# 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) 541

­ 2648 brachtl.megan@epa.gov
From: Szabo, Aaron [mailto:Aa ron_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 Nation al Ambient Air Quality Standards: State Implementation Plan Requirements Megan, Below are some interagency commen ts based on EPA’s response to comments for the EO 12866 and 13563 review of EPA’s proposed rule entitled, “Fine Particulat e Matter National Ambient Ai r 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 significa ntly contribute to periodic high PM2.5 levels. Besides their effect on air quality, wildfires po se a direct threat to publicsafety – a threat that can be mitigated through management of wildland vegetation . Attempts to suppress w ildfires 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 effectsof catastrophic wild fires 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 fire

­ adapted ecosystems and climate change adaptation, while reducing risk



### Brachtl, Mega n Mon 3/9/2015 4:21 PM

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

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3 / 15 /201 5 https://outlook.office365.com/owa/of uncontrolled emissions from catastrophic wildfires, a nd 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 Measur es (RACM) for this source. Fires play an important ecological role across the globe, benefiting those plant and animal sp ecies that depend upon natural fires for propagation, habitat restoration, and reproduction. Fires are one to ol 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 cata strophic wildfires which may reduce the probability of fire ­ induced smoke impacts and subsequent health effects. RACM for catastrophic wildfire may include addressing the wildland fuels through fuels management, including the use of prescr ibed fire and allowing some wildfire to occur naturally in systems that are ecologically fire dependent. Where appropriate, states, land managers, and landowners may consider developi ng 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. In formation is available from the DOI an d the USDA Forrest Service on smoke management programs and basic sm oke management practices and may be considered when determining RACM for prescribed fires. RACM must be determined for each area on a case ­ by ­ case 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 othernatural sources such as wildfires, air ag encies 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 event

­ influenced data are officially noted and re moved 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 202

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­ 3621 Aaron_L_Szabo@omb.eop.gov 

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