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Page 30, line 3 - Change wildfire to wildland fire

Page 33, line 7 - Insert sentences: Wildfire, due to recent growth in the size, duration and 

severity; has also been found to contribute to elevated ozone levels across the country and well 

removed from the wildfire location. Under most forecasted trends due to climate change, this 

increasing trend in wildfire activity will likely continue and assessment of options for 

consideration of this impact upon background will be assessed by EPA in concert with the Forest 

Service. Innovative methods beyond the use of the exceptional event rule will be considered.

Page 528, line 9 – Insert sentence: If such an extension were granted for the secondary standard, 

General Conformity requirements would also be extended to a matching time period.

Page 559, line 2 – If there is a delay in SIP submittal granted by EPA for the secondary standard, 

Transportation and General Conformity implementation would also be delayed.

Page 559, line 14 – Insert sentence: This includes retention of source specific requirements such 

as use of smoke management programs or use of basic smoke management practicesifor 

prescribed fire. 

Page 561, line 6 – Insert sentence: As wildfire emissions are a key portion of this natural 

background along with the potential for such emissions to increase, it is critical to specifically 

identify when such challenging situations may exist. Additionally, the natural background for 

such areas should consider the contribution of wildland fire, wildfire and prescribed fire, as has 

been considered in regional haze rule and elsewhere. Prescribed fire is considered a viable 

mitigation method for reducing this wildfire contribution to natural background and critical for 

protecting public safety while providing for ecological resilience of ecosystems. The role of 

prescribed fire in nonattainment areas which are taxed by the high ozone levels and climate 

change is doubly critical. This relationship should be considered in the development of state 

plans to implement the standards.

Page 562, line 8 - Change and add sentences: In many most locations, these events were are

relatively infrequent however recent and projected trends for wildfire impacts on background are 

increasing. These impacts increase the monitored ozone levels and an increased background 

could inadvertently lead to areas classified as nonattainment or lead to SIP planning which 

requires more stringent control strategies by states. This increasing trend in wildfire activity will 

likely continue and assessment of options for consideration of this impact upon background will 

be assessed by EPA in concert with the Forest Service and DOI. Innovative methods beyond the 

use of the exceptional event rule will be considered. 

Page 563, line 5 - Insert sentences: Increasing trends in wildfire activity which can contribute to 

elevated ozone background and unhealthy ozone levels across large expanses of the country are a 

particular concern especially considering temperature and drought trends in climate change 
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projections. Additionally, use of prescribed fire, which is used to improve resilience of fire 

dependent ecosystems and as a means of managing fuels which could otherwise threaten public 

safety if a wildfire were to occur, can contribute to this background. EPA has previously 

acknowledged that a substantial portion of prescribed fire is natural for purposes of 

demonstrating progress in regional haze. For the purposes of NAAQS classification of areas and 

demonstration of reasonable progress towards achieving the NAAQS, the same view is retained 

that prescribed fire plays a natural and important role in US ecosystem health, resilience and 

maintenance. In order to assess the wildland fire (wildfire and prescribed fire) contribution to 

background, EPA will investigate further options beyond the EER to consider these impacts 

when classifying areas. 

Page 565, line 12 - Add: ...challenging and expensive. As the ozone effects of wildfire become 

smaller further from the fire, the modeling becomes that much more difficult. As the frequency, 

duration and spatial extant of impact from wildfire is anticipated to grow, the use of the 

Exceptional Events Rule will become more frequent. Other more central and national scale 

approaches for addressing the impacts of wildfire on ozone background will be assessed by EPA 

to insure that areas are not assessed regulatory burden due to these types of impacts and variation 

in approach between EPA Regions is reduced. 

Page 565, line 18 – Strike the sentence “While EPA...” 

Page 566, line 6 – Replace fires with wildland fires.

