Twenty-five Democratic congressional leaders from California sent U.S. Environmental Protection Agency Administrator Michael Regan a June 13, 2023, letter expressing concern that a proposed rule to strengthen the national ambient air quality standard “could inadvertently hinder the ability of land managers to deploy prescribed fires that help California avoid the larger catastrophic wildfires that more significantly pollute the air and threaten public safety.”
We applaud Senator Padilla’s leadership in sending this message and the thoughtful recognition of the importance of prescribed fire in reducing future wildfire risks, including air quality.
Tall Timbers has worked on this issue since the EPA announced the proposed rule to strengthen the national ambient air quality standard in January 2023. Our original article on this subject, including background information, our concerns regarding the Exceptional Events Rule, and our March 2023 comment letter to the EPA, is included below.
California Congressman Doug LaMalfa (R) and Utah Congressmen John Curtis (R) were both early supporters of the need to check air quality standard impacts on the use of prescribed fire. Both have been very cooperative to work with as we seek solutions, and they will continue to be key partners.
The new letter from Democratic congressional leaders marks an important shift to bipartisan support for making sure that proposed air quality regulations don’t get in the way of the need for a nationwide expansion of prescribed fire use.
The new letter also importantly calls out the EPA’s Exceptional Events Rule as “unworkable for the scale of prescribed fire that will be necessary to protect our communities from increasingly catastrophic wildfires.” The Exceptional Events Rule process allows you to apply and seek approval for the smoke from a fire to be removed from pollution totals used for regulating. Some of our western state partners have viewed Exceptional Events as a potential pathway to continue beneficial fire use. However, Tall Timbers opposes this approach in its current form, as it places additional regulatory burdens on private conservationists who utilize prescribed fire.
We thank Matt Weiner of the California-based nonprofit Megafire Action for cooperating with Tall Timbers and for his input on this important letter.
Air quality proposal threatens prescribed fire use
A proposed tightening of federal clean air standards fails to provide a pathway to maintain the current use of prescribed fire and the widely accepted need for more prescribed fire. Tall Timbers is monitoring the issue closely and delivered a letter with potential solutions to the United States Environmental Protection Agency (EPA) in late March 2023.
Tall Timbers is dedicated to addressing this issue and continuing our role as an advocate for prescribed fire use on private and public lands. In addition, we have deployed new air quality research in Southwest Georgia and are raising funds to support science focused on smoke management and air quality. This will be a long-term issue, and Tall Timbers is ready to lead with applied science and practical land management.
This topic emerged over the past few months when the EPA proposed revising the annual PM 2.5 standard from 12.0 µg/m3 to within the range of 9.0 to 10.0 µg/m3. These fine particles measuring less than 2.5 micrometers in diameter are released by various sources, including power plants, factories, diesel trucks, farming practices, and fires—both wild and prescribed. PM 2.5 is so tiny that it can enter the lungs and bloodstream, contributing to asthma, heart attacks, and strokes.
As a conservation and science organization, Tall Timbers ardently supports clean air and reducing human-induced pollutants for human health benefits. However, the proposed rule regarding PM 2.5 is an overly simplistic approach to a complex situation that will result in unintended negative consequences for human health, safety, the environment, and the economy.
Wildfires have become a significant source of air pollution, including PM 2.5. Across federal land management agencies and the broad scientific community, the consensus is that the US needs more prescribed fire to address the wildfire crisis fueled by decades of fire suppression and a changing climate. Yes, it’s complicated that more prescribed fire—a source of PM 2.5—is needed to help address wildfires and their more significant threat to air quality and human health. That is why Tall Timbers calls for investment in prescribed fire air quality research and the development of best practices and technology to help further reduce the impacts of prescribed fire smoke without reducing its beneficial use.
Some of our prescribed fire partners are looking at the “Exceptional Events Rule” process as a potential pathway for maintaining beneficial fire use. This process allows you to apply and seek approval for the smoke from a fire to be removed from pollution totals used for regulating. While the Exceptional Events process may be helpful in some western states dominated by public lands, the current reality is that private landowners lead prescribed fire in the US. Estimates indicate that 65% of all prescribed fire is ignited on private lands, making Exceptional Events Rule filings a significant burden for these individual private landowners. Tall Timbers strongly opposes any regulation that places such burdens on private conservationists.
Tall Timbers will continue to provide updates on this emerging and evolving issue. Please contact us if you have questions or want to contribute to our current effort to expand smoke and air quality research in the Albany and Red Hills regions.
Read the complete March 28, 2023 letter from Tall Timbers to the EPA.
