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The following letter was written by Alabama Forestry Commission State Forester Timothy C. Boyce to each of Alabama's nine Congressmen. The letter was dated April 8, 1998. Boyce can be reached at P. O. Box 302550, Montgomery, AL 36130-2550 - - - (334) 240-9300
Dear ..... :
The Environmental Protection Agency recently established a "Wildland Fire/Air Quality" policy. This was in response to the U.S. Forest Service's plans to significantly increase the amount of prescribed burning in the Western United States. The action has potential for extreme hardships on the small private landowner in Alabama and the Southeast in general.
It is common for western wildland fires to get out of control and do major damage to the timber resource, environment, wildlife habitat, structures, and cause a variety of smoke related problems. One answer to the problem is to prescribe burn, which means to burn under a set of controlled conditions. The Southeast has utilized this valuable tool for years with little or no problems associated directly with the fire or the smoke that it produces.
The new EPA policy, which came into effect because of the Western initiative, calls for several measures that are difficult to achieve and/or expensive. Our landowners see no need for our currently successful practice to be limited by a need that is specific to another part of the United States.
One of the measures we oppose is the requirement for the burning plan for each outdoor burn over a specified size or quantity of fuel. Alabama issues around 30,000 permits per year for approximately one million acres. The requirement of a plan for each of these burns would be unreasonable. Who will write these plans, who will approve them, who will measure the fuel load, and who will monitor compliance?
Each burning plan must be authorized for implementation only after considering its relationship to other burns within the identified "airshed." Who will identify the "airshed" and make the determination of who may and may not burn at a specific time? I assume it is the government probably this agency. Where will the funding and manpower come from? The original EPA standard for particulate matter was 10 microns. The new standard is 2.5 microns. We did not oppose that change. However, that change in combination with the other policy changes may make us rethink our support.
If a state implements EPA smoke/air policy and air quality standards are exceeded, the EPA will allow an opportunity for the problem to be corrected. If a state does not implement EPA policy and the standards are exceeded, the State will be declared to be in non-attainment and punitive action may be assessed.
EPA says Alabama probably will not have a problem since there is no anticipated significant increase in prescribed or general outdoor burning. This is of little consolation after an unexpected violation occurs.
EPA instituted the policy during a short period of time with little opportunity for input. This approach to government regulation greatly disturbs me. On several occasions, Alabama has not been notified of proposals, input opportunities, meetings, conference calls, or actions. I hear the same complaint from other state forestry agencies. Even when input was submitted, it appeared to receive little consideration or possibly ignored. This also is a complaint of other Southern states.
If the policy stands as is, it will likely reduce the prescribed burning that is currently occurring in Alabama. This will lead to an increase in the size and number of wildfires. This increases the smoke problem and therefore has the reverse effect of the intent of the EPA policy.
On behalf of the nonindustrial private landowners who own 72% of Alabama's forestland, I am asking you to contact Ms. Sally Shaver at EPA, MD15, Triangle Research Park, NC 27711, telephone number 919-541-5505, fax number 919-541-5489 and ask her to:
1. Reopen the opportunity for comments relating to their recent decisions.
2. Increase the opportunity for input by conducting more meetings and producing better publicity of the situation.
3. Work with the Southern states to develop rules that are reasonable and workable based on our situation.
Thank you for the interest you show in the needs of Alabama's citizens and especially those associated with forestry.
Timothy C. Boyce
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