## 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 im proved 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 consi derable 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 actua l 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 coun ties 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 res ult 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 whethe r 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 agricult ural burning, in the sentence: Fire emissions were based on a multi

- year climatological average as this analysis was mean t 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, p lease 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 inc reasing 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.