FW: Some Interagency Comments on EPA Response to 

Comments on EO 12866/13563 Review of EPA's Proposed Rule 

Entitled Fine Particulate Matter National Ambient Air Quality 

Standards: State Implementation Plan Requirements 

Incoming #7

Megan V. Brachtl, Group Leader

State and Local Programs Group

Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency

(919) 541­2648

brachtl.megan@epa.gov

From: Szabo, Aaron [mailto:Aaron_L_Szabo@omb.eop.gov] 

Sent: Monday, February 02, 2015 3:33 PM

To: Brachtl, Megan

Subject: Some Interagency Comments on EPA Response to Comments on EO 12866/13563 Review of EPA's 

Proposed Rule Entitled Fine Particulate Matter National Ambient Air Quality Standards: State Implementation 

Plan Requirements 

Megan,

Below are some interagency comments based on EPA’s response to comments for the EO 12866 and 13563 

review of EPA’s proposed rule entitled, “Fine Particulate Matter National Ambient Air Quality Standards: State 

Implementation Plan Requirements.”

Modify language in Response to General Comment 1 to (provided in bold and underlined):

“Wildfire emissions are a component of background PM2.5 and can significantly contribute to periodic high 

PM2.5 levels. Besides their effect on air quality, wildfires pose a direct threat to public safety – a threat that can 

be mitigated through management of wildland vegetation. Attempts to suppress wildfires have resulted in 

unintended consequences, including increased risks to both humans and ecosystems. The use of wildland 

prescribed fire can influence the occurrence, behavior, and effects of catastrophic wildfires which may help 

manage the contribution of wildfires to background PM2.5 levels and periodic peak PM2.5 events. Additionally 

prescribed fires can have benefits to those plant and animal species that depend upon natural fires for 

propagation, habitat restoration, and reproduction, as well as myriad ecosystem functions (e.g., carbon 

sequestration). The EPA understands the importance of prescribed fire which mimics a natural process 

necessary to manage and maintain fire­adapted ecosystems and climate change adaptation, while reducing risk 

Brachtl, Megan

Mon 3/9/2015 4:21 PM 

To:Damberg, Rich <Damberg.Rich@epa.gov>; 

FW: Some Interagency Comments on EPA Response to Comments o... - Damberg, Rich Page 1 of 2

https://outlook.office365.com/owa/ 3/15/2015
of uncontrolled emissions from catastrophic wildfires, and is committed to working with federal land managers, 

tribes, and states to effectively manage prescribed wildland fire use to reduce the impact of wildfire related 

emissions on PM2.5.

If wildfire impacts are significant, contributing to exceedances of the standard, states should consider 

Reasonably Achievable Control Measures (RACM) for this source. Fires play an important ecological role 

across the globe, benefiting those plant and animal species that depend upon natural fires for propagation, 

habitat restoration, and reproduction. Fires are one tool that can be used to reduce fuel load, unnatural 

understory, and tree density, helping to reduce the risk of catastrophic wildfires. Some wildfires and the use 

of prescribed fire can influence the occurrence of catastrophic wildfires which may reduce the probability of 

fire­induced smoke impacts and subsequent health effects. RACM for catastrophic wildfire may include 

addressing the wildland fuels through fuels management, including the use of prescribed fire and allowing 

some wildfire to occur naturally in systems that are ecologically fire dependent. Where appropriate, states, 

land managers, and landowners may consider developing plans to ensure that fuel accumulations are 

addressed and fuels management efforts, including prescribed fire, are not delayed. RACM for prescribed 

fires should also be considered. Information is available from the DOI and the USDA Forrest Service on smoke 

management programs and basic smoke management practices and may be considered when determining 

RACM for prescribed fires. RACM must be determined for each area on a case­by­case basis.

Reviewer recommends editing language on the use of the Exceptional Events Rule (provided in bold and 

underlined):

Where interstate transported emissions contribute to an exceedance or violation and come from prescribed 

fire, wildfires, or other natural sources such as wildfires, air agencies can use the provisions in the EPA’s 

Exceptional Events Rule (40 CFR 50.14) to request exclusion of affected data. Once EPA concurs with an air 

agency’s request, the event­influenced data are officially noted and removed from the data set used to calculate 

official design values.

Please let me know if you have any comments or questions.

Aaron L. Szabo

Policy Analyst

Office of Management and Budget

202­395­3621

Aaron_L_Szabo@omb.eop.gov

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https://outlook.office365.com/owa/ 3/15/2015