Appendix A

Smoke Management Plan

Site C Clean Energy Project

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 Smoke Management Plan
Site C Clean Energy Project

TABLE OF CONTENTS
Revision History ............................................................................................................. 5
Abbreviations and Acronyms ...................................................................................... 10
Glossary ....................................................................................................................... 11
1.0 Introduction ............................................................................................................ 14
1.1 Objectives .................................................................................................. 14
2.0 Regulatory Context ........................................................................................... 14
2.1 Provincial Legislation .................................................................................. 14
2.1.1 Environmental Management Act and Open Burning Smoke Control
Regulation ........................................................................................ 14
2.1.2 Wildfire Act and Wildfire Regulation................................................... 15
2.2 Site-C – Specific Conditions........................................................................ 15
2.2.1 Federal Decision Statement .............................................................. 15
2.2.2 Environmental Assessment Certificate Schedule B – Table of
Conditions ........................................................................................ 15
3.0 Scope................................................................................................................. 15
4.0 General Requirements ...................................................................................... 16
4.1 Identify Sensitivity Zones ............................................................................ 17
4.2 Material to be Burned.................................................................................. 17
4.3 Timing of Burning ....................................................................................... 18
4.4 Setback Distances...................................................................................... 18
4.5 Burn Criteria ............................................................................................... 21
4.5.1 Division 1 – Open Burning by High, Medium, and Low Smoke
Sensitivity Zones............................................................................... 22
4.5.2 Division 5 – Open Burning Using Air Curtain Incinerators ................... 24
4.5.3 Venting Forecasts............................................................................. 25
4.5.3.1 Venting Forecast Sources........................................................... 26
4.5.4 Burn Duration / Burning Period .......................................................... 27
4.5.5 Change in Burning Conditions ........................................................... 28
4.6 Burn Registration ........................................................................................ 28
4.6.1 Category 3 Piles ............................................................................... 28

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4.6.2 Category 2 Piles ............................................................................... 28

4.7 Records and Reporting ............................................................................... 29
5.0 Smoke Reduction – Best Management Practices ............................................ 29
5.1 Seasonal Burn Planning ............................................................................. 29
5.1.1 Burn Season..................................................................................... 29
5.1.2 Burning Prioritization ......................................................................... 29
5.1.3 Sensitive Time Periods ..................................................................... 30
5.2 Debris Pile Construction and Seasoning...................................................... 30
5.2.1 Pile Size, Shape and Components .................................................... 30
5.3 Pre-Burn Protocols ..................................................................................... 32
5.3.1 Collate Burn Plan Information............................................................ 32
5.3.2 Venting Forecasts............................................................................. 32
5.3.2.1 Limitations of Venting Index and Forecasts ................................. 32
5.3.3 Communication with Forecasters....................................................... 34
5.3.4 Training ............................................................................................ 34
5.3.5 Environmental Considerations ........................................................... 34
5.4 Light-Up Procedures................................................................................... 35
5.4.1 Pre-burn Checklist ............................................................................ 35
5.4.2 Ignition Plan...................................................................................... 38
5.4.3 Daily Ignition Period .......................................................................... 38
5.4.4 Pile Ignition ....................................................................................... 38
6.0 Monitoring and Tracking ................................................................................... 39
6.1 Monitoring .................................................................................................. 39
6.2 Tracking ..................................................................................................... 40
6.2.1 Burn Tracking ................................................................................... 40
6.2.2 Record Keeping and Submission....................................................... 44
6.2.2.1 Weekly Submission .................................................................... 44
6.2.2.2 Upon Request ............................................................................ 44
6.3 Air Quality Monitoring, Advisories and Burn Bans ........................................ 44
7.0 Notification and Wildfire Reporting .................................................................. 45

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7.1 Notification ................................................................................................. 45

7.1.1 Public ............................................................................................... 45
7.1.2 First Nations ..................................................................................... 45
7.1.3 Other Stakeholders ........................................................................... 45
7.2 Wildfire Reporting ....................................................................................... 47
7.3 Key Contacts.............................................................................................. 47
8.0 Qualified Professionals..................................................................................... 49
9.0 Works Consulted............................................................................................... 50

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LIST OF TABLES
Table 1. Setback Distances ............................................................................................ 18

Table 2. Sensitive Receptors Requiring a Setback Equivalent to Hospitals, Schools, and

Community Care Facilities, as Identified in Appendix B Air Quality
Monitoring Program of the Construction Environmental Management Plan
(CEMP). .................................................................................................. 19

Table 3. Burn Criteria for Open Burning Completed Under Division 1 by High, Medium,
and Low Smoke Sensitivity Zones. ........................................................... 22

Table 4. Burn Criteria for Open Burning in Modified Setbacks.......................................... 24

Table 5. Burn Criteria for Open Burning Under Division 5, Using Air Curtain Incinerators . 25

Table 6. Venting Indices ................................................................................................. 26

Table 7. Example Open Burning Pre-Burn Checklist for Category 2 and Category 3 Fires.
The Pre-Burn Checklist may be Modified or Adapted to Better Suit Aerial
Ignitions................................................................................................... 36

Table 8. Recommended Daily Ignition Period .................................................................. 38

Table 9. Burn Tracking Form, including an example entry. Ignitions on different parcels,
different geographic location or Smoke Sensitivity Zone, or difference in
Burn Category (Category 2 / Category 3) would necessitate additional
entries or additional forms. An asterisk (*) indicates reporting requirements
from the OBSCR...................................................................................... 42

Table 10. An example of an acceptable burn period / smoke release monitoring form. ..... 43

Table 11. Geographical Units and Key Stakeholders for Notification. Contacts for key
stakeholders are found in Section 7.3. ...................................................... 45

Table 12. Key contacts for notification, party responsible for notification, and primary
method of notification. .............................................................................. 47

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Revision History
Version Date Comments
Rev 2 March • Table detailing revision history to align with requirements in the CEMP S. 2.4.
2018 • Rationale f or edits to align with requirements in the CEMP S. 2.4.
• Add references to relevant legislation, as footnotes.
• Ref ormat and change order of content. Section changes are noted in revision
history table.
• Replace ‘Primary’ and ‘Secondary Smoke Sensitivity Zones’ with ‘Category A’ and
‘Category B Areas’, respectively, to align plan with wording and definitions used in
currently enacted legislation.
• Reduce scope of document; remove vegetation clearing activities, which are
guided by the Vegetation Clearing and Debris Management Plan (VCDMP).
Remove ref erences to VCDMP and all vegetation clearing activities which are
guided by the VCDMP.
• Move content in Appendices to body of document.
• Add definitions for BCWS, CEMP, EIS, MFLNRORD (update to reflect current
Ministry name), and VI. Delete definitions for acronyms VCDMP, PM 2.5, PSSZ,
SSSZ and reformatting and alphabetization (Abbreviations and Acronyms).
• Clarif y regulatory framework applicable to burning activities. Remove guidance
provided by OBSCR policy intentions. Addition of Wildfire Act and Wildfire
Regulation and Site-C conditions (Federal Decision Statement and Schedule B -
Table of Conditions). Add potential for ‘substitute requirements’ if new legislation is
enacted during the project (S. 2.1 / S. 2.1.1, 2.1.2, 2.2)
• Separate regulatory framework from plan scope to simplify plan organization (S.
2.0 / S. 2.0, 3.0)
• Remove vegetation clearing activities from plan scope (S. 2.2 / S. 3.0).
• Remove Vegetation Activities by Project Area; activities guided by VCDMP (S.3.0 /
N/A).
• Clarif y and distinguish in the plan those components that are: required by
legislation or are required as BMPs to meet open burning / smoke condition
objectives. Rename section to better reflect the contents. Removed reference to
VCDMP and ref erences to potential, future regulations. Changes align plan to
currently enacted legislation, remove irrelevant ref erences, clarify regulatory
requirements, and provide contractors and monitors operational best practices to
meet or exceed smoke management objectives (S. 4.0 / S 4.0).
• Clarif ication of annual burn program planning requirements. Content split into
subsections. Addition of prioritization of areas under good venting conditions (S.
4.2 / S. 5.1.1, 5.1.2).
• Change 'to be determined' to 'may be determined’ to more accurately reflect the
ground truthing activities and communications which have occurred since Ver. 1
(S. 4.3 / S. 5.1.3).
• Add ‘schools in session, identified sensitive receptors, and continuing health care
centres’ as land use requiring minimum 1,000 m setback. Add list of identified
sensitive receptors. Changes are to remain consistent with the categories outlined
in currently enacted legislation (OBSCR), Appendix B of the CEMP, Appendix L of
the EIS, and Condition 57. Add allowance for application to relax minimum

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Version Date Comments

setbacks to allow alignment with currently enacted legislation (OBSCR) (S. 4.4 /
S.4.4).
• Smoke release periods re-defined to match definitions in currently enacted
legislation (OBSCR) (S. 5.0 / S.4.5).
• Addition of annual allowable burning periods and smoke free periods to the burn
criteria f or Category A Areas to align plan to currently enacted legislation (OBSCR)
(S. 5.0 / S. 4.5).
• Ref ormat and move daily ignition period (S. 5.0 / S. 5.4.1).
• Remove redundant definition daily ignition period (S. 5.2 / N/A).
• Add methods to amend daily burn plan, in the case of changed venting conditions:
allow use of forced air mechanism or extinguishing burning (S. 6.1 / S. 5.3.2).
• Add provincial ambient air quality objectives. Update BCH-installed particulate
monitoring station (number and locations) (S. 6.2 / 6.2).
• Delete Post Season Custom Venting Forecast Analysis to align with currently
enacted legislation (OBSCR) (S. 6.3 / N/A).
• Clarif y methods, responsibility, and requirement of obtaining BRN for Category 2
and 3 burns to align with currently enacted legislation (Wildfire Regulation) and
with requirements in the CEMP S. 2.4. (S. 7.1, Appendix A / S. 4.6).
• Clarif y roles and responsibilities regarding notification including: stakeholders
based on geographic location, timing of notification(s), notification responsibility,
and required documentation (S. 7.2, Appendix D / S. 7.0, 7.1).
• Clarif y tracking responsibility, add tracking requirements and amend submission
timing and format. Required tracking: daily burn logs, documentation of compliance
with smoke release period, nest/ den survey results, setback relaxation approvals,
and debris reduction monitoring. Add example entry of burn tracking form (S. 7.3,
Appendix C / S. 6.1.1).
• Delete annual burn reporting to align with currently enacted legislation (S. 7.4 /
N/A).
• Update revision information (QP and date) (S. 8.0 / S. 8.0).
• Update works consulted (S. 9.0 / S. 9.0).
• Expand and clarify piling requirements (locations prohibited, definitions, fuel break)
(Appendix A / S. 5.2.1).
• Identif y contractor responsibility for burn plan. Provide direction for burning in the
event that ventilation forecast is not representative of local conditions. Provide
additional considerations prior to practical applications for venting forecasts
(f orecaster confidence, prioritization of areas, wind direction, location of values
potentially impacted) (Appendix A / S. 5.3.1, 5.3.2).
• Add pre-burn considerations, requirement and example template of pre-burn
checklist (Appendix A / S. 5.4).
• Reduce allowable surface area of debris emitting smoke at the end of the smoke
release period from 10% to 5% for Category B areas to align with currently enacted
legislation (OBSCR) (Appendix A / S. 6.0).
• Expand upon connection between venting forecasts, ventilation index, ventilation
category, mixing height and wind speed (Appendix B, S. 5.1 / S. 4.5.1).
• Replace Table 6 notification list with detailed contact list, by geographic area