Page 580 – Insert Executive Order 13653 - Preparing the United States for the Impacts of 

Climate Change Agencies are guided to identify and seek to remove or reform barriers that 

discourage investments or other actions to increase the Nation's resilience to climate change 

while ensuring continued protection of public health and the environment; and reform policies 

and Federal funding programs that may, perhaps unintentionally, increase the vulnerability of 

natural or built systems, economic sectors, natural resources, or communities to climate change 

related risks. (If EPA wishes to address benefits of Secondary Standard approach it could fit 

here.) In the calculation of background cited in section VII.F, the relationship and contribution 

of wildland fire, wildfire and prescribed fire, should be clearly defined by EPA as to not allow 

increases from these natural background sources to mask progress towards attainment. As these 

sources are critical to long-term carbon sequestration and carbon stability in the United States, 

states developing implementation plans in concert with EPA will address these natural 

background sources, their contributions towards nonattainment and viable approaches such as 

use of smoke management programs and basic smoke management techniques to insure that 

efforts to use fire to address hazardous fuels are not derailed. 

Page 626, line 11 – Add: prescribed fires. 
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Page 580 –EO 13653 - Preparing the United States for the Impacts of Climate Change – specific 

text to document consideration of wildland fire management within land and resource 

management policies related to climate change:

Wildland fire and ozone

The role of wildland fire in background levels, for both a primary and secondary standard, 

remains paradoxical. Wildland fire emissions do significantly contribute to periodic high levels 

and affects background levels of ozone (Jaffe, D.A. and N.L. Wagner, 2012, “Ozone production 

from wildfires: A critical review”, Atmospheric Environment 51: 1-10), especially as standards 

approach background levels (Emery, C. et al., 2012, “Regional and global modeling estimates of 

policy relevant background ozone over the United States”, Atmospheric Environment 47:206-

217). The paradox is that attempts to exclude wildland fire have resulted in unintended 

consequences, including increased risks to both humans and ecosystems. Indeed, “Fire policy 

that focuses on [wildfire] suppression only, delays inevitable, promising more dangerous and 

destructive future...fires” (Stephens, S. et al., “Managing Forests and Fire in Changing 

Climates”, Science 342:41-42. 2013). Wildfires pose a direct threat to public safety – a threat 

that can be mitigated through management of wildland vegetation.

Initial non-attainment areas based on the RIA suggest that several hundred million acres state, 

private, Tribal and Federal lands might be designated. The USDA Forest Service and the 

Department of the Interior (Bureau of Indian Affairs, Bureau of Land Management, Bureau of 

Reclamation, National Park Service, US Fish and Wildlife Service) each manage about 500 

million acres of wildlands that are subject to wildland fire, and about one-half of that land is in 

fire-adapted ecosystems. The EPA acknowledged the natural role of fire in the maintenance of 
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ecosystems in the Interim Policy on Wildland and Prescribed Fire Emissions (EPA, 1998), the 

Regional Haze Rule (XXX) and in the Exceptional Events Rule (XXX). Additionally, EPA 

captured many concerns regarding wildfire risks in “Endangerment and Cause or Contribute 

Findings for Greenhouse Gases Under Section 202(a) of the Clean Air Act” (Federal Register 74 

(239):66496-66546, 2009). After these EPA rules and policies were published, there has been 

considerable independent, Federally sponsored, and international research on the scientific basis 

for managing wildland fire on wildlands in the U.S., including research on wildland fire 

emissions and impacts of those emissions. 

Collectively, the interagency background materials on the natural role of fire prepared for the 

1998 EPA Interim Air Quality Policy on Wildland and Prescribed Firesii, the Regional Haze 

Rule, and the Exceptional Events Rule, suggest wildland fire, wildfire and prescribed fire, should 

be considered as background emissions for ozone and other pollutants. The management of 

wildfire and increased judicious use of prescribed fire, including the use of Basic Smoke 

Management Practices (USDA 2011) and the inclusion of prescribed fire in smoke management 

plans, can clearly reduce the impacts of fire emissions and in some cases may reduce total fire 

emissions.

