GAO Report on EPA’s Coordination (or Not) with Other Federal Agencies on Wildfire Smoke

I’m one of many people who has had the opportunity to be in interagency conflict resolution meetings, in my case FS, ACE and EPA.  My own experience (based on a few incidents) is that some EPA employees have an attitude toward land management agencies that is not conducive to collaboration.  Their attitude seemed to be “we know more than you do”, which they didn’t, and “we are more righteous than you” which they weren’t.  At the same time, I have to say that one of the best people I’ve ever worked with was a political appointee at EPA (a lawyer and law professor) during the Clinton administration. So I’m not saying they’re all like that.. but I’ve run into a few.

The theme of the next few posts  is “right hand and left hand” or… are federal agencies aligned in the same direction? I think all of us agree that federal tax dollars should not be wasted or mismanaged by opposing government programs (if it can be avoided) and that for important topics like decarbonization or wildfires, agencies should be aligned.  It’s the administration’s job to make sure that happens and enforce it within the executive branch. We’ve discussed before this EPA PM 2.5 thing. Too bad the GAO didn’t explore how the proposed rule could have gotten all the way to OIRA before anyone noticed it was a problem. That could really shed some light on coordination processes and efficacy. Thanks to alert TSW readers for noticing this GAO report.

Here’s a link to the GAO Report, published on March 13, titled “Wildfire Smoke:Opportunities to Strengthen Federal Efforts to Manage Growing Risks.”

It could be that there are so many wildfire commissions and task forces nowadays that the idea of high-level officials actually engaging with each other and resolving disputes has fallen by the wayside. Which is of great concern. So while the EPA says they will respond to the need for “better coordination” with land management agencies, they haven’t actually pulled the plug on revising the 2.5 NAAQS. Maybe they have sent signals to high level folks at USDA and Interior, but it would be nice for us here in the cheap seats to also get the message.

Here is the National Association of Forest Service Retirees letter on the proposed rulemaking, which I also received last week. If they are standing down on this for prescribed fire, it would save work by many in our space. If they are not standing down- well actions speak louder than words about “coordinating.” Maybe the need is for less “coordination” and more “woodshed.”

I’m always a fan of coordinating research..does this seem like something the USG should institute as a matter of course for research topics?

Additionally, officials from the CDC said that creating a framework for coordinating research related to community preparedness for wildfire smoke could help federal agencies more intentionally plan such research and create a community of practice on the topic.

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Here’s the air curtain discussion…

Also, to remove barriers to certain wildfire risk mitigation strategies, EPA officials said that the agency could, for example, finalize its proposed rule related to permit requirements for air curtain incinerators. Air curtain incinerators are devices for burning debris collected through methods such as mechanical thinning.92 According to EPA officials, these devices offer an alternative to prescribed burns and have much fewer emissions than burning debris piles or prescribed burns

And ..According to Forest Service officials, the use of air curtain incinerators helps reduce woody fuel on a site but does not necessarily reduce the need for prescribed burns to reduce fine surface fuels.

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I thought it was interesting to compare the views of the FS and BLM (Interior), who conceivably have the same issues:

In its written comments, USDA stated that the role of the Forest Service in responding to wildfire smoke and protecting public health, as well as the importance of mitigation efforts to address smoke impacts associated with
the wildfire crisis, was captured well in our report, and that this role and mitigation are critical to long-term efforts for wildfire risk reduction. USDA also stated that, as the environmental impacts of catastrophic wildfire
extend far beyond air quality, effectively implementing our recommendations requires focused collaboration beyond smoke and its impacts to public health. USDA said that only focusing on the effect of wildfire smoke on public health minimizes the breadth of the current crisis impacting the natural and human environment and neutralizes the most effective mitigation tool that also mimics natural processes—prescribed fire, which, according to USDA, can be managed to minimize impacts on public health.

In addition, USDA said that, as air quality standards become more stringent, expanded interagency discussions are needed to ensure the increased use of prescribed burning as the primary mitigation to catastrophic wildfire. USDA said that bolstering current authorities and approaches mentioned in our draft report should balance impacts on firefighter and public safety, water quality, and protection of municipal water supplies, among other environmental effects. As discussed in our report, EPA has raised other concerns related to the increased use of prescribed burning. We believe USDA would have important opportunities to raise these and related issues as it works with EPA and Interior to
implement our recommendation to better align air quality and land management goals.

Here’s Interior, which seems like the answer is “we’ll hire more people.”

In its written comments, Interior stated that to achieve our recommendation to work with EPA and USDA to better align air quality and land management goals, it plans to increase staffing to plan for and manage smoke emissions at the departmental and bureau levels and to work across agencies at the national and regional levels, as well as with tribal, state, and local governments and other external partners. Interior also stated that its management of air quality and wildfire risk mitigation goals will include an increasingly wide array of communications, data management, planning, budget development, wildfire operations, environmental justice efforts, and fuels management implementation, which will be supported by its additional staffing. Interior said these efforts will be initiated this year and will enable coordination of its existing efforts with EPA and USDA and the joint development of further efforts. Interior stated that this will support efforts to increase the pace and scale of fuels management treatments and address the overall wildfire risk reduction objectives included in the  Infrastructure Investment and Jobs Act. The actions Interior described, if implemented effectively, would address our recommendation.