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Version Date Comments

(Appendix D / S. 7.3).
• Add objectives for SMP to align with requirements in the CEMP S. 2.4 (N/A / S.
1.1).
• Def ine ‘Category Areas’ and addition of Category Area mapping to align with
requirements in the CEMP S. 2.4. (N/A / S. 4.1)
• Add prohibited materials, acceptable timing of burning, and specific conditions
which limit burning to align plan to currently enacted legislation (OBSCR) (N/A /
4.2, 4.3).
• Add definition of Category pile sizes and conditions to align plan to currently
enacted legislation (Wildfire Regulation) (N/A / S. 4.2).
• Def ine sources of venting forecasts; identify acceptable use of sources (N/A / S.
4.5.1.1).
• Recognize smoke free periods and allowable annual smoke release periods as
legislated requirements to align with currently enacted legislation (OBSCR) (N/A /
S. 4.5.3, 4.5.4).
• Add ‘stop-burn’ conditions to align with currently enacted legislation (OBSCR) (N/A
/ S. 4.5.5).
• Recognize risk of hold-over fires, add conditions for burning outside of normal
burning windows (N/A / S. 5.1, 6.0).
• Add local validation of venting forecast through use of test piles (N/A / 5.3.2).
• Clarif y training requirements, contractor responsibility regarding training,
competence, and record-keeping to align with requirements in the CEMP S. 2.4
(N/A / 5.3.4).
• Add Environmental Considerations section to require den and active nest surveys
prior to ignition (N/A, 5.3.5).
• Add acceptable methods to monitor and measure smoke release period to ensure
compliance with currently enacted legislation; require contractor to develop
measurable reporting and documentation of smoke release period compliance.
Add infrared scheduling information (N/A / S. 6.1).
• Def ine and identify wildfire reporting requirements to align with currently enacted
legislation (Wildfire Act and Wildfire Regulation) (N/A / S. 7.2).
These revisions are not material within the meaning of Section 2.6 because:
• The revisions will not result in a reduction of any monitoring or reporting
requirements;
• The revisions will not result in the deletion or reduction of an environmental
specification;
• The revisions will not otherwise make an adverse effect more likely, nor become
more adverse and be significant.
Rev 3 Nov. • The entire document was reviewed and updated to reflect regulatory changes,
2019 specifically the September 2019 Open Burning Smoke Control Regulation. Edits
and updates include changes in: practices to ensure compliance with new or
amended regulatory requirements; technical definitions and how new definitions
apply to practices or regulatory interpretations, and terminology (minor changes to
wording generally not impacting practices). Updates to Rev 3 include updating all
citations to the current Open Burning Smoke Control Regulation (from BC Reg.

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Version Date Comments

145/93 to BC Reg. 405/19).
• Add Glossary to define words and phrases from the relevant legislation, as well as
to define words and phrases recurring throughout the document.
• Update to the footnote legal citation style.
• Update S. 2.1.1 to describe newly enacted OBSCR.
• Update S. 3.0 to clarify scope of the document.
• Update S. 4.0 to reflect OBSCR (terminology) and to reflect the changes in section
headings of the updated SMP (to ensure consistency throughout document).
• Update S. 4.1 to introduce smoke sensitivity zones which replace category areas.
Delete maps outlining outdated category areas. Provide direction to provincial
mapping for smoke sensitivity zone identification.
• Move definitions in S. 4.2 to glossary. Update criteria and definition of allowable
and prohibited material to be burned (origin of material, banned materials,
requirement to minimize material for open burning) as per new OBSCR.
• Update S. 4.3 to introduce ‘burn criteria’ as required elements for burning, as per
new OBSCR. Clarif y and outline situations which supersede burn criteria and
under which burning may not occur, as per OBSCR.
• Update S. 4.4 with regulation setbacks and option to burn with modified setbacks,
as per OBSCR. Change terminology (continuing care to community care) to remain
consistent with legislation.
• Update S. 4.5 to reflect OBSCR: ‘ignition criteria’ is changed to ‘burn criteria’,
addition of burn divisions potentially applicable to the Project.
• S. 4.5.1 defines specific burn criteria for burn division 1: by smoke sensitivity zone
and modified setbacks.
• S. 4.5.2 defines burn criteria for burn division 5: burning using air curtain
incinerators.
• S. 4.5.3 relates venting forecasts to burn criteria and relevant tables.
• S. 4.5.3.1 removes option to test burn as acceptable venting forecast. Removes
ref erence to ‘parcel’ as the main unit for determining compliance with OBSCR.
Update ventilation forecasting website. Align terminology ‘custom ventilation
f orecaster’ with OBSCR.
• S. 4.5.4 align burn period, burn duration, and burn ‘end’ definitions with OBSCR.
Identif y pile as the unit for regulatory compliance (burn criteria, smoke sensitivity
zone, burn duration are all measured by pile).
• S. 4.5.4 allows option to move vegetative debris from the point of origin to provide
some operational flexibility.
• Update 4.5.5 with wording consistent with OBSCR.
• Add S. 4.7 to outline new reporting requirements, as per OBSCR.
• S. 5.0 clarif y that best management practices also include regulatory requirements.
• S. 5.1.1 add ‘burn criteria’ to encompass all the criteria required for ignition under
OBSCR.
• S. 5.1.2 replace ‘category areas’ with ‘smoke sensitivity zones’. Add requirement to
minimize soil content mixed in with vegetative debris. Add seasoning requirements
based upon smoke sensitivity zone. Clarify that minimum setbacks differ for open

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burning piles versus use of an air curtain incinerator. All changes were made to
comply with OBSCR.
• S. 5.1.2 include option for BCH to authorize hand-piling (as per CEMP) in RRZs, if
necessary due to topographic limitations; change is to offer flexibility for piling in
highly constrained areas.
• S. 5.3.1 replace ‘category areas’ with ‘smoke sensitivity zones’.
• S. 5.3.2 remove reference to test burn as an approved method for obtaining
venting forecast.
• S. 5.3.2.1 replace ‘category areas’ with ‘smoke sensitivity zones’. Remove option
to apply to the MOE for a longer smoke release period; this is no longer an
allowable practice under OBSCR.
• S. 5.3.5 allows for use of drones during den surveys. Allowance for QEP to provide
environmental rationale, when deemed appropriate by the QEP, in place of
completing another den survey after the duration of validity has expired.
• S. 5.4 add specific reference to aerial ignition and requirement of an ignition plan.
• S. 5.4.1 remove bulleted examples of safety, regulatory and operational variables
f or the pre-burn checklist to reduce redundancy from other sections. Clarify
requirement to comply with Wildfire Act and Regulation as part of pre-burn
checklist.
• S. 5.4.1, Table 7 (pre-burn checklist) update to reflect regulatory changes and
terminology. Wording clarification for pile locations specific to RRZs.
• S. 5.4.2 include requirement for, and minimum components of, an ignition plan.
• S. 5.4.3, Table 8 update to comply with OBSCR (daily ignition period by smoke
sensitivity zone).
• S. 5.4.4 require aerial ignitions to comply with specific helicopter company safe
work procedures and best practices.
• S. 6.1 update monitoring requirements to comply with OBSCR definitions of ‘end’ in
terms of open burning. Include acceptable actions in the event that piles do not
achieve desired levels of debris consumption or comply with burn ‘end’
requirements, as per OBSCR. Add allowance to use thermal scans for hazard
abatement monitoring.
• S. 6.2 summarize / clarify list of records created during proper implementation of
the smoke management plan. Include requirement for ignition plan.
• S. 6.2.1 updates to burn tracking procedure. Updates to data collection
requirements and update Table 9 (burn tracking form) to comply and be consistent
with OBSCR. Add Table 10 as an example system to document compliance with
OBSCR, in terms of burn period and smoke release monitoring.
• S. 6.2.2, S. 6.2.2.1 and S. 6.2.2.2 clarify record-keeping responsibility and
expected frequency of record submission to BCH.
• S. 7.0 clarif y that ‘reporting’ is in reference to the reporting of a wildfire or escaped
open burn.
• S. 7.3 update key contacts.
• S. 8.0 update with current and applicable OBSCR.
• S. 9.0 update works consulted.

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Version Date Comments

Rev 4 Sept. • The entire document was reviewed for potential amendments required due to
2020 regulatory changes, specifically the Wildfire Regulation, BC Reg 38/2005,
amended June 26, 2020 by B.C. Reg. 157/2020. No edits or updates were required
as a result of this review.
• MOE changed from Ministry of Environment to Ministry of Environment and
Climate Change
• Earle Plain title and contact details updated
Rev 5 Sept • Updated Table 3 to amend the ‘period for igniting piles of unlit vegetative debris’
14, and ‘period for adding unlit vegetative material to ignited piles’ within the MSSZ to
2021 be consistent with Open Burning Smoke Control Regulation (B.C. Reg 152/2019).
• Updated Table 12, key contacts for notification, specifically contacts for the
f ollowing: Ministry of Environment and Climate Change Strategy, RCMP Hudson
Hope Detachment, RCMP Fort St John Detachment, City of Fort St John, Fort St
John Fire Department, District of Taylor and Fire Department, District of Hudson’s
Hope, Hudson’s Hope Fire Department, Chetwynd Fire Department, BC Wildfire
Service, Northern Health, BC Hydro Public Relations and Communications.

Abbreviations and Acronyms

BCWS................................................................................... British Columbia Wildfire Service

BMP ............................................................................................Best Management Practices

BRN................................................................................................Burn Registration Number

CEMP ................................................................ Construction Environmental Management Plan

CVF................................................................................................ Custom Venting Forecast

EAC............................................................................... Environmental Assessment Certificate

EAO................................................................................BC Environmental Assessment Office

EIS ....................................................................................... Environmental Impact Statement

HSSZ..........................................................................................High Smoke Sensitivity Zone

LSSZ .......................................................................................... Low Smoke Sensitivity Zone

MFLNRORD….Ministry of Forests, Lands, and Natural Resource Operations and Rural Development

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MOE .....................................................................Ministry of Environment and Climate Change

MSSZ .................................................................................... Medium Smoke Sensitivity Zone

OBSCR ...................................................................... Open Burning Smoke Control Regulation

SMP ...............................................................................................Smoke Management Plan

VI .......................................................................................... Venting Index / Ventilation Index

Glossary1
Burnt surface area: the area that is underneath or surrounding the remains of a fire and
covered by charred or smoldering vegetative debris.

Category 2 open fire 2: an open fire, other than a campfire, that:

(a) burns material in one pile not exceeding 2 m in height and 3 m in width,
(b) burns material concurrently in 2 piles each not exceeding 2 m in height and 3 m in
width, or
(c) burns stubble or grass over an area that does not exceed 0.2 ha.

Category 3 open fire3: an open fire that burns:

(a) material concurrently in 3 or more piles each not exceeding 2 m in height and 3 m in
width,
(b) material in one or more piles each exceeding 2 m in height or 3 m in width,
(c) one or more windrows, or
(d) stubble or grass over an area exceeding 0.2 ha.

Community Care Facility4: premises or part of a premises (a) in which a person provides car e
to 3 or more persons who are not related by blood or marriage to the person and includes any
other premises or part of a premises that, in the opinion of the medical health officer, is used in
conjunction with the community care facility for the purpose of providing care, or (b) designated
by the Lieutenant Governor in Council to be a community care facility.
Custom ventilation forecast: a forecast of the atmosphere’s ability in a geographic area to
disperse smoke and which is (a) obtained from a custom ventilation forecaster, and (b)
submitted by email to the ministry, using the email address made known by the ministry for the
purposes of receiving custom ventilation forecasts, before starting open burning. 5

1 Unless otherwise noted, all definitions in the glossary are from BC Reg 405/19 Part 1 – Definitions.
2 BC Reg 38/2005, s. 1(1)
3 BC Reg 38/2005, s. 1(1)
4 Community Care and Assisted Living Act S.B.C. 2002, c. 75, parts 1 and 3 and BC Reg 405/19, Part 1.
5 BC Reg 405/19, s. 16

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Custom ventilation forecaster: a person who (a) is a meteorologist employed by Environment

Canada and classified as a Meteorologist 3 or above, (b) is a Weather Forecaster, a Fire
Weather Forecaster, an Air Quality Meteorologist or an Air Quality Science Specialist employed
by or under contract with the government, or (c) has similar knowledge and experience as
described in paragraph (a) or (b) and is approved in writing by a director to conduct custom
ventilation forecasts for the purposes of this regulation.

Dry basis moisture content: with respect to a given amount of vegetative debris, means the
weight of moisture contained in the vegetative debris divided by the weight of the vegetative
debris if the vegetative debris was dry, with both weights measured in the same weight units,
multiplied by 100 and expressed as a percentage.

