Wildland Fire Management Plan Craters of the Moon National Monument XV. Air Quality/Smoke Management

A. Issues

The Craters of the Moon Wilderness Area is a mandatory Class I air-shed under the Federal Clean Air (CAA). Sections 160-169 of the Act establish a program to Prevent Significant Deterioration (PSD) of air quality in "clean air areas" of the country (i.e., attainment areas), which include Class I areas. Among the purposes of the PSD program are "to preserve, protect and enhance air quality in national parks, monuments, national seashores, and other areas of special national or regional natural, recreational, scenic or historic value." Congress provided additional protection for Class I areas in Section 169A of the Clean Air Act, which specifies a national goal of "remedying any existing and preventing any future manmade visibility impairment" in these areas.

The Federal Government has granted responsibility and authority to establish air quality standards and regulations to States. All NPS units are required to comply with the National Ambient Air Quality Standards (NAAQS) both inside and outside unit boundaries, and protect visibility in Congressionally-mandated Class I unit areas.

NPS fire management activities which result in the discharge of air pollutants (e.g., smoke, carbon monoxide, and other pollutants from fires) are subject to, and must comply with, all applicable Federal, state, interstate, and local air pollution control requirements, as specified by Section 118 of the Clean Air Act, as amended (42 USC 7418). These requirements are the same substantive, procedural, and administrative requirements that apply to a private person or other non-governmental entity. The U.S. Environmental Protection Agency issued Interim Air Quality Policy on Wildland and Prescribed Fires in 1998. Fires that occur in the wildlands (generally undeveloped areas such as forests, grasslands,etc.) fall into two categories, (1) planned or prescribed fires which are purposely started to meet specific land management objectives, and (2) wildland fires which are all other non-structural fires in the wildlands, including unwanted wildfires. EPA's interim policy applies to both wildland and prescribed fires that are managed to benefit resources or the environment. Under EPA's Policy, Federal prescribed fire projects would be considered to conform with the state implementation plan if they are managed under a certified basic smoke management program. The program must require regional coordination (cooperation of all jurisdictions in an airshed) when authorizing fires and real-time air quality monitoring at sensitive receptors, when warranted, in addition to the basic program components.

As this plan was prepared a number of air quality monitoring programs have been in place at CRMO. Those that relate to wildland fire emissions include, particulates (PM10 and PM 2.5), and ozone. Particulate samplers (part of the IMPROVE Network) do not provide "real-time" output of particulate levels but can be referenced post-fire to determine levels reached during particular fire events. The ozone monitor can provide "real-time" information on ozone concentrations (preliminary non-validated data).

Predictive models of smoke emissions and dispersion are run in Stage III of the individual Wildland Fire Implementation Plan (Implementation Procedures and Reference Guide for the Wildland and Prescribed Fire Management Policy). Stage III is usually developed within 48 hours of fire detection. In some small fire situations Stage II implementation actions are determined to be adequate. This determination is made through a Stage III Needs Assessment based upon relative risk (fire size, season, fire danger indicators, and potential complexity). Air quality values are one complexity element factored into the needs assessment. Results of smoke model predictions will be shared with the Idaho Department of Environmental Quality.

Smoke sensitive areas include; the monument headquarters complex, the communities of Arco or Carey , the Idaho National Engineering and Environmental Laboratory or visibility impairment of highways or the Class I area (wilderness).

B. Coordination with the State

CRMO will coordinate on smoke management issues with the Idaho Department of Environmental Quality and conform with the requirements of the South Idaho Cooperative Smoke Management Plan. The South Idaho Cooperative Smoke Management Plan is currently a voluntary program which emphasizes spring and fall prescribed burning. The program is being expanded to include smoke emissions from wildland fire use. The NPS will stay informed on the program's development to comply with its recommended actions.

C. Air Quality Management Objectives

When wildland fires are managed as Wildland Use Fires the following objectives will apply;

1. Smoke levels along Highway 93 should not decrease visibility below one mile.
2. Smoke levels in the immediate area of the Headquarters complex should not cause visibility to drop below 5 miles for more than 24 consecutive hours.
3. Visibility from Big Craters should not obscure a vista of Big Southern Butte or Echo Crater for more than 7 consecutive days. During any fire season there should be no more than two seven day periods in which this visibility threshold is exceeded.
4. NAAQS should not be exceeded and the South Idaho Cooperative Smoke Management Plan guidelines should be followed.
5. Following any wildland fire managed as WFU, data on particulate levels will be obtained for those fire days if available.

If these objectives are not met (or are predicted to be exceeded) a wildland use fire will no longer meet air quality objectives and appropriate management response will be initiated to achieve the objectives. These responses may vary but can include full suppression actions.