The EPA was a signatory agency of the 1995 Federal Wildland Fire Management Policyiii as 

well as the 2001 Review and Update of the policy. As a counterpart to the, 1998 EPA Interim Air 

Quality Policy on Wildland and Prescribed Fires, the Federal fire policy set forth guiding 

principles for wildland fire management and smoke management. The risk of inaction, a science 
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and risk based approach and a balance of short and long term actions and impacts are central to 

wildland fire management.

Fire-adapted ecosystems require periodic occurrence of fire to maintain ecological health, 

including resilience to climate change and drought. When fire is prevented from performing its 

natural role, risk to both humans and ecosystems increases as vegetation accumulates or becomes 

degraded. In some instances, e.g., immediately adjacent to communities, alternative types of 

vegetation treatment are employed when these actions are consistent with land uses and land 

allocations. 

The increased density of forest stands, a build-up in flammable fuels (and carbon), increasing 

prevalence of invasive species, the construction of homes within the wildlands, climate 

variability and climate change, have all contributed to increased risk of wildfire nationally. It is 

well known that several decades of attempted fire exclusion have impacted vegetation health and 

increased fire risk, and that it will take decades of effort to untangle more than one hundred years 

of active fire suppression. Unfortunately, emissions from the consumption of fuels that have 

accumulated for decades are one consequence of undesired fires today, which are also being 

fueled by climate change and drought.

In Wildfires and Air Pollution: the Hidden Health Hazards of Climate Changeiv (2013), it was 

reported that “Wildfires burning within 50-100 miles of a city routinely caused air quality to be 

5-15 times worse than normal, and often 2-3 times worse than the worst non-fire day of the 
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year.” While the unhealthy air quality levels described in the report were due to fine particulates, 

smoke emissions also contain ozone precursors that affect the same areas as well as additional 

populations further downwind. This report indicated that large wildfires in the West could 

increase six-fold, or more, in the next 20 years. Wildfire trends are documented in greater detail 

in The Age of Western Wildfiresv(2012).

A noteworthy study in 11 western States stated that one potential means to reduce carbon 

emissions from wildfire is through the use of prescribed fire, which could reduce CO2 emissions 

by up to 25 percent regionally, and up to 60 percent in specific forest ecosystems (Wiedinmyer 

and Hurteau, 2010). While this study did not estimate impacts on ozone, it is reasonable to infer 

that lower emissions would lead to reduced emissions of ozone precursors as well.

The National Climate Assessmentvi (especially Chapter 7, Forests; 2014) describes the long 

distance impact from wildfires from one region of the U.S. to another, as well as threats to 

human health and well-being from air quality decreased by wildfire. The assessment states that 

carbon sequestration, by forests and woodlands alone, reduces carbon dioxide emissions from 

fossil fuel burning by 16 percent. The assessment also states that changes in land use and forest 

management could change these ecosystems from net absorbers to net emitters of carbon, due to 

projected decreases in carbon sequestration.

The March 31, 2014 United Nations report on climate change (Climate Change 2014: Impacts,
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Adaptation, and Vulnerability; Summary for Policymakers) lists a very high confidence that 

climate impacts on wildfires " ... [R]eveal significant vulnerability and exposure of some 

ecosystems and many human systems ... " The report lists a high confidence that management 

actions can reduce risks to ecosystems and species. Finally, the report lists a very high 

confidence that climate (through heat and fire impacts), may seriously degrade human health. 

Smoke impacts from wildfire may place populations at risk unless the land managers retain a full 

range of tools to mitigate that risk, including prescribed fire. Other fuel treatments may help 

reduce risk, but are impractical for use on the hundreds of millions of acres in fire-adapted and 

fire-maintained ecosystems.

The amount of land burned by wildfires has shown a general increase over past decades, but 

remains highly variable annually, geographically, and by vegetation type. Research suggests that 

modest climate change may lead to several-fold increases in wildfires acres burned in parts of the 

western U.S. Climate change influences both wildfires as well as air quality, yet other factors, 

such as land use and biogenic emissions exert a strong influence over future summertime air 

quality (Avise, J. et al., 2009; “Attribution of projected changes in summertime US ozone and 

PM2.5 concentrations to global changes”, Atmos. Chem. Phys. 9:1111-1124). Differences in 

climate models and differences in air quality model predictions dictate a need to include all 

available studies when assessing long-term trends associated with climate change (ibid).