End (with regards to open burning): (a) if the open burning is being done using an air curtain
incinerator, the point in time when the fire in the air curtain incinerator is emitting s moke from no
more than 10% of the base of the air curtain incinerator, and (b) respecting all other open
burning, the point in time when each pile of vegetative debris has ceased flaming and is emitting
smoke from no more than 10% of its burnt surface area;

Fire suppression system6: a system for suppressing fire by delivering: (a) water, (b) a
suppressant, (c) a surfactant, or (d) any combination of the substances (a) to (c) and may
include a water delivery system.

High smoke sensitivity zone: (a) land in the province that is outlined and shaded in pink and
labelled ‘High Smoke Sensitivity Zone’ in the legend, on a map listed in Schedule 3 except all
areas of that land that are designated under section 7 as being a medium smoke sensitivity
zone or a low smoke sensitivity zone, and;
(b) all areas of land that are designated under section 7 as being a high smoke sensitivity zone”.

Low smoke sensitivity zone: land in the province that is not a high smoke sensitivity zone or a
medium smoke sensitivity zone.

Medium smoke sensitivity zone: ( a) land in the province that is outlined and shaded in
yellow, and labelled "Medium Smoke Sensitivity Zone" in the legend, on a map listed in
Schedule 3 except all areas of that land that are designated under section 7 as being a high
smoke sensitivity zone or low smoke sensitivity zone, and
(b) all areas of land that are designated under section 7 as being a medium smoke sensitivity
zone”.

Opacity7: the degree to which smoke obscures the view of an object in the background,
expressed numerically from 0% (transparent) to 100% (opaque).8

Seasonal residence9: a fixed residence that, while not being occupied on a full-time basis, is
occupied on a regular basis. A regular basis does not imply a scheduled occupancy but implies
use of six weeks per year or more. The residence must not be mobile and should have some
sort of foundation or features of permanence (e.g., electrical power, domestic water supply,

6 BC Reg 38/2005, s. 1(1)

7 BC Reg 405/19, s. 28(1)
8 As determined in accordance with the United States Code of Federal Regulations, Title 40, Part 60, Chapter 1, Appendix A -4,

Method 9, as amended from time to time.

9 Alberta Energy Regulator 2007

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septic system) associated with it. Summer cottages or mobile homes are examples of
seasonally occupied dwellings, while a holiday trailer simply pulled onto a sit e is not.

Seasoned vegetative debris: vegetative debris that (a) has been dried to the extent that the
dry basis moisture content is 30% or less, (b) has been put in piles for a period of at least 4
months, or (c) has originated from standing dead timber.

Water delivery system10: a system that can (a) deliver a sufficient volume of water to
effectively fight a fire of a reasonably foreseeable size, taking all factors into consideration,
including the conditions of the area where the water delivery system may need to be used, and
(b) deliver water to any place at the site of an industrial activity, on the burn area or the high risk
activity, or reasonably adjacent to the burn area or the site of a high risk activity.

10 BC Reg 38/2005, s. 1(1).

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1.0 Introduction
As part of the planning associated with the Site C Clean Energy Project (the Project), and the
environmental assessment process, a Smoke Management Plan (SMP) was developed and
submitted with the Environmental Impact Statement (EIS) (BC Hydro 2013) and currently exists
as Appendix A of the Construction Environmental Management Plan (CEMP).11 The SMP
describes how project-related burning will be conducted compliant with the most current British
Columbia Ministry of Environment Open Burning Smoke Control Regu lation (OBSCR) and other
relevant regulatory requirements, outlines best management practices to reduce smoke
emissions and mitigate air quality impacts from burning, and remains in accordance with the
Site C Clean Energy Project Construction Environmental Management Plan (CEMP), section
5.1 Air Quality Management, which states:

• Manage smoke from the burning of clearing debris in accordance with the Smoke
Management Plan (Appendix A).

1.1 Objectives
The objectives of the SMP are as follows:
• Outline regulatory requirements of open burning activities;
• Detail Best Management Practices to avoid, mitigate, or minimize the emissions of
smoke and particulates from open burning; and,
• Ensure consistency and compliance with all relevant provincial and federal conditions
mandated as part of the environmental assessment process.

2.0 Regulatory Context

2.1 Provincial Legislation
2.1.1 Environmental Management Act and Open Burning Smoke Control Regulation

Under the authority of the Environmental Management Act12, the BC Ministry of Environment
(MOE) has the mandate to regulate smoke emissions from open burning activities through the
application of the Open Burning Smoke Control Regulation13 (OBSCR). The OBSCR is divided
into the Part 1 – Interpretation and Application, Part 2 – General Requirements for Open
Burning, Part 3 – Specific Requirements for Open Burning, Part 4 – Substituted Requirements,
Part 5 – Air Protection Measures, and Part 6 - Miscellaneous. The Open Burning Smoke Control
Regulation 405/19 is under effect as of September 15, 2019 and has replaced the repealed
Open Burning Smoke Control Regulation 145/93. Revision 3 (November 2019) of the SMP is to
reflect the regulatory changes reflected in the recently enacted OBSCR. This plan may need to
be reviewed and updated to reflect any future changes in legislation.

11 B.C. Hydro. 2016. Construction Environmental Management Plan, Site C Clean Energy Project Revision 4.
12 Environmental Management Act S.B.C. 2003, c. 53
13 BC Reg 405/19

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2.1.2 Wildfire Act and Wildfire Regulation

The Wildfire Act14 and Wildfire Regulation 15 define the legal responsibilities and obligations
regarding fire use, wildfire prevention, wildfire control, and rehabilitation. These pieces of
legislation are the responsibility of the Ministry of Forests, Lands, and Natural Resource
Operations and Rural Development (MFLNRORD) and, more specifically, the BC Wildfire
Service (BCWS). The Wildfire Regulation lays out the responsibilities of a person or entity
igniting a fire including, but not limited to: ensuring no fire escapes, providing sufficient fire
suppression systems and personnel, and defining fire control requirements in the case of an
escape. Additionally, it is the Wildfire Regulation which requires notification to the MFLNRORD
(Burn Registration Number), depending on the category of burn defined by the size and number
of piles ignited16, as well as the information required to receive the registration number 17.
Although the Wildfire Regulation does not address smoke control or air quality, it is directly
relevant to open burning.

2.2 Site-C – Specific Conditions

2.2.1 Federal Decision Statement
The Federal Decision Statement, issued November 25, 2014, by the Minister of Environment
Canada and under Section 54 of the Canadian Environmental Assessment Act, 2012 (CEAA),
establishes conditions with which BC Hydro must comply. Relevant to the Smoke Management
Plan is Section 12 – Health of Aboriginal Peoples – Air Quality. Specifically, Section 12 requires
measures to avoid or minimize exceedances of federal and provincial air quality objectives and
to minimize or manage the potential effects of smoke.

2.2.2 Environmental Assessment Certificate Schedule B – Table of Conditions

The Environmental Assessment Certificate was issued with 77 Conditions under which the
project may proceed. The following conditions are directly applicable to the SMP:
• Condition 57, which outlines provincial conditions regarding ambient air quality,
specifically the requirements regarding an Air Quality Management Plan and a Smoke
Management Plan. This condition mandates that project-related smoke is controlled by
following the OBSCR. Additionally, the plan is to include measures to manage emissions
and procedures to provide MOE with: 1) data collected during monitoring; and, 2) the
SMP and any amendments for review.
• Condition 70, which stipulates that Project effects through construction and operations
must be managed by implementing measures detailed in mitigation and monitoring
plans, such as this SMP and the Contractor’s Environmental Protection Plan.

3.0 Scope
The smoke management plan outlines the practices for burning clean woody / vegetative debris
(open burning) to manage the effects of smoke emissions from burning, to reduce the risk of an

14 Wildfire Act S.B.C. 2004, c. 31

15 BC Reg 38/2005
16 BC Reg 38/2005, s. 22 (1) (c)
17 BC Reg 38/2005, s. 24 (1)

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escape, and to meet all regulatory requirements relevant to open burning. The scope of the
smoke management plan is limited to open burning practices implemented as part of the Site C
Clean Energy Project.

4.0 General Requirements

All burning activities will be compliant with, or exceed the requirements of, the BC OBSCR18.
The following measures have been developed in accordance with these existing regulations and
other relevant regulatory requirements:

1. general requirements;

2. identification of smoke sensitivity zone(s);

3. material to be burned;

4. timing of burning;

5. minimum set-back distances;

6. ignition criteria and burn duration;

7. burn registration; and,

8. Records and reporting.

Best Management Practices (BMPs) are intended to provide operational direction to, as much
as practicable, promote fast and efficient burns which minimize the amount of smoke generated
and confine smoke emissions as much as possible to periods with favourable venting thereby
minimizing potential impacts of smoke from burning activities, and minimize the chance of fire
escape. BMPs are outlined in Sections 5.0, 6.0, and 7.0 include direction in the following areas:

1. seasonal burn planning;

2. debris pile construction and seasoning;

3. pre-burn protocols;

4. light-up procedures;

5. monitoring and tracking; and,

6. Notification and wildfire reporting.

18 BC Reg. 405/19

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4.1 Identify Sensitivity Zones

The OBSCR and allowable burning practices are based upon three spatial Categories: high,
medium and low smoke sensitivity zones. The zones are based upon distance from populations:
the ‘high’ zone is immediately surrounding communities, while the ‘low’ zone is farthest from
population centers.

To identify the relevant sensitivity zone, use the provincial interactive mapping application found
here:
https://governmentofbc.maps.arcgis.com/apps/webappviewer/index.html?id=6d288bc667b2452
8a5c1e3b4c0373d07.

The smoke sensitivity zone and relevant operational requirements (burn criteria) for open
burning is designated per pile and by pile location.19

In addition to the aforementioned regulated spatial zones, through ground-truthing exercises

with Aboriginal groups, or during the notification period, locations of high Aboriginal use may be
identified, and shall be treated as high smoke sensitivity zones during planned burning activities
(i.e. utilize burn criteria for high smoke sensitivity zones).

4.2 Material to be Burned

This smoke management plan applies solely to open burning of vegetative (clean woody) waste
that meets Category 2 and Category 3 pile sizes and has been piled within a 5 km radius of
where the vegetative debris originated. 20

In areas where operations vary between the two Category of burns (Category 2 and Category
3), differences will be noted, else, practices and operations will be the same.

Prior to open burning, BCH and the contractor must ensure that every reasonable alternative for
reducing, reusing, or recycling the vegetative debris has been used in order to minimize the
amount of debris burned. 21 Vegetative debris usage is detailed in the Vegetation Clearing and
Debris Management Plan.

Open burning that does not meet the definition provided above is outside the scope of this SMP
and may require additional permits from the MOE.
Regulations prohibit the burning of the following material in any quantity: animal carcasses;
asphalt or asphalt products; batteries; biomedical waste; carpets; construction waste other than
lumber that has not been treated with wood preservatives or other chemicals and is not coated
with paint, varnish, oil or other finishing material; demolition waste; electrical wire; fibreglass and
other fibre-reinforced polymers; fuel and lubricant containers; furniture and appliances;
hazardous waste; manure; paint and varnish; plastics; polystyrene foam; railway ties; rubber; tar
paper; tires; treated or painted wood products; and used oil.22

19 Personal communication (email), October 10, 2019 from [email protected].

20 BC Reg. 405/19, s. 9
21 BC Reg. 405/19, s. 10
22 BC Reg. 405/19, s. 12 and BC Reg. 320/2004, schedule 1, s. 2

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4.3 Timing of Burning

Open burning may occur when in accordance with all burn criteria, including acceptable venting.
See Section 4.3 for burn criteria and Section 4.5.3 for details on acceptable venting forecasts.
Prior to ignition, it must be confirmed that there are no other burning restrictions in place. This
includes burning restrictions from relevant local government 23, the MOE24, and MFLNRORD
(bcwildfire.ca), all of which supersede venting indices or venting forecasts, including custom
venting forecasts (CVF).25 The OBSCR grants the MOE the authority to prohibit burning in an
area during periods of poor air quality, when it is likely that air particulate matter will reach
unacceptable levels within 24 hours26, or when pollution is occurring or likely to occur from open
burning.27 In these circumstances, the MOE may require fires extinguished, prohibit additional
debris added to the fire, or prohibit ignition.
Burning may not be initiated if the local air flow or atmospheric mixing is likely to cause smoke
to have a negative impact on a nearby population or workcamp or create a navigational hazard
at nearby airports or on nearby highways by significantly reducing visibility.28 Both of these
conditions override the existence of an acceptable venting forecast and/ or compliance with all
other burn criteria.

