June 25, 1999




Dear Madam or Sir:

The California Air Resources Board (ARB or Board) invites you to participate in workshops to discuss draft language to revise the regulation governing agricultural burning, as part of our overall effort to improve California's smoke management program. Agricultural burning refers to the intentional use of fire for vegetation management - in areas such as agricultural fields, orchards, and wildlands like rangeland and forests.

Smoke Management Workshops

July 14, 1999 July 20, 1999
10 a.m. - 1 p.m 1 p.m. - 5 p.m.
Redding Elks Lodge San Joaquin Valley District Office
250 Elk Drive Governing Board Room
Redding, California 1990 E. Gettysburg Avenue
  Fresno, California

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July 15, 1999 Video-Teleconferencing Locations for
July 20, 1999 Fresno Workshop:
10 a.m. - 1 p.m. San Joaquin Valley District Offices
ARB Offices 4230 Kiernan Ave., Suite 130
Hearing Room, Lower Level Modesto, California
2020 L Street 2700 M Street, Suite 275
Sacramento, California Bakersfield, California

The draft regulation will be posted on our website at http://www.arb.ca.gov by July 1, 1999 for review prior to the July workshops. Copies are also available by contacting Susan Paul at (916) 322-6048. If you would like to offer written comments on the draft version of the regulation, please submit them to Mr. Don McNerny, Chief, Modeling and Meteorology Branch, by July 30, 1999. We will release the proposed version of the regulation and a Staff Report on September 10, 1999 for the formal public comment period. The Board will consider this item at a public hearing on October 28-29, 1999 in Sacramento. Although this is an accelerated schedule, we intend to work closely over the next several months with the regulated community, the air pollution control districts (district), and the public to ensure our proposal represents the most efficient and effective approach to improving air quality by strengthening the smoke management program statewide. We encourage your input throughout this process.

The workshops on the draft regulation are the next step following seven regional meetings this Spring on a preliminary concept paper. Over 400 participants attended and many sent written comments as well. Most of the comments we received can be summarized into four major points: (1) revisions to the regulations should avoid creating a new regulatory authority like the proposed Regional Burn Centers; (2) the proposed regional "cap" described in the concept paper is unworkable based upon the level of technical data currently available to districts; (3) non-burn alternatives need to be considered if health impacts are to be reduced; and (4) the program improvements should be sensitive to resource limitations in the districts and regulated community. In response, we re-evaluated the initial concepts and have modified our approach to address these concerns.

  • Regional Burn Centers. While regional coordination of burn events is a necessary part of effective smoke management, the draft regulation would enable each district or group of districts (rather than a required Regional Burn Center) to tailor their own programs to achieve the desired objective.

  • Regional Cap on Burning. Rather than a quantitative cap on the total amount of burning within each area, the draft regulation would instead require the district to develop an allocation system that considers the timing, location, and number of individual burns. ARB would continue to identify burn and no-burn days, while districts would make decisions on the extent and location of burns within their region on burn days.

  • Alternatives to Burning. The draft regulation would specify that district smoke management programs must identify how non-burn alternatives will be considered. In addition, approval of burn applications would require burners to address actions taken to minimize smoke impacts. Within the Staff Report, we will discuss other mechanisms to encourage alternatives where feasible.

  • Need for Additional Resources. ARB recognizes that program improvements will require more resources and is committed to working with affected parties to develop an electronic burn tracking system for use by agencies and the public statewide. This system would enhance a district's ability to manage burn decisions, provide a mechanism for coordination with neighboring regions, and allow the public access to timely information on burns so sensitive individuals could plan or act accordingly.


If you have any questions or would like to discuss the smoke management program improvements, please contact me at (916) 322-5350 or Don McNerny at (916) 322-6048.
Sincerely,

Terry McGuire, Chief




Planning and Technical Support Division


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