state so.
2. Would you say that your organization is set up to perform the maximum amount of burning on a burn day, or do you see limitations on the amount of burning that can be done? If there are limitations, what are they?
Relationships with land managers: 3. Do you have a working relationship your land managers?
4. Do you think that land managers understand “your side”? Do they attend conferences and meetings that are collaborative in nature?
5. Do you have a way of getting in touch with land manager staff after hours? Would they be available to you?
6. Have you ever denied a burn request or asked to extinguish a burn? If yes, why and what happened? Any other issues?
7. Do you think that your experience is similar with or different than other agencies like yours? Why or why not?
Relationship with the public: 8. Do you think that you have a positive relationship with the communities in which you work? If yes, why do you think so and what are you doing to continue to promote that? If no, do you have ideas as to how you might improve the relationship?
9. Do you get information on people sensitive to smoke (elderly, health issues, etc.) who live in the communities near where you burn? If yes, where do you get that info and do you let them know when burning is taking place? If yes, how do you do that?
10. Has your organization ever worked with a land management agency to conduct informational or town hall-type meetings to let a community know about a pending prescribed burn project? Would you support such efforts?
11. You’ve requested Exceptional Events exemptions for your air district recently; tell me about your experience in submitting the paperwork/requests.
116 APPENDIX C-4
Academics Interview Questions, Scott Stephens and Christine Eriksen
Questions for Dr. Stephens:
1. Do you think that the fire suppression myth is really a myth? (Chaparral Institute blog)
2. (In referencing the research that Dr. Stephens did with Neil Sugihara regarding California Native Americans’ fire use): Do you think that we have romanticized Native Americans and their use of fire? Are we (modern people) really that much different? (altering our landscape to suit our needs)
3. Topics of discussion:
a. Budgets – general
b. Urban interface – is it valid that the problem is people moving into the WUI or would fires have become more intense/larger regardless?
c. Climate Change – how do you think climate change has affected our forests and what do you think about sequestering carbon?
Questions for Dr. Eriksen:
1. (After discussing the article in the New Yorker by Max Moritz, UC Berkeley regarding flood damage) You have been doing research in the US on the Oakland Hills firestorm. Land use regulations and building codes could help keep people safe by keeping them from building in fire prone areas or by requiring that builders construct the homes with materials that are fire resistant (high hazard zone classifications, established after Oakland fire, exist because of the Oakland Hills fire). What are your thoughts on the impacts of land use regulations and building codes?
2. Tell me about some of the work that you have done recently regarding wildfire preparedness and community cohesion. 3. What can you tell me about risk reduction in bushlands and how it can be applied in the US? Are the issues similar or different? And can we learn from what successes you’ve seen in Australia? What are they?
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APPENDIX D-1
Land Manager Surveys - Question 1
118
APPENDIX D-2
Land Manager Surveys - Question 2
119 APPENDIX D-3
Land Manager Surveys - Question 3
120 APPENDIX D-4
Land Manager Surveys - Question 4
121 APPENDIX D-5
Land Manager Surveys - Question 5
122 APPENDIX D-6
Land Manager Surveys - Question 6
123 APPENDIX D-7
Land Manager Surveys - Question 7
124 APPENDIX D-8
Land Manager Surveys - Question 8
125 APPENDIX D-9
Land Manager Surveys - Question 9
126 APPENDIX D-10
Land Manager Surveys - Question 10
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APPENDIX D-11
Air Quality Regulator Surveys - Question 1
128 APPENDIX D-12
Air Quality Regulator Surveys - Question 2
129 APPENDIX D-13
Air Quality Regulator Surveys - Question 3
130 APPENDIX D-14
Air Quality Regulator Surveys - Question 4
131 APPENDIX D-15
Air Quality Regulator Surveys - Question 5
132 APPENDIX D-16
Air Quality Regulator Surveys - Question 6
133 APPENDIX D-17
Air Quality Regulator Surveys - Question 7
134 APPENDIX D-18
Air Quality Regulator Surveys - Question 8
135 APPENDIX D-19
Air Quality Regulator Surveys - Question 9
136 APPENDIX D-20
Air Quality Regulator Surveys - Question 10
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