4.4 Setback Distances

The minimum fire setback distances that will be maintained for burning operations carried out
under the Site C SMP are described in Table 1.
Areas may be identified during ground-truthing exercises with Aboriginal groups, or through the
notification process, that meet the definition of “seasonal residence”. Identified seasonal
residences will have appropriate fire setback distances applied ( Table 1).

Table 1. Setback Distances

Modified Setback
Category Setback Distance (m) 29
Distance (m) 30

Neighbouring buildings: residences

(including seasonal residences in 500 100
use), businesses
Nearest property line of: hospitals,
schools, community care facilities, and 1,000 500
identified sensitive receptors 31

23 BC Reg. 405/19, s. 6(a)

24 BC Reg. 405/19, s. 30(1)(a)(b)
25 BC Reg. 38/2005, s. 22(1)(a)
26 Specifically, when the amount of particulate matter in the air in an area has reached, or will reach within 24 hours, a level

that is likely to result in the air quality not meeting the ambient air quality objectives set out in Schedule 2 of OBSCR.
27 BC Reg. 405/19, s. 30(1)(a)(b)
28 BC Reg. 405/19, s. 14(a)(b)
29 BC Reg. 405/19, s. 13(1) and the Site C Clean Energy Project Construction Environmental Management Plan Appendix B - Air

Quality Monitoring Program

30 BC Reg. 405/19, s. 13(2)
31 Identified sensitive receptors as outlined in the CEMP Appendix B – Air Quality Monitoring Program.

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Modified setback distances are allowed under OBSCR, when open burning complies with
specific burning conditions. The burn criteria for modified setbacks is detailed in Table 4 of
Section 4.5.1. Open burning utilizing air curtain incinerators have unique setbacks to pile
burning; setbacks for air curtain incinerators are found in Table 5 of Section 4.5.2.

Sensitive receptors for the area have been identified in Environmental Impact Statement (EIS)
Volume 2 Appendix L. Those sensitive receptors which require a minimum setback of 1,000 m
are enumerated in Table 2. Regardless of sensitive receptors listed in Table 2, any and all
hospitals, community care facilities, or schools require setbacks based on relevant burn criteria,
as outlined in Table 1, Table 4, or Table 5.32

Table 2. Sensitive Receptors Requiring a Setback Equivalent to Hospitals, Schools, and

Community Care Facilities, as Identified in Appendix B Air Quality Monitoring Program of the
Construction Environmental Management Plan (CEMP).
Schools Health Care Facilities Senior Care Facilities Childcare Facilities
Aboriginal Education Fort St. John Health Heritage Manor III Chunky Monkey
Center Unit Daycare

Alwin Holland Fort St. John Hospital Peace Lutheran Apt. Oscare
#1 Daycare/Oscare Tots

Baldonnel Elementary Fort St. John Medical Peace Lutheran Apt. The Zoo Daycare
Clinic #2

Bert Ambrose Fort St. John The Sunset Home Little Kritters Daycare
Elementary Pharmacy and
Wellness Centre
Bert Bowes Middle The Taylor Medical North Peace Care ABC & 123 Family
School Clinic Centre Daycare

Board Office ABC Medical Clinic Abbeyfield Houses of Baby Bear Daycare
Fort St. John

Charlie Lake North Peace Medical New Senior Housing Rascals

Elementary School Clinic

Christian Lif e School Peace Villa Building Blocks

Daycare

CM Finch Elementary Kidz Club

Dr. Kearney Middle Northern Lights

School College Daycare

Duncan Cran Little Bear Family

Elementary Daycare

32 BC Reg. 405/19, s. 13 (1) and (2)

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Schools Health Care Facilities Senior Care Facilities Childcare Facilities

École Central Little Peanuts Family
Elementary Daycare

Facilities and Little Pigs Family

Transportation Daycare

Key Learning Centre Nanny Norma’s

Daycare

North Peace Pitter Patter Day Care

Secondary

Energetic Learning Puddle Jumpers

Campus

Northern BC Distance Seeds to Sow

Education

Open Learning The Playground

Family Daycare

Robert Ogilvie The Wiggles and

Elementary Giggles Daycare

Student Support TJ’s Playhouse

Services

Taylor Elementary Tot’s and Tikes Family

Daycare

Technology Services The Stepping Stones

Centre

Upper Half way Aboriginal Head Start

Elementary

Wonowon Elementary Child Development

Centre

Keeginaw Pre-School

Totem Pre-School

Rise and Shine

Clubhouse

Barney and Friends

Family Daycare

Hudson's Hope
Playschool

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Best Management Practices shall be employed so that smoke does not negatively impact a
nearby population centre or workcamp or pose a hazard at airports or on provincial highways by
significantly reducing visibility.33

4.5 Burn Criteria

Four components combine to define the timing of debris pile ignition and the burn duration
(length of allowable burning), specifically, open burning division, smoke sensitivity zone, venting
forecasts, and setbacks.

There are five acceptable divisions within OBSCR under which open burning can occur, two of
which are likely to be employed under the Project:

1. Division 1 – High, Medium and Low Smoke Sensitivity Zones.

2. Division 5 - Air Curtain Incinerators.

33 BC Reg. 405/19, s. 15 (a) and (b)

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4.5.1 Division 1 – Open Burning by High, Medium, and Low Smoke Sensitivity Zones
Table 3 outlines the specific burn criteria for burning in high, medium and low sensitivity zones.

Table 3. Burn Criteria for Open Burning Completed Under Division 1 by High, Medium, and Low Smoke Sensitivity Zones34.
Division 1 – Open Burning by Smoke Sensitivity Zone

Sensitivity Zone High (HSSZ) Medium (MSSZ) Low (LSSZ)

Setback Residences and Businesses: 500
Distances (m)35 Schools, hospitals, and community care facilities: 1000
Burn Duration < 2 days < 1 day < 4 days < 1 day < 6 days
Venting Indices Good (Day Open Good Good (Day Open Burning Good Good or Fair (Day Open
Required Burning Starts), Fair Starts), Fair or better Burning Starts) and Good
or better (Second (Second day of burning) or Fair (f or the Second Day
day of burning) of Open Burning)
Ignition Time Not earlier than 1 hour af ter sunrise During the burning period
Period for Between 1 hour af ter During the Between 1 hour af ter During the burning During the burning period
Igniting Piles of sunrise and 4 hours burning period sunrise and 2 hours period
Unlit Vegetative bef ore sunset on the bef ore sunset on the day
Debris day that open that open burning starts
burning starts
Period for Between 1 hour af ter During the Between 1 hour af ter During the burning During the burning period
Adding Unlit sunrise and 4 hours burning period sunrise and 2 hours period
Vegetative bef ore sunset on the bef ore sunset on the day
Material to day that open that open burning starts
Ignited Piles burning starts and on the second day of
open burning
Burning Ends36 4 pm on the second 4 pm or two 4 pm on the f ourth day of 4 pm or two hours 4 pm on the sixth day of
day of open burning hours before open burning bef ore sunset, open burning
sunset, whichever is later,
whichever is on the same day
later, on the open burning starts
same day open
burning starts

34 BC Reg. 405/19, ss. 19 - 22

35 BC Reg. 405/19, s. 13(2). Open burning is allowed within modifie d setbacks, as per Section 13 (2), OBSCR 405/19. Additional burn criteria apply and are outlined in Table 4.
36 "end", with regards to when open burning ends, as defined in BC Reg. 405/19 Part 1 and in the glossary.

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Division 1 – Open Burning by Smoke Sensitivity Zone

Sensitivity Zone High (HSSZ) Medium (MSSZ) Low (LSSZ)

Seasoning37 Vegetative debris must be seasoned The amount of seasoned Vegetative debris The amount of seasoned
Requirements vegetative debris must be must be seasoned vegetative debris must be
maximized maximized
Ventilation Ventilation forecast for the area must be obtained on the day, but before burning starts
Forecast
Requirements
CVF CVF f or the area must be obtained on the day before or on the day, but before burning starts
Requirements

37 As defined in BC Reg. 405/19 Part 1 and in the glossary.

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Despite the setbacks detailed in Table 3, when completing open burning as per Division 1, open
burning may be carried out within modified setbacks, if the additional burn criteria conditions laid
out in Table 4 are met with respect to the open burning.

Table 4. Burn Criteria for Open Burning in Modified Setbacks.38

Modified Setbacks (Division 1 – Open Burning by Smoke Sensitivity

Zone)
Setback Residences and Businesses: 100
Distances (m) Schools, hospitals, and community care facilities: 500
Piling Vegetative debris must be piled before it is open burned
Pile Dimensions Largest horizontal dimension is not greater than twice the height (e.g. for a pile
4 m tall, horizontal dimension must be ≤ 8 m).
Reporting Written record of the dates the vegetative debris was piled is available to an
of ficer upon request.
Pile Composition No stumps; largest part of each separate portion of the vegetative debris has a
diameter < 50 cm; vegetative debris is seasoned vegetative debris
Notification (not All reasonable efforts are made to give notification of open burning to:
later than 24 hours occupants of residences, businesses, schools, hospitals and community care
in advance of f acilities within 500 m.
starting open Notif ication to the persons who manage the school, hospital or community care
burning) f acility.
Ventilation Good
Forecasts
Ignition Time Not earlier than 1 hour af ter sunrise
Burning Ends 4 pm or two hours before sunset, whichever is later, on the same day open
burning starts
Other Ventilation
• Ventilation forecast for the area must be obtained on the day, but
Requirements
bef ore burning starts, or
• CVFs f or the area must be obtained on the day before or the day of
burning, but before burning starts.

4.5.2 Division 5 – Open Burning Using Air Curtain Incinerators

Open burning using air curtain incinerators is exempted from setbacks, as outlined in Section
4.4 and Table 1, as well as piling and seasoning requirements. Setbacks specific to the use of
air curtain incinerators are dependent upon meeting open burning criteria and are outlined in
Table 5.

38 BC Reg 405/19, s. 13(2)

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Table 5. Burn Criteria for Open Burning Under Division 5, Using Air Curtain Incinerators. 39
Distance of open burning Distance of open burning
from values (m) from values (m)
Neighbouring buildings 100 - 1000 1000+
residences (including seasonal
residences in use), and
businesses
Nearest property line of 500 – 2000 2000+
hospitals, schools, community
care f acilities, and identified
sensitive receptors.
Opacity40 requirements Does not exceed 40% during the 30-minute period following the
start of open burning and does not exceed 15% for more than 5
consecutive minutes during any other 30-minute period during open
burning
Vegetative debris stacking Vegetative debris is not stacked above the air outlet of the air
curtain incinerators.
Operational continuity Air curtain blowers operate continuously until the incinerators cease
combustion of the vegetative debris or until all the vegetative debris
has been reduced to ash
Ignition Time Not earlier than 1 hour af ter N/A
sunrise
Timing of addition of vegetative From one hour after sunrise to N/A
debris sunset
Ventilation forecast Fair or better for the day open N/A
burning is carried on; a Poor
f orecast for the day requires that
no more vegetative debris is
ignited

4.5.3 Venting Forecasts

Venting forecasts are issued every morning for the current and next day. The forecasts include
the ventilation (or venting) index (VI), wind speed, and mixing height to help guide burning
operations. Forecast venting conditions for the day of the burn and the following day, if
applicable, must meet the minimum venting requirements laid out within the OBSCR and in the
relevant burn criteria table (Table 3, Table 4, Table 5).

BC Air Quality defines VI as; “a numerical value related to the potential of the atmosphere to
disperse airborne pollutants, such as smoke from a prescribed fire. It is based on both the
current wind speed in the mixed layer and the mixing height. The mixed layer is the surface
layer of air that is turbulent and well mixed. The mixing height is the thickness of this mixed
layer.” Greater wind speeds and thicker mixing heights will result in higher venting indices. It
should be noted; however, when wind speeds are too high, ground level mixing may be
reduced.

