Record Keeping

Record keeping includes daily fire tracking for communication purposes, and documenting the event for at least three and a half years.

Track fire activity on a daily basis.

At a minimum document the acres treated (blackened acres), location, date, and time of burn. Additional information on type of burn, fuel type, and pre-burn fuel loading will be useful for accurately estimating emissions if desired. This information can be retained at the burner location until needed in the event there is an adverse impact from a burn. Tracking of fire activity is a key element of BSMPs while specific reporting requirements are left to the discretion of the State, Tribe, or locality.

Document the event and retain relevant records for 3.5 years.

Event documentation, including the use of BSMPs, and retaining other relevant records is important if problems arise due to a smoke intrusion into a sensitive area. This is true whether it be a nuisance issue or an event which possibly impacts National Ambient Air Quality Standards (NAAQS) compliance. Information collected about the burn will enhance emissions estimates and smoke dispersion predictions which could help a burner understand how the adverse impact occurred and how to avoid it in the future. For federal land managers, the documentation is critical for conducting After Action Reviews which are a key mechanism for improving performance and avoiding recurrence of incidences.

Documentation can also lead to a better understanding of a prescribed fire's contribution to high pollution readings at air quality monitors located downwind. This information will be required if an exceptional event occurs. It is important to retain the records for 3.5 years (based on the 2007 Exceptional Events Rule) as NAAQS violations may not be identified and evaluated immediately. Sample analysis and data review take time, and NAAQS violations are computed using several years of data. Air regulators may not investigate the causes of a violation until a year of more from the event. Documentation can take a variety of forms depending on the local or State requirements, but can range from personal records to submittal of records into a fire activity tracking system.

Source:

USDA Forest Service and Natural Resources Conservation Service. 2011. Basic Smoke Management Practices. Basic Smoke Management Practices Tech Note, October 2011. Accessed 3 January 2017. Available at: https://www.frames.gov/catalog/20307