Summary of Interagency Working Comments on Draft Language under 

EO12866/13563 Interagency Review. Subject to Further Policy Review.

 Table 3-1 – EPA has assumed no change in VOC or NOx emissions from Fires (both Wild and 

Prescribed) and Biogenics in their Base Case modeling between 2011 and 2025. It would 

seem that fire emissions would increase – wildfire is likely to be more prevalent if prescribed 

fire is not allowed or suppressed, and wildfire emissions are much greater than prescribed 

fire emissions due to the fire and emission characteristics of wild vs. prescribed fire. Also, if 

improved ozone concentrations result in improved vegetative health and vigor, it would be 

reasonable to expect that VOC emissions from vegetation will likewise increase. Assuming 

that these two categories will stay the same is just not a good assumption.

 In Appendix 6A, there is additional considerable discussion of crop yield improvements due 

to improved ozone concentrations. However, all of these improvements are based on 

modeled conditions of theoretical research. For soybeans especially, there appears to be no 

good correlation between actual yields (using data from the 2012 Census of Agriculture) for 

nonattainment counties in 5 nonattainment areas in the upper mid-West vs. those 

attainment counties directly adjacent to the nonattainment counties (in Indiana, Illinois, 

Missouri, and Ohio, as well as a few additional counties in Kentucky and Wisconsin to 

complete the nonattainment areas and surrounding attainment counties). In fact, the 

nonattainment counties in those areas in 2012 generally had a higher yield per acre than the 

attainment counties immediately surrounding them. EPA had intended to address some of 

this uncertainty in the preamble document, but it appears that they are still relying on 

benefits from crops in the RIA. The commenters would recommend that this discussion in 

the RIA be quite limited, as it appears that EPA’s modeling isn’t matching reality for 

crops. Additionally, EPA states “Crop acreage was projected to decline with the introduction 

of the ozone standards because additional productivity per acre reduces the demand for 

crop acreage...” (see p. 6A-29, section 6A.2.1.2). Given the increasing worldwide population 

and the worldwide demand for agricultural crops, a small increase in production due to 

improved ozone concentrations (if that is actually correct) will not result in a decrease in 

agricultural crop acreage anytime in the near future. That decision will be driven more by 

global crop demand, so EPA’s assumption in their modeling is incorrect. As such, the 

commenters strongly recommend scaling back the discussion on benefits from crops, as 

there appear to be incorrect assumptions and inconsistencies with reality in EPA’s current 

modeling assessment.

 Page 2-1, please change wildfires to wildland fires in the sentence (wildfires have never 

been considered as anthropogenic under any EPA rule or policy to date): Thus, emissions 

from plants, animals, and wildfires wildland fires could be considered either natural or 

anthropogenic, depending on whether emissions result from agricultural practices, forest 

management practices, lightning strikes, or other types of events (US EPA, 2013, sections 3.2 

and 3.7.1)

 Page2-13, please clarify and specify the fire sources to wildfire, prescribed fire and 

agricultural burning, in the sentence: Fire emissions were based on a multi-year 

climatological average as this analysis was meant to capture seasonal mean background and 

typical ranges rather than explicitly quantify background ozone on specific days.
Summary of Interagency Working Comments on Draft Language under 

EO12866/13563 Interagency Review. Subject to Further Policy Review.

 Chapter 3

Page 3-5, please insert in current text(citations are available if needed): ...and more 

prevalent wildfires. In the U.S. over the last 15 years this trend is already occurring with the 

total acres of wildfires increasing and frequency of large wildfires increasing with many 

states recording their largest fires ever. To the extent that climate change does lead to 

higher ozone concentrations, there could potentially be a need for more stringent emissions 

reductions to counteract the higher ozone potential from these phenomena.