A VI of 0 means that there is no ability for the atmosphere to disperse smoke, whereas a VI of
100 means excellent smoke dispersion; the persistence of smoke from open burning is tied

39 BC Reg 405/19, s. 28
40 As defined under BC Reg 405/19, s. 28(1) and the glossary.

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directly to atmospheric venting conditions. The numerical values are categorized into three
ranges: poor, fair, and good (Table 6). Category boundaries may differ in some jurisdictions; the
ventilation forecast provides both the numerical value, as well as the ventilation category.
Regulatory requirements outline minimum requirements for ventilation category.

Table 6. Venting Indices

Venting Index Numerical Rating Ventilation Category

0-33 Poor

34-54 Fair

55-100 Good

4.5.3.1 Venting Forecast Sources

There are three acceptable sources for daily venting forecasts: custom venting forecasts
(CVFs), Environment Canada regional forecasts, and qualified independent forecasters (details
for each source are found in the following subsections). The source of daily forecasts for
burning under this SMP will be CVFs, with few exceptions as noted below.

Custom ventilation forecasts must be obtained by a custom ventilation forecaster, as per

OBSCR. 41

There may be times when a CVF for the burn area is not available. In the circumstance that
CVFs are unavailable, contractors shall utilize the Environment Canada ventilation forecasts.
Contractors must record the daily forecast and source, as well as results of test burn, if
applicable. More information on recording and reporting is found in Section 5.

In summary, the source for daily ventilation forecast shall be used in the following order:
1. CVF subscription service, then
2. Environment Canada regional forecast.
It is not allowable to select the forecast that is the most favourable for operations or that best
suits burning objectives.

A retained, independent, MOE-approved forecaster would replace the CVF subscription service
for ventilation forecasts listed above.

Custom Venting Forecasts

To encourage the best dissipation of smoke, burning under this smoke management plan will
use custom venting forecasts prepared by a custom ventilation forecaster. Custom venting
forecasts are tied more closely to specific geographic locations than Environment Canada
forecasts which are prepared for a larger regional area. For this reason, custom venting
forecasts are generally thought to be a more accurate choice than Environment Canada venting
indices, which often can result in a forecast which is either too strict or too lenient for those
locations which are not well-represented by the average area or region for which the forecast
was prepared.

41 BC Reg 405/19, s. 16

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The provincial fire centre weather forecasters are approved by the MOE and shall be retained
by the contractor through subscriptions for service to provide custom venting forecasts. Custom
forecasting subscriptions are generally available for the fall burning season. To set up
subscription and receive MOE-approved CVFs, the contractor shall contact the regional MOE
contact (see section 7.3 Key Contacts).

The contractor shall provide the following information to the forecaster, where burning is
anticipated: Burn Registration Number, location, latitude /longitude, elevation / elevation range,
and approximate number of piles. 42

Environment Canada Forecasts

The Environment Canada daily venting indices for the Fort St John Zone can be found at:
https://www2.gov.bc.ca/gov/content/environment/air-land-water/air/air-pollution/smoke-
burning/ventilation-index or by phoning 1-888-281-2992 (See Section 7.3).

Independent Qualified Forecasts

BC Hydro may hire an independent, qualified forecaster to provide custom venting forecasts. It
is required that all independent forecasters meet the OBSCR definition of custom ventilation
forecaster and are approved by the MOE Director in advance of any burning activity which
depends upon their forecasts. 43 The first step in forecaster approval is contacting the regional
MOE contact (See Section 7.3).

If either BCH or a contractor retains an independent forecaster, the forecasts will take the place
of the CVF subscription service. Documentation of MOE approval must be recorded and kept on
file.

4.5.4 Burn Duration / Burning Period

The burning period is the time between ignition and burn end, as outlined in the applicable burn
criteria. Burn ‘end’ for pile burning means the point in time when each pile of vegetative debris
has ceased flaming and is emitting smoke from no more than 10% of its burnt surface area. 44

Smoke release monitoring is the monitoring of burning activities in accordance with burn
duration commitments, based upon smoke sensitivity area, setback, and Division under which
open burning is occurring. Burn duration commitments are detailed in Table 3, Table 4, and
Table 5. Smoke release monitoring and tracking is detailed in Section 6.1.

Burn duration is measured per pile.45 Each pile that is ignited must individually adhere to burn
duration / burn period.

42 A general rule of thumb which may be helpful for estimating number of piles is: (NAR * 2 = # of piles), where NAR = Net Area
to be Reforested (ha) = Area Harvested / Cleared.
43 BC Reg 405/19, Part 1 and pers. comm. Gail Roth, Ministry of Environment, August 3, 2017.
44 BC Reg 405/19, Part 1
45 Personal communication (email), October 10, 2019 from [email protected].

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The regulation allows for vegetative debris to be open burned up to 5 km from the point of
origin. In the case that longer burning period or more flexibility on venting conditions, vegetative
debris originating within the HSSZ may be moved to the MSSZ, within 5 km, for open burning.

4.5.5 Change in Burning Conditions

Should weather conditions change such that local airflow or atmospheric mixing is causing or
likely to cause make smoke dispersion inadequate, specifically to negatively impact a nearby
population or work camp or to be a navigational hazard at an airport or on highways by
significantly reducing visibility, debris may not be added to an open burn until conditions
improve and is no longer causing to have effects described as above.46

4.6 Burn Registration

4.6.1 Category 3 Piles

Prior to the initiation of any Category 3 burns, the contractor shall obtain a Burn Registration
Number (BRN).47 BRNs are obtained through the BC Wildfire Service at 1.888.797.1717. BRNs
are valid for one parcel and for a two-week period after which time they may be re-issued
through the same process. A separate BRN is required for each parcel on which open burning is
planned. The following information is required in order to receive a BRN: contact information for
person initiating burn (contractor information), parcel description / coordinates of open burning
(center point of area for parcels with multiple piles), the number of piles to be burned under the
BRN, type of material to be burned, and any other information relating to the proposed open fire
that the official or the person answering the telephone number requires.48

The following is required for compliance with the BRN49: check venting indices (CVFs) prior to
ignition; comply with OBSCR, local bylaws, local and provincial fire bans, the Wildfire Act and
Wildfire Regulations. Following this SMP will ensure compliance with the BRN.

BRNs must be recorded and kept on site during burning activities. Details regarding required
contractor recording and reporting are found in Section 6.2.

4.6.2 Category 2 Piles

Category 2 burns do not require a BRN. When completing Category 2 burns, the contractor
shall record size (height and width), number of piles burning concurrently (two or fewer), and
number of piles burned through the day. Piling and burning may be done concurrently, under
the condition that pile number or size do not exceed maximums allowed for Category 2. Details
regarding required contractor recording and reporting are found in Section 6.2.

46 BC Reg 405/19, s. 15
47 BC Reg. 38/2005, s. 22(1)
48 BC Reg. 38/2005, s. 24(1)
49 Pers. comm. Operator at BCWS BRN phone number.

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Category 2 burns as part of industrial operations must adhere to all OBSCR regulations, and
therefore contractors must: check venting indices (CVFs) prior to ignition; comply with OBSCR,
local bylaws, local and provincial fire bans, the Wildfire Act and Wildfire Regulations.

4.7 Records and Reporting

OBSCR requires all Category 3 and open burning with use of an air curtain incinerator record
and maintain specific information, with respect to open burning.50 The documentation must be
kept on site and available for the duration of the open burning, retained for a period of one year
from the start of burning, and submitted to the MOE upon request. Details on required
information to achieve regulatory compliance are found in section 6.2.

5.0 Smoke Reduction – Best Management Practices

Best Management Practices (BMPs) provide guidance to debris management contractors and
BCH monitors for opening burn activities and smoke management to help achieve smoke
management objectives and compliance with regulatory requirements. The OBSCR requires all
reasonable efforts are taken to minimize the amount of smoke emitted when open burning. 51
The strategies and techniques within the BMPs of this section shall ensure that this requirement
is met. Specific regulatory requirements outlined in the OBSCR will be identified within the
BMPs, where appearing.

5.1 Seasonal Burn Planning

5.1.1 Burn Season
Typically, the late summer / early fall offers better burning conditions in terms of fire weather
indices and longer daily average of appropriate venting (i.e. longer days). Additionally, this
window provides the best window to avoid “holdover” fires; fires that do not extinguish during the
winter months can retain the potential to ignite dead grass and forest fuels in the early spring
fire season (usually April and May). Fires in late summer and fall have the most time to
extinguish on their own in the winter months. Fire hazard abatement monitoring is detailed in
Section 6.1.
Burning outside the usual burning season (as noted above) is acceptable, given that the
regulatory requirements as set out in this SMP are followed, regardless of seasonal timing (i.e.
open burning is compliant with all applicable burn criteria, such as venting indices are checked
and favourable, there are no provincial or local fire prohibitions, BRN is received, if applicable,
and burns comply with all provincial legislation and regulations (OBSCR, Wildfire Act and
Wildfire Regulation).

5.1.2 Burning Prioritization

Any burning within high smoke sensitivity zones should be prioritized to take advantage of the
best venting conditions and longer daytime hours to allow for optimum conditions in those areas
closest to populations.

50 BC Reg 405/19, s. 31.

51 BC Reg. 405/19, s. 11

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5.1.3 Sensitive Time Periods

Seasonal scheduling of burning activities will consider regionally important time periods, for
example periods with high recreational activity or periods with known Aboriginal use based on
the results of ground-truthing exercises. During, and two days prior to, sensitive time periods, no
debris piles will be ignited.

Based on regional recreation activity, the following periods have been identified as sensitive:

• long weekends in May, July, August and September

• Aboriginal use periods – may be determined based on ground-truthing exercises and

through the First Nations notification process. Burning practices may require
modification based upon responses received from notification. For details regarding
burning notification, see Section 7.1.

5.2 Debris Pile Construction and Seasoning

Proper pile construction techniques will aid in the achievement of a high intensity burn that is
capable of consuming itself in the shortest time possible and achieve easy and safe ignition.

5.2.1 Pile Size, Shape and Components

Pile construction shall consider the following:

1. Piles should be roughly conical (haystack or bell-shaped) with a width to height ratio
of roughly 2:1. In all cases, piles must be stable. 52

2. Large piles typically burn hotter and cleaner than smaller piles. Efforts should be
made to make fewer, larger piles, while considering crew safety and meeting the
smoke release period criteria. Ideally, pile height of 4 m, or higher, is recommended.

a. Category 2 burns are a maximum size of 3 m in width and 2 m in height

(maximum of two piles burning concurrently per parcel).

3. Coniferous slash often burns better than deciduous (aspen/cottonwood) slash.

Efforts should be made to mix fuel types, where practicable.

4. To ensure the continuity of the burn, piles should contain a mixture of debris sizes
(mixture of fines with larger diameter material) with as few voids as possible. 53

5. To achieve efficient ignition, place smaller diameter fuels at the base to create an
ignition zone, ideally 2 m thick.

52 To help achieve compliance with BC Reg. 405/19, s. 11(b)

53 To help achieve compliance with BC Reg. 405/19, s. 11(b)

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a. For Category 2 piles, create a good mixture of small and large diameter
fuels throughout the pile. Due to reduced size, a 2 m ignition zone is
neither ideal, nor feasible.

6. Minimize soil content that may be mixed in with vegetative debris; break root wads
up to remove any soils/rocks prior to piling and place pieces higher on the pile. 54

7. Within the high sensitivity smoke zone, all vegetative debris burned (piles) must be
seasoned, such that the pile is 30% or less moisture content, originates from dead
standing timber, or has been piled for a minimum of 4 months55. Pile covering is an
option to keep fuel moisture content low; remove covering prior to burning.

8. Within the medium sensitivity smoke zone, within each pile maximize the amount of
vegetative debris which is seasoned vegetative debris; piles should be seasoned
until they can easily combust. Ideally seasoned piles would be 30% or less moisture
content or piled for at least 4 months. 56 Pile covering is an option to keep fuel
moisture content low; remove covering prior to burning.

9. Establish a fuel break around each pile. 57 Determining necessary f uel break width
and type should consider, but not be limited to, the following variables: pile size,
proximity to adjacent fuels, type of fuels burning and adjacent, fire weather, slope,
and aspect. Fuel breaks are defined as: 1) a barrier or a change in fuel type or
condition, or 2) a strip of land that has been modified or cleared. 58

a. Examples of potentially acceptable fuel breaks, depending on the

variables list above, may include: frozen soils to a depth of one foot,
snowpack on frozen soil, or removal of all combustible material / biomass
to mineral soil to a width determined to be sufficient for conditions.