At recent historic levels of fire occurrence, wildland fire emissions are a large component of the 

U.S. carbon budget, in spite of high annual and spatial variability (Wiedinmyer and Neff, 2007). 
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Historically, the long-term impacts of carbon emissions from wildland fires were relatively 

neutral in fire-adapted ecosystems, because of regrowth following fire. However, with changing 

climate and changes in fire regimes (the size, frequency and severity of fires), there are concerns

that wildland vegetation may become a net source of carbon rather than a carbon sink (ibid). The 

National Climate Assessment and other recent scientific literature focus extensively on climate 

change effects on forest lands. Other research highlights carbon management issues related to 

wildfire in on-forest landscapes, wherein the below ground carbon sequestered may be 

significant both at a site basis, and due to the vast landscapes with this vegetative cover (see, for 

instance, Rau. B.M. et al., 2011, “Woodland expansion’s influence on below ground carbon and 

nitrogen in the Great Basin U.S.”, Journal of Arid Environments 75(9): 827-835).

In addition to increased length of the fire season and on increased wildfire size summarized by 

the EPA in “Endangerment and Cause or Contribute Findings for Greenhouse Gases Under 

Section 202(a) of the Clean Air Act” (Federal Register 74 (239):66496-66546, 2009), recent 

scientific literature indicates that the severity of wildfires (i.e., tree mortality following wildfire) 

is also increased by climatic stress associated with warming as an element of climate change. 

This affect was noted across all regions, tree genera, and tree sizes (van Mantgen, P.J. et al., 

2013). Increased fire frequencies would lead to a transition from forested vegetation to 

grasslands (Lenihan, Bachelet and Draper, 2011), and a corresponding decrease in the amount of 

carbon stored in ecosystems.
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As identified in the Interim Policy on Wildland and Prescribed Fire Emissions (EPA, 1998), 

there is a need to increase the occurrence of fire on landscapes in many parts of the U.S. The lack 

of sufficient scale of area currently managed with fire is cited as a factor in the amount of land 

affected by large, high-severity wildfires (North, Collins, and Stephens, 2014).

Rationale for including prescribed fire in background levels of ozone

Prescribed fires are normally burned in smaller units, low-intensity/low-severity and can be 

conducted in optimal conditions to disperse smoke emissions, versus a larger, high-intensity 

wildfires that can emit smoke for days, weeks, or months with very little or no management 

influence of emission rates or smoke trajectories.

Prescribed fire treatments are important for restoring ecosystem resiliency to fire and climate 

change and should not be restricted to avoid conflicts with Executive Order 13653 (2013) -

Preparing the United States for the Impacts of Climate Change, signed by the President.

Prescribed fire replicates a natural process and performs essential ecosystem functions in fireadapted ecosystems. Without wildland fire, ecosystems result in loss of species and biodiversity, 

degradation of habitat, degradation of ecosystem services, including site productivity, water flow 

and quality, carbon sequestration and the regulation of endemic pathogens. Carbon sequestration

is not a function reserved for forests: carbon sequestration in the vast landscapes of grasslands 

and shrublands managed by Federal land managers is very significant, as documented in recent 
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scientific literaturevii,viii,ix,x,xi. The difference is that carbon on these latter lands is stored below 

ground rather than above ground. Without periodic fires, many Federally managed lands are not 

as healthy and may release carbon rather than store it, just as with forest lands.

Decades of exclusion of fire as a natural ecosystem process, expansion of human populations 

into the interface between communities and wildland ecosystems, extensive drought and the 

emergence of climate change impacts, widespread introduction of invasive species and 

widespread outbreaks of insects and pathogens, have demonstrated a continued need to focus on 

the management of wildland fire. In 2014, the intergovernmental National Cohesive Wildland 

Fire Management Strategyxii was signed by the Secretary of the Interior and the Secretary of 

Agriculture. Three foundational goals of the Cohesive Strategy are: 

1. Restore and maintain landscapes: Landscapes across all jurisdictions are resilient to firerelated disturbances in accordance with management objectives. 

