Wildfire vs. Man-Caused Fires
The potential for hazardous wildfires exists throughout the West. Two management tools – prescribed burns and wildland fire use, or the management of naturally caused wildfires – pose a problem because they also contribute to smoky skies and regional haze.
So, the dilemma is:
How to decrease the potential for wildfires while keeping smoke from preventive measures -- prescribed burns and wildland fire use -- within the bounds that meet the goals of reduced emissions under the Clean Air Act’s Regional Haze Rule?
The Western Regional Air Partnership, or WRAP, has a series of goals, plans and materials designed to help states and tribes develop their own approaches to first quantify the impacts from smoke and fire of all kinds and then to work toward reductions. The approaches include:
Annual Emission Goals
Fire Tracking Systems
Smoke Management Plans
These approaches deal in varying ways with 4 types of fires:
Wildfire – Natural, unwanted, nonstructural fire. Tracked, not counted in emission goals
Wildland Fire Use – Wildfire managed for resource objectives. Uses naturally ignited fires to gain specific, pre-stated federal resource management objectives in defined geographic areas.
Prescribed Fire – Fire ignited to meet specific management objectives. Fire is confined to a predetermined area and managed to attain fire treatment and resource management objectives.
Agricultural Fire – Fire ignited for specific objectives on agricultural land.
WRAP’s Proposed Approaches to Dealing with Fire
Annual Emission Goals – Key Points
• Don’t address wildfires, which cannot be directly controlled.
• Requires annual emission goals for fire other than wildfire so that emissions are minimized as much as possible. (e.g. agricultural and prescribed fires)
• Must be set by states or tribes or the designated authority in cooperation with federal land management entities and private entities on a yearly basis.
• Do not apply to Native American cultural nonvegetative burning for ceremonial or related purposes, or to residential, commercial or industrial open burning, although these types may be considered when states and tribes address impacts.
Fire Emission Tracking Systems
• Tracking Systems used for:
--calculating fire emissions and assessing impacts from emissions;
--verifying whether emission reductions are occurring – in line with the Regional Haze Rule’s call for tracking changes in emissions of visibility-impairing pollutants; and
--standardizing information-gathering for improved regional purposes.
States choosing to file under Section 309 of the Rule must adopt such tracking systems and tribes may adopt them. The Western Regional Air Partnership has developed policies to help implement this provision.
States filing under Section 308 will find that a tracking system meets several Regional Haze Rule requirements, including: a statewide inventory of emissions from pollutants, emissions information that is part of a long-term strategy showing reasonable progress in reducing emissions, and the identification of man-caused sources of visibility impairment.
• Tracking Systems to include: date of burn, burn location, area of burn, fuel type, a calculation of the weight of fuel per unit area in tons per acre (pre-burn fuel loading), the type of burn, and whether the burn is man-caused or natural.
Smoke Management and Enhanced Smoke Management Plans
• Required under Section 309 and a helpful tool for addressing smoke if states filing under Section 308 see fire emissions as impairing visibility.
•The Enhanced Smoke Management Plan addresses 9 elements: actions to minimize emissions from fire, evaluate smoke dispersion, alternatives to fire, public notification of burning, air quality monitoring, surveillance and enforcement, program evaluation, burn authorization and regional coordination.
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For more information, visit the WRAP Website: or contact WRAP co-directors:
Pat Cummins at the Western Governors’ Association (303) 623-9378 or
Bill Grantham at the National Tribal Environmental Council (505) 242-2175