10. Maintain fuel breaks while the fire is burning and there is a risk of the fire escape .59

Additional considerations:

11. Do not construct piles in low, water-receiving sites. Low water-receiving sites are
defined as any location where the water table is at the soil surface such that fuels are
not be able to season or would not be able to achieve ideal fuel moisture content for
burning. Areas to avoid may include swales, wetlands, low-lying flood plains, or
areas of seepage. This is to ensure that fuels achieve the desired fuel moisture
content and therefore burn hotter and with less smoke emission. Piles should be built
in locations which are dry (water table not at the surface) for more than 4
consecutive months from spring to winter, not including moisture received during

54 BC Reg. 405/19, s. 11(a)

55 BC Reg. 405/19, s. 19(a)
56 BC Reg. 405/191, s. 1(c)
57 BC Reg. 38/2005, s. 22 (1)
58 BC Reg. 38/2005, s. 1 (1)
59 BC Reg. 38/2005, s. 22 (1) (f)

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precipitation events, and which are not likely to have the water table at the surface
during the desired burning window.60

12. Do not construct piles within riparian reserve zones (RRZ)61, unless directed by BCH
due to operational or topographic limitations. Any machine work will be conducted in
accordance with CEMP Section 4.5 (15 m machine-free riparian buffer from the
Ordinary High Water Mark).

13. Do not construct piles within the minimum setbacks outlined in Table 1, unless open
burning using an air curtain incinerator.

a. Setbacks for air curtain incinerators can be found in Table 5

14. Do not pile where burning will negatively impact (scorch) the timber edge or retained
trees. Larger, machine-built piles will require larger setbacks, whereas smaller, hand-
built piles can be closer.

15. Avoid introducing soils and other non-combustibles into the pile. 62

5.3 Pre-Burn Protocols

5.3.1 Collate Burn Plan Information

Prior to the burning season, contractors shall collate information related to the smoke sensitivity
zone and the approximate number and location (coordinates) of the piles slated for burning.
This information is required in obtaining Burn Registration Numbers (BRNs) (see Section 4.6).
This information must be available for BCH upon request.

5.3.2 Venting Forecasts

Confirm source of venting forecast: custom venting forecast, whether through a subscription
service provided by a MOE pre-approved forecaster or by retaining a qualified independent
forecaster, or regional forecasts from Environment Canada. See Section 4.5.2 for details
regarding venting forecast sources and acceptable utilization.

5.3.2.1 Limitations of Venting Index and Forecasts

Strict adherence to the venting indices (the computed value or category) may conflict with the
practical objective of minimizing potential impacts of smoke. There are limitations to the venting
index calculations, which shall be considered by the contractor prior to ignition. For example,
wind direction and proximity to potential values impacted are not incorporated into the venting
index. There may be additional impacts from changing weather, such as changing wind patterns

60 To help achieve compliance with BC Reg. 405/19, s. 11(c)

61 BC Reg 41/2016, s. 1 (1)
62 To help achieve compliance with BC Reg. 405/19, s. 11(a)

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and rain/snow events that may result in undesirable burning conditions or evening and overnight
venting conditions. It is important to consider wind direction and mixing heights.

Practical Application

The following adaptations shall be considered by the contractor prior to ignition, as appropriate:

• If wind direction is not favourable and smoke is likely to impact populations, highways, or
airports, burn instead in locations where wind direction works in favour of burn and
smoke travel.
• Consider moving to remote piles when forecaster confidence in continued good venting
is low.
• Consider prioritizing any high smoke sensitivity area burns when forecaster confidence
in continued good venting is high.
• Lower mixing heights will not have the capacity for large volumes of smoke, suggesting
that the ignition of a large number of piles should be avoided. Ignite fewer piles in these
situations to reduce overall volume of smoke emitted.

Despite acceptable venting forecast (e.g. good and fair) advancing weather conditions can
result in a rapid decline in venting leading to unacceptable levels of smoke.

Venting Forecast Validation

Venting forecast validation can be completed through ignition and monitoring of a test pile. After
test pile ignition, monitor the performance of the burn for 15-30 minutes relative to:

• Fire intensity.
• Smoke release (direction, dispersion, quantity and relation to important infrastructure
such as highways, airports, sensitive receptors, and population centres).
• Potential for escape to adjacent piles or slash.

With confirmation that the test pile is burning as planned, continue with the daily burn plan and
monitor pile burning performance throughout the day. Where significant reductions in burn
performance are noted, burning shall be halted or the burn plan revised to increase burn
performance to an acceptable level. Documentation of venting forecast validation, results, and
pile performance monitoring are the responsibility of the contractor. See Section 6.2 for details.

During Burning

If, during burning, it is determined that smoke dispersion is not ideal, potential adjustments to
daily burn plans could include one, or more, of the following strategies:

1. Ceasing to add new debris to the pile earlier in the day or imposing earlier end time
for ignition period to allow for more daytime burning.

2. Using accelerants to promote more rapid pile ignition.

3. Using forced air mechanisms to encourage hotter fires and more complete
combustion.

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4. Re-piling slash to improve pile construction.

5. Extinguishing burn pile.

5.3.3 Communication with Forecasters

The contractors shall communicate with the custom venting forecasters regarding burn
registration information. To maximize the effectiveness of the custom venting forecast, work with
the forecaster in identifying any additional information that may be required to ensure the most
accurate forecasts possible. This information may include specific pile elevation and timing
related to the issuance of forecasts. Forecast limitations should be discussed with the forecaster
and documented in the daily burn log, as applicable.

5.3.4 Training

Desired open burning outcomes are much more likely to be achieved if burning crews have the
appropriate level of experience and training. All supervisors, ground crews, and machine
operators shall be appropriately trained in regulatory requirements, BMPs, safe work protocols,
and Standard Operating Procedures and must be competent in operational fire and fire
suppression activities. Contractors must retain records of training and certification on site and
provide to BCH upon request. The following is a non-exhaustive list of areas of competency.

• Wildfire Regulation requirements;

• OBSCR requirements;
• Site C Smoke Management Plan –smoke management strategies and BMPs;
• burning criteria;
• burn pile construction;
• burn pile ignition;
• firefighting;
• wildfire reporting;
• fuel handling, storage and spill reporting; and,
• emergency response procedures (ERPs).

5.3.5 Environmental Considerations

The Contractor’s Qualified Environmental Professional (QEP) shall survey each burn pile prior
to light-up to confirm they are not actively being used as an animal den. QEPs may consider the
use of drones for den surveys. Den surveys shall have validity duration of 7 days, so if a pile is
not lit within this validity period the QEP must complete another den survey prior to light-up or
provide environmental rationale in weekly environmental monitoring reports justifying the
duration that the burn pile can be considered clear of animal dens. During the bird nesting
window (see the CEMP), and when Contractors intend to burn piles, the QEP shall also survey
each pile to confirm it is absent of active bird nesting activity. These bird nest surveys shall have
validity duration of 3 days, so if a pile is not lit within this time period the QEP must complete
another nest survey prior to light-up. The results of these den and nest surveys (as appropriate)
shall be available on-site at all times during burn activities and included in weekly reporting (see
Section 6.2). Any pile containing an active den or nest must be clearly marked in the field and
mapped and this must be communicated to crews in a documented tailboard so they can easily
identify it and not light it.

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5.4 Light-Up Procedures

Pile ignition may occur by ground crews or by aerial ignition (helicopters). It is critical to ensure
that all the logistics relative to the burning plan have been addressed prior to ignition. In order to
ensure this, a pre-burn checklist (go no-go safety checklist) and an ignition plan must be
completed.

5.4.1 Pre-burn Checklist

The pre-burn checklist should include all critical safety, regulatory, and operational variables. It
is the responsibility of the contractor to ensure that pre-burn checklists include smoke
management variables, as well as ensure compliance with other directly relevant legislation,
such as the Wildfire Act and Wildfire Regulation. A pre-burn checklist must be completed each
day one or more debris piles are ignited and separate checklists must be generated for each
area covered by a venting forecast and for burning in separate smoke sensitivity zones (e.g.,
separate pre-burn checklists are required for burns in a custom venting forecast area that spans
two or more smoke sensitivity zones). In the event that one or more boxes on the pre-burn
checklist are unable to be ‘ticked’, ignition must not occur.

Table 7 provides an example pre-burn checklist for operators.63

63Pre-burn checklist adapted from a variety of sources, including: BCTS Strait of Georgia Open Burning Checklist and BCWS Burn
Plan Template.

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Table 7. Example Open Burning Pre-Burn Checklist for Category 2 and Category 3 Fires. The Pre-
Burn Checklist may be Modified or Adapted to Better Suit Aerial Ignitions.

Parcel Description: Project Geographic Location:

Latitude (UTM): Longitude (UTM):

Category Area: Burn Category:

Completed by: Date:
Company Name:

Contact Phone Number(s)

(cell / office / other )
(cell / office / other )

MFLNRORD Burn Registration Number (required for Category 3 burns):

N/A Call 1-888-797-1717

ALL forest fires must be reported immediately to:

1-800-663-5555, or *5555, or to a regional manager, district manager, designated
forest official, or peace officer.
The BCH contact must also be notified as soon as possible.
This checklist is intended for informational purposes only. It is not legal advice. Regulatory obligations are
found in the Wildfire Act and Regulation and the Environmental Management Act and Open Burning Smoke
Control Regulation.
Definitions from Wildfire Regulation (2005) Section 1
Category 2 Open Fire: “…open fire that (a) burns material in one pile not exceeding 2 m in height and 3 m in width, (b) burns
material concurrently in 2 piles each not exceeding 2 m in height and 3 m in width, or (c) burns
stubble or grass over an area that does not exceed 0.2 ha.” (See W ildfire Regulation, S. 21).”
Category 3 Open Fire: “…open fire that burns (a) material concurrently in 3 or more piles each not exceeding 2 m height and 3
m in width, (b) material in one or more piles each exceeding 2 m in height or 3 m in width, (c) one or
more windrows, or (d) stubble or grass over an area exceeding 0.2 ha.” (See Wildfire Regulation, S.
22).”
‘NO’ = NO IGNITION

Element Yes / No / N/A Comments

PLANNING
Has smoke sensitivity zone been determined? Is it
understood how the smoke sensitivity zone impacts
operational activities (burn criteria)?
Are the piles sufficiently seasoned, according to the smoke
sensitivity zone?
• HSSZ – piles were constructed 4 months ago or
more, debris originates from dead standing timber,
or are ≤30% moisture content.
Has piling been completed according to the SMP such that
burning can be completed safely and effectively (including
surrounded by a fuel break) and such that the pile can be
consumed and burning end within the applicable burn
duration? If no, re-pile or allow to season .
Are pile locations >500 m from any inhabited residences or
business and >1,000 m from schools in session, hospitals,
continuing care facilities, and identified sensitive receptors
(unless burning under the burn criteria conditions stipulated
for modified setbacks)?
Are pile locations outside riparian reserve zones?

Are piles located according to BMPs: 1) outside of low-lying

and water receiving areas; 2) sufficient distance from
standing timber to avoid scorching; 3) sufficient distance
from surrounding bush to avoid scorching?
Is a site map available for workers on –site, as well as for
arriving responders in the event of an escape? Maps should
identify water sources, access/egress, potential helicopter
landings, etc.
A Qualified Environmental Professional has surveyed the
piles and confirmed they are free of active animal dens and
active migratory bird nests.
Are ERPs completed and on -site?
Are there any applicable burning bans or restrictions? Check
with BCWS and record fire danger rating .

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Is there a means to report a wildfire on site? (cellular, satellite

phone, or radio contact)
Does the venting index/ venting forecast meet OBSCR (day of
burn and following day)? Record rating.

Are there any Air Quality Burning Bans? Check with MOE.
Document communications.
Burn Registration Number received (Category 3 only)?
Legal obligations under the Wildfire Act and Wildfire Regulation
reviewed and understood?
Legal obligations under the Environmental Management Act
and Open Burning Smoke Control Regulation reviewed and
understood?
BCH SMP reviewed and understood?
Do the piles include only clean, woody waste / debris?

