### Summary of Interagency Working Comments on Draft La nguage under

EO12866/13563 Interagency Review. Subject to Furth er Policy Review.

Environmental Protection Agency (EPA): Proposed Rul e

Protection of Visibility: Amendments to Requirement s for State Plans

RIN 2060-AS55

Reviewer recommends the following revisions below:

Specific Comment 10 Follow-up now on page 63: (iv) a prescribed fire is presumpt ively not reasonably preventable (in the sense that it not wo uld have been reasonable to not conduct it, because of the multiple important benefits that wou ld have been foregone, if a multi-year land or resource management plan 1 for a wildland area has a stated objective to esta blish, restore and/or maintain a sustainable and resilient wildland ecosy stem and/or to preserve endangered or threatened species through a program of prescribed fire and the use of prescribed fire in the area has not exceeded the frequency indicated in that pl an.

Comment: the footnote is from EE NPRM, page 72872 i n the discussion of the “not reasonably controllable or preventable” section with explicit addition of State Forest Action Plans.

Page 64 New Specific Comment: We believe appropriate use of prescribed fire need ed for ecosystem health and to protect life and property f rom wildfires, with best basic smoke management practices applied, should be encouraged by EPA rules and policies, and that potentially unnecessary barriers to its use should be reassessed by the responsible authorities with input from land managers, affected communities and stakeholders.

Page 68 New Specific Comment: If a state determines that compliance with a smoke management program of a particular design is requir ed for reasonable progress, then the state should include the smoke management program in the SIP as part of the long-term strategy. We believe that states can include sufficiently detail ed, enforceable language in their smoke management programs to make them practicably enforc eable for SIP purposes (as may not be the case for all basic smoke management practices). Su ch a program should not impose unnecessary barriers to prescribed fire use and should include a plan for periodic assessment by the responsible authorities with input from land manage rs, affected communities and stakeholders.

Comment: The precedent for program assessment was p art of Section 309 of the RHR. The

submittal of the results of the assessment could be added to the G. Requirements for Periodic Reports.

Page 70 continuation of comment 10 on page 63 above : The adjustment would consist of adding to the value of natural visibility condition s an estimate of wildland prescribed fire impacts, only for the purpose of calculating the un iform rate of progress and only for prescribed

1 These plans could also include State Forest Action Plans, fire management plans, prescribed fire on w ildland management plans, landscape management plans or equ ivalent public planning documents.

### Summary of Interagency Working Comments on Draft La nguage under

EO12866/13563 Interagency Review. Subject to Furth er Policy Review.

fires that were conducted under multi-year land or resource management plans 2 for wildland areas that have a stated objective to establish, re store and/or maintain a sustainable and resilient wildland ecosystems and/or to preserve endangered o r threatened species through a program of prescribed fire and that provide for the use of ap propriate basic smoke management practices.

Specific Comment 25 Follow-up now on page 119: 2) wildland prescribed fires that were conducted under a multi-year land or resource manag ement plan including State Forest Action Plans, fire management plans, prescribed fire on wi ldland management plans, landscape management plans or equivalent public planning docu ments for a wildland area that has a stated objective to establish, restore, or maintain sustai nable and resilient wildland ecosystems or to preserve endangered or threatened species through a program of prescribed fire and that provides for the use of appropriate basic smoke management p ractices.

Page 129 Follow-up to call discussion on inclusion of SMP assessment provision: (6) An assessment of whether the current implementation pl an elements and strategies are sufficient to enable the State, or other States with mandatory Cl ass I Federal areas affected by emissions from the State, to meet all established reasonable progr ess goals for the period covered by the most recent plan required under paragraph (f) of this se ction and results of the periodic assessment of the smoke management program for prescribed fires o n wildland that it is not imposing unnecessary barriers to prescribed fire use conduct ed with input from land managers, affected

communities and stakeholders .

2 These plans could also include State Forest Action Plans, fire management plans, prescribed fire on w ildland management plans, landscape management plans or equ ivalent public planning documents.