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USEPA Region 9
Director of Air Quality and Radiation
75 Hawthorne Street
San Francisco, CA 94105

To:
Deborah Jordan or Current Director
Elizabeth Adams or Current Deputy Director
Kerry Drake
Colleen McKaughan
Amy Zimpfer or Current Associate Directors

Subject:
1. Request for a Temporary Moratorium on all Federal Burn Agency “Prescribed”
Burns in Arizona.
2. Request the USEPA Protest the Toxic Air Pollution Created From Increased Federal
Agency “Managed” Burns.

In the spirit of prioritizing public health throughout the Southwest we urgently request that the USEPA place a temporary one year moratorium on all federal burn agency and federal burn agency related or contracted “prescribed” burns in Arizona effective immediately.

Additionally, we request that the USEPA lodge a formal protest with the US Forest Service, US BLM and National Park Service against the toxic smoke impact being produced by increasingly purposefully grown and uncoordinated federal “managed” burns undertaken for the purpose and priority of debatable forest land and resource objectives over the priority of scientifically proven toxic pollution effects on humans that these burns produce.

The public is also largely unaware that tactics for these destructive “managed” burns include Minimum Impact Suppression Tactics (MIST), per Federal burn agency fire management policies since at least 2003. These tactics result in purposely grown agency produced “mega fires” that are often reported to the public and politicians as “wildfires” from their inception. There is nothing “natural” about this human intervention eco-engineering process or the toxic pollution that ensues. This destructive process results in significantly degrading air quality not only in the region of the “managed” burn but sometimes for hundreds or thousands of miles and can go on polluting and destroying for months.

These federal burn agency “managed” burns have resulted and are currently resulting in significant degradation of the air breathed by hundreds of thousands of our citizens and visitors, pets, wildlife and decreased recreational opportunities. No one is spared the effects of the unhealthy air, most importantly our children, the frail elderly, and those members of our communities with heart disease, lung disease, diabetes, strokes, inflammatory diseases such as rheumatoid arthritis and lupus. In short hundreds, if not
thousands of residents and visitors susceptible to the effects of poor air quality endure curtailed activities and exasperated symptoms on these frequent smoke filled days.

This leaves us to ask the question, how much toxic smoke exposure for Arizonans seems to be enough to motivate the federal burn agencies and our air quality regulators to significantly reduce, or end all together the toxic air pollution created by these highly destructive but preventable and controllable “managed” burns?

These federal burn agencies pollute, plain and simple. Current policies and practices are not compliant with the spirit of the Clean Air Act and constitute an assault on the public health. The agencies granted authority to protect our air quality (the USEPA and State and Local Air Quality Agencies) appear to be unable or unwilling to fulfill their public health obligation to the citizens/communities they serve. Why?

The toxic pollution from federal agency created “managed” burns seems to be exempt from being adequately or accurately monitored or from determining or establishing meaningful public health impact metrics. Apparently, there are no agency checks and balances in place holding federal burn agencies accountable for the short and long -term true impact on citizen/community health or degradation of quality of life. Hundreds of thousands of southwestern citizens continue to be exposed to toxic smoke by-products, including PM10, PM2.5, carbon black, aldehydes, polycyclic aromatic hydrocarbons, carbon monoxide, mercury, benzene, ozone and ozone precursors and other noxious emissions.

Our assessment is this: Federal burn agency activities are out of control, uncoordinated and lack adequate checks and balances or accurate, meaningful pollution/public monitoring or health metrics. The annual burn period now seems to extend to 365 days a year, supporting unacceptable instances of “managed” burns. This destructive and toxic practice is followed by numerous cumulative uncoordinated local, state, and federal burn agency “prescribed” and “pile burning.”

One has to wonder if those establishing and carrying out these “must burn” and “let burn” policies and practices really understand the extent of the toxic and cumulative air pollution health consequences of their decisions.

It is time for the health needs of our citizens to be heard and for a balanced approach. It is time for the federal state and local burn agencies to make citizen/public air quality health the #1 priority when setting burn policy and practices. The public is becoming increasingly intolerant with burn agencies “must burn” and “let burn” policies/paradigm and their continued unfettered path to create pollution with impunity.

Additionally, we are now aware of a new push for an old idea to increase “prescribed” burning in return for reducing the growing number of federal agency managed burns which, in the eyes of the private citizenry, is akin to federal agency deception. This idea will simply increase agency created pollution each year without meaningful control and boundaries of either “managed” or “prescribed” burns. In short, this appears to be a burn agency scheme to “burn more.”

As far as increased toxic air pollution, when “prescribed” burn permits are issued, many of these agency created burns fall out of prescription almost immediately or by nightfall when the evening inversion layer forces the toxic smoke downward and citizens and visitors are forced to breathe the polluted air. There are usually no criteria to hold burn agencies responsible to provide any ongoing, adequate or accurate air monitoring or to put the fire or the intense smoldering out as soon as the prescribed burn goes out of prescription. Instead the burned areas are left to burn and smolder. A permit to burn is not a permit to pollute.

It is time to return clean air to Arizona citizens and we can start by a simple one year moratorium on all federal burn agency related “prescribed” burning and protesting the destructive, massive toxic pollution from subjective and uncoordinated federal “managed” burns.

During this period we urge open and fair discussion with informed consent given to our citizens about the scientifically proven increased rate of morbidity and mortality from this toxic air pollution.

Hasn’t the entire Southwest had enough toxic air pollution. How much burning is enough burning? How much ash and toxic particles are enough?

It is time that prevention of toxic smoke pollution exposure and public health becomes the priority over the “must burn” and “let burn” paradigm embraced by our burn agencies, particularly at the federal level.

Respectfully submitted by:

Name: ______________________________

Date: _______________________________

Email:_______________________________

 


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