Have all notifications been completed and recorded in the

notification log?
Have you checked with the local Fire Department and
Municipality for local Bylaws that pertain to open fires and
permits which may be required ?
Has the crew briefing been completed?
WEATHER
Have you checked current and forecasted wind conditions?
Are the current and forecasted winds acceptable for
burning? If the wind is strong enough to carry sparks to
other combustible material, do not burn.
Check the detailed weather information, including Fire
Danger Class, Temperature, Relative Humidity,
Precipitation and Wind Speed for work site.
Ensure that a system is in place for site crew and supervisor to
keep notified of current and expected weather forecasts. (Keep
records)
Have site conditions that could lead to potentially dangerous
fire behavior or increase probability of spot potential or
escape, including slope, aspect, topography, fuels, access and
egress, been fully considered?
Have you checked wind direction and confirmed that wind
direction is favourable (will not negatively impact nearby
populations and will not pose a hazard at airports or provincial
highways by significantly reducing visibility)?
Was a test pile lit and results recorded?
SAFETY / SUPPRESSION CAPABILITIES
Is crew competent and trained to complete operational fire
and fire suppression activities? Keep training logs and
certifications on file.
Has all staff on-site been trained on a suppression/response
plan in the event of an escape?
Has a communication plan been established for reporting
escaped fire or other emergency situations?
Are available resources known, able to be contacted, and aware
of their responsibility to respond if contacted for containment of
potential escapes?
And does the list of resources meet the requirements of Wildfire
Regulation based on Category of fire?
Have sources of water for fire suppression been identified. If
none available, develop a contingency plan.
Ensure key contact information for reporting
emergencies is included in the ERP.
Is adequate suppression equipment available at
the burn area of a type and capacity adequate for
fire control if a fire escapes?
Are adequate personnel on site to ensure that the
fire does not exceed the capacity of the persons,
firefighting tools and h eavy equipment on site for
timely action to prevent fire from escaping ?
Is there a patrol on site equipped with at least one
firefighting hand tool and who will immediately
carry out fire control, if practicable, and who has
the means to report the fire and is aware of this
responsibility?
Crew members have adequate PPE and fire
suppression tools in good working order.

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5.4.2 Ignition Plan

A daily ignition plan shall be developed and provided to BCH prior to each day’s ignition
activities. It shall include, but not be limited to, personnel; ignition method, tactics, and
procedures; ignition location (e.g. GPS points of piles to be ignited or extents of ignition); and
flight plan.

5.4.3 Daily Ignition Period

The daily ignition period is the recommended time of pile ignition and has been designed to
coincide with the time of day where venting conditions are typically best and to ensure that there
is sufficient time remaining after ignition for the burn to consume most of the pile (Table 8).
Following daily ignition periods will increase the potential for burns to occur during the time of
day when venting is most favourable and minimize the release of overnight smoke when venting
is generally less favourable.

Table 8. Recommended Daily Ignition Period

Smoke Venting Forecast Venting Forecast Daily Ignition Period

Sensitivity Zone (Day of Ignition) (Day After Ignition)

High Good Fair or Better 1-hr after sunrise to

4-hr before sunset64
Medium Good Fair or Better 1-hr after sunrise to
2-hr before sunset65

Low Fair or Better Fair or Better 1-hr after sunrise to

2-hr before sunset

5.4.4 Pile Ignition

Pile ignition shall conform to the following:
1. Ignition should occur on the upwind side of the pile.
2. Ignition should be low on the pile.
3. To support rapid ignition, select a portion of the pile with the most ideal mixture of
piece size and distribution (i.e. choose a portion of the pile that most accurately
represents the characteristics of the piles, as described in Section 5.2.1).
4. When fine fuels are damp / green or when slash pile lacks the appropriate
distribution of piece sizes, consider using propane torches or fuel gel and forced air
mechanisms to encourage a better and hotter ignition. Alternately ignition can wait
until fuel moisture conditions are such that an ef ficient ignition and burn can be
achieved.
5. When aerial ignition is used, all ignitions shall follow the safe work procedures and
best practices of the helicopter company and the situational awareness and
judgment of the pilot.

64 BC Reg 405/19, s. 20 (d)

65 BC Reg 405/19, s. 21 (c)

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6.0 Monitoring and Tracking

6.1 Monitoring
Monitoring of pile burning will be undertaken at three levels; smoke release, debris reduction
and hazard abatement.

1. Smoke Release

After the allowable burning period ends, piles will be inspected for compliance with the burn
duration. If, at the end of allowable burn duration, the pile is found to be emitting smoke from
more than 10% of its burnt surface area66 (or with the use of an air curtain incinerator, the burn
is emitting smoke from more than 10% of the base of the air curtain incinerator) , then the pile
will be extinguished (debris broken up to achieve burn end).

In the event that debris reduction objectives have not been met at the end of the burn duration ,
available options include and may implemented, at the discretion of BCH:

• extinguish the pile and consider all operations for the pile to be complete;
• re-pile to facilitate cleaner burning and reignite under a new burning period with
acceptable venting and according to the relevant burn criteria; or,
• buck any long pieces to a length <4 m.

New piles will be considered a new burning period and must comply with this SMP and
regulatory requirements as a new burn. 67

Under all scenarios, BC Hydro and the contractor shall review the contributing factors to a burn
which exceeds the burn period and shall make appropriate compensatory changes to
subsequent burn plans.

It is the contractors’ responsibility to ensure compliance with burn periods. The contractor shall
document compliance and submit documentation to BCH weekly with the burn tracking
requirements (see 6.2.1 for details).

2. Debris Reduction

Debris reduction shall be assessed to ensure that the appropriate reduction in debris mass has
been achieved. If it is deemed that the level of debris reduction is not acceptable, BCH may
determine that the pile shall be: 1) extinguished, re-piled and ignited again; 2) bucked into
lengths shorter than 4 m; or, 3) left as-is.

3. Hazard Abatement

66 As defined in BC Reg 405/19, s. Part 1 and the glossary.

67 Personal communications: Earle Plain Air Quality Meteorologist email October 29, 2019.

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For the purposes of hazard abatement, piles will be monitored to ensure that the pil es are
completely extinguished. Category 3 fires must be extinguished by the date specified by the
official or person who issued the BRN. 68 Contractors must be able to display that each individual
pile is out. This can be achieved by cold trailing by hand or assurance by a thermal scan.

Depending on seasonal timing of burns, there may be potential for holdover fires to pop up in
the spring. Pile monitoring in spring shall be completed by the contractor to ensure holdover
fires do not cause unintended ignitions or burns. This risk is highe st in spring after snowmelt
and prior to green-up.69 Infrared scanning shall be completed immediately after the site is snow-
free and prior to hazard build up. Site conditions shall be monitored to determine appropriate
timing for infrared scanning, rather than relying solely on calendar timing to schedule scans.70

6.2 Tracking
Tracking, or documentation, is required to demonstrate diligence to the process, to demonstrate
compliance with legislation and commitments, and to help track efficacy and improve
performance. Tracking documents produced though activities related to this SMP include, but
are not limited to:
• Burn tracking form;
• Pre-burn checklist;
• Ignition plan;
• Burn period / smoke release form;
• Den and bird nesting surveys; and,
• Associated photo-documentation of the above.

6.2.1 Burn Tracking

Burn tracking begins prior to ignition and continues through to the time it is confirmed that the
fire is extinguished. Burn tracking provides valuable data for continual improvement, helps to
achieve compliance with regulations and BMPs, and tracks productivity. It is the contractor’s
responsibility to:

1. Ensure a pre-burn checklist and ignition plan is completed prior to ignition and
provided to BCH upon request (Sections 5.4.1 and 5.4.2, Table 7).
a. Note any diversions from ignition plan.
2. Record GPS coordinates of ignited piles, date of piling, and allowable burning
duration.
a. Pre-ignition, georeferenced photos of piles is recommended (or
alternative documentation system of an equivalent and measurable
monitoring system developed by the contractor and approved by BCH).

68 BC Reg. 38/2005, s. 22 (2) (b)

69 Personal communication, Doug Smith, BCWS, Prince George Fire Centre.
70 Personal communication, Cliff Laursen, BCWS, Prince George Fire Centre.

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3. Complete and submit the Burn Tracking Form daily (Table 9). The form provides
details on the progress of the burn plan, documents compliance, and provides
information related to burning criteria.
4. Document any changes to ongoing burn plans; note if or how the changes are a
direct result from monitoring feedback (Table 9).
5. Complete the burn period / smoke monitoring tracking form (or alternative equivalent
documentation system developed by the contractor).
a. Record ocular observations and photos related to achievement of burn
period per pile.
6. Complete and retain results of den and active-bird nesting surveys (Section 5.3.5).
The daily burn tracking form, burn period / smoke release monitoring documentation, photo-
documentation and den and bird nesting surveys shall be submitted weekly to the BCH
representative / project supervisor. All other documentation shall be available to BCH upon
request.

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 11/15/19, 10:30am – *Date / Ignition Period
11:30am

71
95 *Number of Piles

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94 Piles Ignited

1 Pile Remaining
BRN Information

123456 *Burn Reference #

REM SEC 3 TP 86 R Parcel Description (Legal, PID, or

24212W6M description)

56. 14 54.36 Latitude

31(1) Open Burning Smoke Control 405/19

Location

121.12 58.82 Longitude

700 m Elevation

Medium Smoke Sensitivity Zone

Page 42
11/18/2019, 4:00 pm Burn period end

CVF *Venting Source Used

65 (good) *Venting @ 4 pm Day 1 (VI/ VI

Category)
Custom Venting Forecast

52 (fair) *Venting @ 4 pm Day 2(VI/ VI

Category)

17 kph, NE / 6kph, N Wind speed and direction (Current

/ Forecasted)

Fort St John - NE Closest value and direction from

burn site

N/A – Category 3 burn Pile size (height and width)-

Category 2 Only

Y – 9:30am ignition, venting Test Burn (Y/N and results)

Revision 5: September 14, 2021

moderate, wind blowing
away from town. Clear skies.
6” snow on frozen soils, Fuel Break (type, width,
expanded 2’ during burn, maintenance)
watched and no fire spread

11:30 am checked Change in conditions / update

conditions, venting slightly (Time/ Comment)
improving, no reduction of
visibility.
Other Information

2:00 pm change in wind Change in conditions / update

speed and direction. Gusting (Time/ Comment)
to 35 km, S wind. Burn
halted.
(Category 2 / Category 3) would necessitate additional entries or additional forms. An asterisk (*) indicates reporting requirements from the OBSCR. 71

Photo documented test burn Additional comments

venting, afternoon venting,
and pre-burn piles.
Table 9. Burn Tracking Form, including an example entry. Ignitions on different parcels, different geographic location or Smoke Sensitivity Zone, or difference in Burn Category
Site C Clean Energy Project
Smoke Management Plan
 11/15/19, 3:45 pm Date / Time of Day

123456 Burn Reference #

REM SEC 3 TP 86 R 24212W6M Parcel Description (Legal, PID, or

sitecproject.com
description)

56. 14 54.36 Latitude

General information

121.12 58.82 Longitude

Medium Smoke Sensitivity Zone

<4 days Allowable Burn Duration

Allo
11/15/17, 10:30am Pile Ignition Date / Time

11/18/2019, 4:00 pm Burn period end

~5% % of burnt surface area emitting

Page 43
smoke
Smoke release / burn duration monitoring

None required; smoke release in Action taken

compliance with burn end (<10%)

Cold trail or thermal scan to ensure pile Follow-up recommended

is extinguished (spring 2020)
Table 10. An example of an acceptable burn period / smoke release monitoring form.

2m x 3m x1 m Pile size (m) (unconsumed

vegetative debris remaining)

1 piece >4 m Piece size (note number and size

of pieces >4 m in length)

Revision 5: September 14, 2021 None recommended; one piece > 4m will Follow-up recommended
remain due to pile location and limited
accessibility
Debris reduction

Georeferenced photographs taken; Additional comments

smoke release is visible.
Other
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Smoke Management Plan
 Smoke Management Plan
Site C Clean Energy Project

6.2.2 Record Keeping and Submission

It is the responsibility of the contractor to complete, retain, and submit all records created as a
result of open burning and implementation of the SMP.