2. Fire-adapted communities: Human populations and infrastructure can withstand a 

wildfire without loss of life and property. 

3. Wildfire response: All jurisdictions participate in making and implementing safe, 

effective, efficient risk-based wildfire management decisions. 

The Cohesive Wildfire Management Strategy has a goal of maintaining resilient landscapes; the 

Strategy seeks to restore fire resilience with all its benefits on Federal, state tribal and private 

lands, including the special lands that are set aside for special uses. The science supporting the 

Strategy directly supports EPA’s goals of reducing air quality impacts from fire.
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The goals of the Cohesive Strategy relate to wildland fire smoke emissions in important ways. 

Wildland fire is impacted by changes in climate, yet also exerts influences over climate through 

carbon and other emissions. Indeed, the Cohesive Strategy is part of the Federal response to, and 

of, the President’s Climate Action Planxiii. Numerous nonattainment areas are in fire-adapted 

ecosystems.

 

i USDA Forest Service and Natural Resources Conservation Service, Basic Smoke Management Practices Tech Note, 

October 2011. http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb1046311.pdf

ii EPA Interim Air Quality Policy on Wildland and Prescribed Fires (1998), 

http://www.epa.gov/ttn/oarpg/t1/memoranda/firefnl.pdf

iii Federal Wildland Fire Management Policy (1995), 

http://www.forestsandrangelands.gov/strategy/documents/foundational/1995_fed_wildland_fire_policy_program_re

port.pdf

iv Wildfires and Air Pollution: the Hidden Health Hazards of Climate Change (Kenward et al., 2013, Climate 

Central), http://assets.climatecentral.org/pdfs/WildfiresAndAirPollution.pdf

v The Age of Western Wildfires (2012, Climate Central), 

http://www.climatecentral.org/wgts/wildfires/Wildfires2012.pdf

vi National Climate Assessment (2014), http://www.globalchange.gov/nca3-downloads-materials

vii Rau, B.M., et al., Woodland expansion’s influence on belowground carbon and nitrogen in the Great Basin U.S.,

Journal of Arid Environments (2011), doi:10.1016/j.jaridenv.2011.04.005

viii Zhu, Z., and Reed, B.C., eds., 2012, Baseline and projected future carbon storage and greenhouse-gas fluxes in 

ecosystems of the Western United States: U.S. Geological Survey Professional Paper 1797, 192 p.; 

http://pubs.usgs.gov/pp/1797/

ix Zhu, Z., and Reed, B.C., eds., 2014, Baseline and projected future carbon storage and greenhouse-gas fluxes 

in ecosystems of the eastern United States: U.S. Geological Survey Professional Paper 1804, 204 p., 

http://dx.doi.org/10.3133/pp1804; http://pubs.usgs.gov/pp/1804/pdf/pp1804.pdf

x Zhu, Z., ed., , 2011, Baseline and projected future carbon storage and greenhouse-gas fluxes in the Great 

Plains region of the United States: U.S. Geological Survey Professional Paper 1787, 28 p.;

http://pubs.usgs.gov/pp/1787/
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xi Zhu, Z., and Stackpoole, S., 2011, Assessing carbon stocks, carbon sequestration, and greenhouse-gas fluxes in 

ecosystems of the United States under present conditions and future scenarios: U.S. Geological Survey Fact Sheet 

2011-3007, 2 p.; http://pubs.usgs.gov/fs/2011/3007/

xii National Cohesive Wildland Fire Management Strategy (2014), 

http://www.forestsandrangelands.gov/strategy/index.shtml

xiii Climate Action Plan (2013), 

http://www.whitehouse.gov/sites/default/files/image/president27sclimateactionplan.pdf