Forest Bill Would Jeopardize Clean Air and Public Health

Senate Environment Committee to Hear Substitute “Forest Harvest” Bill

Tomorrrow the Senate Environment Committee will hear a substitute version of Senator Smith’s controversial “Forest Harvest” bill, S1085 (old version).

There are a bunch of significant and controversial bills on the agenda, including SCR 59, a legislative veto of the “waiver rule” (See excellent NJ Spotlight story), so the forestry bill could fly under the radar.

I’ve written previously about the troubling forest and public lands issues raised by that bill, and some of those issues remain in the substitute version. But, for today, I will leave the forestry aspect to others, who have far more knowledge than I.

Instead, today I will focus on one disturbing aspect of the bill that has gotten no attention.

NJ 2002 PM 2.5 emissions (Source: NJDEP)

The bill would promote “controlled burns” as a forestry management technique, on a statewide basis. The bill would also encourage more burning of firewood.

Thus, the bill would have significant adverse impacts on air quality and public health.

Here is NJ DEP emissions inventory data for particulate matter.

Please read my letter to Chairman Smith, the sponsor, requesting that the controlled burn provisions be eliminated.

Dear Senator Smith:

I wanted to provide emissions data and science to support my concerns on the controlled burn provisions of substitute for S1085, which I understand will be expanded from the Pines to statewide. 

As you know, north jersey hardwood forests are ecologically very different from Pines, particularly with respect to the role of fire. The human population, population density (exposure potential) and ambient air quality in north jersey are significantly worse as well. 

In addition to air quality and public health concerns, please be advised that increased incremental emissions from prescribed burns (and residential wood burning from harvested wood) would need to be factored into NJ’s SIP. 

Thus, the forestry practices of S1085 could have an unintended and significant consequence of forcing costly emissions ratchet down on other commercial and industrial sources to achieve instate PM 2.5 NAAQS.

The Mid-Atlantic Regional Air Management Association (MARAMA) made a presentation to the NJ Clean Air Council on April 11, 2012 that provided emissions inventory data and projections.

MARAMA identified prescribed burns and wood burning stoves as significant sources of PM 2.5 (and other pollutants, including ozone precursor VOC’s).

According to the MARAMA regional air emissions inventory, PM 2.5 emissions in NJ declined from 19,350 tons per year in 2002, to 14,292 tons in 2007, a significant 35% reduction. Thus, new emissions from prescribed burns expanded by the bill would wipe out this progress on clean air and adversely effect public health.

Worse, PM 2.5 emissions were projected to rise (most current model) to 15,926 TPY in 2009, an 11.4% increase.

With additional emissions from forestry managed controlled burns and more combustion from wood burning stoves, compliance with EPA NAAQS air quality standards is made more difficult and costly.