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RAC leans toward allowing pile registration to satisfy smoke‑management 'burn‑plan' minimums
Summary
After debate about whether pile burning should require a distinct burn plan, committee members coalesced around treating registration (pile tonnage, location, timing) as meeting minimum smoke‑management burn‑plan requirements for OAR 629‑048 purposes, while recognizing CBM requirements remain more prescriptive.
The committee reviewed three candidate definitions for pile burning. Randy, Chad and others argued that piles typically accumulate during activity and the burn plan often follows; requiring a formal plan before piles are created could be impractical. James and others worried that without a plan, pile burning could fall under open‑burn rules rather than prescribed‑fire rules.
Members reached a working consensus that registering pile tonnage and unit location should meet the smoke‑management program's minimum burn‑plan requirement (for OAR 629‑048), while allowing landowners or managers to provide more detailed burn plans where CBM or agency requirements apply. Several members recommended explicit language that registration "meets minimum requirements of a burn plan for smoke management," and staff were asked to draft that clarification.
