The Department of Forestry agrees with the purpose of the State Air Pollution Control Board’s decision to revise the Open Burning regulation 9VAC5-130.  We agree it is important for the Commonwealth’s agencies to revise regulations as needed to efficiently and effectively meet its goals while avoiding unreasonable hardships on the regulated community, the department, and the general public.  The Department of Forestry is pleased to submit the following comments regarding the proposed change to open burning regulations administered under the State Air Pollution Control Board.  We strongly support that open burning for forest management practices continue to be permitted as outlined in 9VAC5-130-50.  Virginia’s forest landowners depend upon prescribed (controlled) burning to achieve efficient and effective practices on their forestland to insure healthy and productive forests.  Prescribed burning results in direct benefits to forestland owners and the general public, including:

 

·         Reduces forest fuels, which reduces the damaging effects of wild fires. 

·         Controls growth of undesirable competing species.

·         Controls diseases spread through conifer forests.

·         Creates favorable habitats for certain wildlife and plant species as well as threatened and endangered species.

·         Removes dead vegetation for certain maintenance and hazard reduction work.

·         Regenerate desirable species of pine and hardwood.

 

Section 9VAC5 – 130 -50 permits open burning for forest management practices in accordance with the Department of Forestry’s smoke management guidelines as outlined under the Code of Virginia §§ 10.1-1142.  The smoke management plan is a comprehensive plan that accounts for climatic and other environmental factors to reduce negative impacts of smoke on the public, while effectively accomplishing the intended forest management practice.  The Department of Forestry provides complete training on prescribed burning to its employees as well as non-employees engaged in prescribed burning.  The effect of this training effort is a better informed prescribed burning operator, who understands the management of smoke and how to reduce impacts on the public. 

 

We strongly support the continuation of permitting open burning for forest management practices.  We would suggest that no changes be made to the regulation which would negatively impact the ability of forest land owners to continue the use of prescribed burning tool on their forest lands.