6.2.2.1 Weekly Submission

The following forms (or contractor-developed equivalent) and associated photo documentation
shall be submitted weekly by the contractor to the appropriate BCH representative. Records will
be saved as pdf files and uploaded to SharePoint.
• Burn tracking form;
• Burn period / smoke release form;
• Den and bird nesting surveys.

6.2.2.2 Upon Request

The following records must be retained and submitted to BCH or MOE upon request.
• Pre-burn checklist;
• Ignition plan.
Daily burn tracking forms must be retained for a period of one year beginning on the start date
of open burning and be submitted to an MOE officer upon request.72

6.3 Air Quality Monitoring, Advisories and Burn Bans

The BC Ministry of Environment operates an air quality monitoring station at the North Peace
Cultural Centre in Fort St. John. Fine particulates will be monitored at 3 locations (85th Avenue
Industrial Lands, Old Fort, and the Site C worker accommodation complex) and monitoring will
be completed according to Appendix B - Air Quality Monitoring Program of the CEMP.

The Ministry of Environment (MOE) may issue air quality advisories or burn bans should
particulate matter concentrations approach or exceed provincial objectives73. The current
provincial 24-hour ambient air quality objectives are as follows:
Particulate matter <2.5 microns (PM 2.5): 25 µg/m3
Particulate matter <10 microns (PM 10): 50 µg/m3

If an advisory and/or burn ban is issued, burn operators are required to adhere to the terms of
the advisory and/or burn ban. 74

72 BC Reg 405/19, s. 31(2)(b)(c)

73 BC Reg 405/19, s. Schedule 2
74 BC Reg 405/19, s. 30(1)(2)(3)

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7.0 Notification and Wildfire Reporting

7.1 Notification
Notifications to key stakeholders will take a multi-layered approach. The contractor shall notify
BCH of existence of acceptable burning conditions and intention to ignite up to 24 hours in
advance of ignition and not later than 8:00 AM on the day prior to ignition.

7.1.1 Public

Intentions to burn will be included in a biweekly construction bulletin issued by BC Hy dro.

Additionally, the Contractor will issue notices to groups identified in Tables 9 and 10, preferably
within 24 hours of a day with acceptable burn conditions and no later than 8:00 AM on the day a
burn might or will occur. Contractors will use messaging approve by BC Hydro for this
communication and will cc BC Hydro on all e-mail notifications. Property owners and First
Nations will be contacted by BC Hydro.

7.1.2 First Nations

Indigenous groups are to be notified a minimum 30 days’ prior to the commencement of burning
activities in a given location. This is in order to maintain a consistent standard and to align the
notification process with requirements from other permits and licenses issued for the Site C
project under the Wildlife Act and the Land Act. As outlined in the aforementioned permits and
licenses, notification is to occur: prior to initiation of an activity; within 30 days of completion of
the activity; and, upon significant change to a construction activity. Therefore, the notification
process applies to all open burning activities, as outlined in this smoke management plan.
Indigenous groups will be notified by BCH Indigenous Affairs Department.

7.1.3 Other Stakeholders

All other stakeholders shall be notified by the contractor. Notification shall occur prior to 8:00 AM
on the day of burn. Contractors must keep notification logs to document and track: day and time
of notification, method of notification (email, phone, text, or a combination), results of notification
(voicemail, read receipt, summary of conversation, etc.). Notification logs must be submitted by
the contractor to BCH weekly.
Table 11. Geographical Units and Key Stakeholders for Notification. Contacts for key stakeholders
are found in Section 7.3.

Site C Reservoir Transmission Line Quarry Sites

Stakeholders Dam Cache Halfway Site C Jackfish West Portage
Site to Creek to River to Dam to Road to Pine Mountain
Cache Half-way Hudson’s Jackfish Peace
Creek River Hope Road Canyon Dam

RCMP x x x x x x

City of Fort St
x x
John

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Site C Reservoir Transmission Line Quarry Sites

Stakeholders Dam Cache Halfway Site C Jackfish West Portage
Site to Creek to River to Dam to Road to Pine Mountain
Cache Half-way Hudson’s Jackfish Peace
Creek River Hope Road Canyon Dam

Fort St John
Fire x x
Department

Charlie Lake
Volunteer Fire x
Department

Peace River
Regional x x x x x x
District

District of
Taylor and
x x x x x
Taylor Fire
Department

District of
Hudson’s x x x x
Hope

Hudson’s
Hope Fire and
x x x x
Rescue
Service

Chetwynd Fire
x x
Department

District of
X x
Chetwynd

BC Wildf ire
x x x x x x x
Service

Northern
x x x x x x
Health

MFLRNORD x x x x x x

Property
x x x x x x x
owners

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7.2 Wildfire Reporting

In accordance with the Wildfire Act, all wildfires shall be reported to 1.800.663.5555 or *5555
from a cellular phone. 75 There must be means on site to report a wildfire (cellular phone,
satellite phone, or radio to someone with means to report).76

7.3 Key Contacts

Table 12. Key contacts for notification, party responsible for notification, and primary method of
notification. 77
Responsible Primary
Agency Contact for Method for
Notification Notification
Ministry of Earle Plain Contractor Email
Environment – Head, Air Quality Section Monitoring, Assessment,
Regional and Stewardship
Contact Environmental Protection
Ministry of Environment and Climate Change
Strategy
Of f ice: 250-739-8253
Fax: 250-751-3103
[email protected]
2080-A Labieux Road
Nanaimo, BC V9T 6J9

Gail Roth
Air Quality Meteorologist, Air Quality Section
(Assessments)
Monitoring, Assessment & Stewardship
Ministry of Environment and Climate Change
Strategy
Of f ice: 250-645-9358
Fax: 250-565-6629
[email protected]
Suite 325, 1011 4th Avenue, Prince George, BC
V2L 3H9
Environment https://www2.gov.bc.ca/gov/content/environment/air- N/A N/A
Canada Daily land-water/air/air-pollution/smoke-
Ventilation burning/ventilation-index
Forecasts
RCMP Cpl. Rob Gardner Contractor Email
Hudson Hope email: [email protected]
Detachment
Linda Cantlon
[email protected]

75 2 Wildfire Act S.B.C. 2004, c. 31

76 6(4) Wildfire Regulation, 38/2005
77 Contacts are likely to change over the duration of the project. It is recommended to confirm and update, as necessary, p rior

to each burning season.

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Responsible Primary
Agency Contact for Method for
Notification Notification
RCMP Fort St S/Sgt. Scott Watson Contractor Email
John Email: [email protected]
Detachment

City of Fort St Milo MacDonald, Chief Administrative Officer Contractor Email

John [email protected]
250-787-8160
Fort St John Fire Darrel Blades, Fire Chief Contractor Email
Department [email protected]
250-785-4333
Peace River [email protected] Contractor Email
Regional District 250-784-3200
District of Taylor Steve Byford, LAFC, CD, Fire Chief Contractor Email
and Taylor Fire [email protected]
Department 250-789-3392

Kevin Holder, Deputy Fire Chief

[email protected]
District of Mokles Rahman, Chief Administrative Officer Contractor Email
Hudson’s Hope [email protected]
250-783-9901
Hudson’s Hope Brad Milton, Fire Chief Contractor Email
Fire and Rescue [email protected]
Service 250-783-0542
Charlie Lake Edward Albury, Fire Chief Contractor Email
Volunteer Fire [email protected]
Department 250-785-1424
Chetwynd Fire Dan Golob Contractor Email
Department78 [email protected]
250-788-2424
District of Carol Newsom, Chief Administrative Officer Contractor Email
Chetwynd [email protected]
250-401-4104
BC Wildf ire Doug Smith, Senior Wildfire Officer – Prevention Contractor Email
Service, Prince [email protected]
George Fire 778-693-2879
Centre
James Bergen, Fire Protection Officer
[email protected]
778-576-8898
250-785-6349
Northern Health [email protected] Contractor Email
250-263-6000

Seyoum Gebeyehu
Environmental Health Officer, Health Protection and
Disease Prevention
[email protected]

78The Chetwynd Fire Department does not provide firefighting or rescue services for the West Pine quarry area. Highway
rescue only is available.

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Responsible Primary
Agency Contact for Method for
Notification Notification

Ali Moore
Team Lead, Health Protection and Disease
Prevention
[email protected]

MFLRNORD Ken Dobb – Project Manager Contractor Email

[email protected]
250-795-4169
Property James Thomas, BC Hydro Senior Manager, BCH Public Bi-weekly
Owners Properties: [email protected] Relations Construction
604-695-5288 Department Report

Thomas Brent: [email protected]

Steven Burke: [email protected]

Will Mbaho, Communications Advisor:

[email protected]
604-699-7281

Jimmy Yip: [email protected]

First Nations BCH TBD by BCH

Indigenous Indigenous
Af fairs Af fairs
Department Department

8.0 Qualified Professionals

This plan was revised in accordance with the BC Open Burning Smoke Control Regulation
405/19, enacted September 15, 2019, Waste Discharge Regulation, Wildfire Act, and Wildfire
Regulation by the following qualified professional:

Tove Pashkowski Registered Professional Forester

This plan was originally prepared (June 2015) in accordance with the BC Open Burning Smoke
Control Regulation (BC MOE 2012) and proposed updates to the regulation (BC MOE 2010), by
the following qualified professionals:

William Golding Registered Professional Forester, Silvicon Services Inc.

Paul Veltmeyer Registered Professional Forester, BC Hydro.

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9.0 Works Consulted

Alberta Wildfire. 2019. Brush Piles and Windrows Safe Burning Practices.
https://open.alberta.ca/publications/9781460122389. Accessed: 22 June, 2020.

BC Hydro 2013. Site C Clean Energy Project, Environmental Impact Statement.

British Columbia Ministry of Environment. “Open Burning Smoke Control Regulation.” Province of
British Columbia, Province of British Columbia, 29 Mar. 2017,
https://www2.gov.bc.ca/gov/content/environment/air-land-water/air/air-pollution/smoke-
burning/regulations/openburningregulation . Accessed: 25 October 2019.

BC Ministry of Environment. “Air Quality Objectives & Standards.” Province of British Columbia,
Province of British Columbia, 10 Apr. 2017, https://www2.gov.bc.ca/gov/content/environment/air-
land-water/air/air-quality-management/regulatory-framework/objectives-standards. Accessed
August 22, 2017.

“B.C. Air Quality.” Venting Index, British Columbia Ministry of Environment,

http://www.env.gov.bc.ca/epd/epdpa/venting/ . Accessed August 22, 2017

British Columbia Ministry of Forests, Lands, and Natural Resource Operations. 2014. Industrial
and Resource Management Burning – A Guide to Category 3 and Resource Management Open
Fires. http://www2.gov.bc.ca/assets/gov/public-safety-and-emergency-services/wildfire-status/fire-
bans-and-restrictions/bcws_resourcemgmt.pdf. Accessed August 4, 2017.

Bulkley Valley Smoke Management Plan Pilot, August 31, 2012.

http://www.for.gov.bc.ca/dss/Smoke%20%20Zones/BV%20Smoke%20Management%20Plan%20
Final%202012.pdf Accessed: October 3, 2014

Bulkley Forest District Burn and Smoke Management Plan (BSMP), Sept 8, 2016.
http://cleanairplan.ca/BOF2016/gq5SMP-BulkleySmokeManagementPlan2016-signed.pdf
Accessed: August 3, 2017.Continuing Care Act. R.S.B.C. 1996, c. 70

Environmental Management Act [SBC 2003] Chapter 53.

Forest Planning and Practices Regulation B.C. Reg. 14/2004.

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FP Innovations. n.d. Woody Debris Management Strategies Info-Flip.

http://wildfire.fpinnovations.ca. Accessed August 25, 2017.

Ministry of Environment and Climate Change Strategy. 2019. Factsheet Open Burning Smoke
Control Regulation. https://www2.gov.bc.ca/assets/gov/environment/air-land-
water/air/f actsheets/obscr_general_factsheet.pdf . Accessed June 24, 2020.

Open Burning Smoke Control Regulation, BC Reg. 405/19

Waste Discharge Regulation, BC Reg. 154/2019

Wildfire Act. S.B.C. 2004, c. 31

Wildfire Regulation, BC Reg. 38/2005

Wildfire Regulation, BC Reg. 157/2020

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