We first caught wind of this move at the Northern California Prescribed Fire Council conference in early December. Briefly, the EPA is proposing to tighten the existing ground-level ozone standards from 75 ppb (parts per billion) to 65-70 ppb while taking comment on a 60 ppb level.
The prescribed fire community was very alarmed about this development. Experts explained that pine forests are naturally-high ozone environments. Pine trees emit volatile organic compounds (VOCs) that catalyze ozone production at ground level. With the pine trees pushing the local atmosphere beyond the EPA’s saturation limit, prescribed fires would not be allowed. Since prescribed fire is a major tool in the toolbox for reducing fuel loads, this will result in even greater fire hazards if implemented.
CCFA board members Cate and Eric Moore attended the EPA’s Sacramento hearing on the topic on February 2, along with Southern Sierra Prescribed Fire Council member Karina Silvas-Bellanca. Karina and Eric were testifying about the impacts the new standard would have on fuel management and ecological restoration in California forests. The EPA wasn’t expecting that one. Briefly, the points Eric made were:
The earliest Europeans to come to California, such as Fray Juan Crespi, recorded large amounts of fire on the landscape.
Scientific studies show that before the arrival of the Europeans, an average of 10% of California burned every year. The majority of these fires were set by humans, who were doing this since the close of the last Ice Age.
These frequent fires created a fire-dependent ecology in California.
Many plants such as the fire poppy and the California lilac, and the animals that feed upon them, only thrive after fires.
Many of California’s rare and endangered species need fire to survive. These species started going into decline as modern fire suppression policies were introduced.
Both of California’s redwood species are pyrophytes whose seeds germinate best after a fire.
Modern fire suppression’s legacy is that California currently has the largest fuel load of the last 12 thousand years.
Firefighting agencies are increasingly unable to suppress large fires due to this legacy fuel load.
This is demonstrated by the current megafires such as the “Rim” fire and their massive impacts on air quality.
These fires can also sterilize large tracts of land and eradicate endangered plant and animal populations.
The only practical way to restore fire to the ecosystem and enhance the survivability of these endangered plants and animals is through the use of controlled burns.
Controlled burns are also the only way that catastrophic air quality impacts from megafires can be mitigated.
For these reasons, controlled burns need to be considered as part of the natural background levels in this regulation.
Should the EPA choose not to do so, the agency must accept the liability and the responsibility for forcing many of California’s rare and endangered species closer to extinction.
While we were there, we heard other parties voice their objections and learned that:
- Most of the country is not in attainment of the current standard.
- Much of the ozone that is fueling this controversy is coming from outside the state, even as far away as China.
- If everyone in the Central Valley turned off all their electricity and hid in their houses without driving anywhere, the valley still could not achieve attainment.
- The EPA is not using their monitoring stations and their software correctly. (This one from the developer of said monitors and software.)
All in all, the EPA is cramming another ill-conceived, unachievable, one-size-fits-all standard down our throats. CCFA has chosen to submit their comments to the EPA in a letter. CCFA to EPA re Proposed Smog Standards 3
We urge you to weigh in with your thoughts. Instructions are below.
How to Comment on EPA’s Proposal to Revise the Ozone Standards
EPA will take written comment on the proposed standards until March 17, 2015. Be sure to reference Docket ID number:
Comments may be submitted by one of the following methods:
- Federal eRulemaking portal: Follow the online instructions for submitting comments
- Email A-and-R-Docket@epa.gov: Include docket ID No. EPA-HQ-OAR-2008-0699 in the subject line of the message
- Fax: Fax your comments to: 202-566-9744.
- Mail: Environmental Protection Agency, EPA Docket Center (EPA/DC), Mailcode 28221T, Attention Docket ID No. OAR–2008-0699, 1200 Pennsylvania Avenue, NW., Washington, DC 20460.
- Hand Delivery or Courier: Deliver your comments to: EPA Docket Center, Room 3334, 1301 Constitution Ave., NW, Washington, DC, 20460. Such deliveries are only accepted during the Docket’s normal hours of operation, and special arrangements should be made for deliveries of boxed information.
Download and print instructions on How to Comment (PDF)