### Summary of Interagency Working Comments on Draft Language under

EO12866/13563 Interagency Review. Subject to Further Policy Review.

1 Page 30, line 3

- Change wildfire to wildland fire Page 33, line 7

- Insert sentence s : 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 increa sing 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 gran ted 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 practices i for 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 f ire , wildfire and prescribed fire, as has been considered in regional haze rule and elsewhere. Prescribe d 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 a reas 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 sentence s : 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 assesse d 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 cl imate change

### Summary of Interagency Working Comments on Draft Language under

EO12866/13563 Interagency Review. Subject to Further Policy Review.

2 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 t his 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 to wards 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 m uch 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 s moke 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.

### Summary of Interagency Working Comments on Draft Language under

EO12866/13563 Interagency Review. Subject to Further Policy Review.

3

### Summary of Interagency Working Comments on Draft Language under

EO12866/13563 Interagency Review. Subject to Further Policy Review.

4 Page 580

– EO 13653

- Preparing the United States for the Impa cts 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 th e United States”, Atmospheric Environment 47:206

- 217). The paradox is that attempts to exclude wildland fire ha ve 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 tha t land is in fire

- adapted ecosystems. The EPA acknowledged the natural role of fire in the maintenance of

### Summary of Interagency Working Comments on Draft Language under

EO12866/13563 Interagency Review. Subject to Further Policy Review.

5 ecosystems in the Interim Policy on Wildland and Prescribed Fire Emissions (EPA, 1998), the Regional Haze Rule (XXX) and in the Exceptional Events Ru le (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 ru les 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 Fires ii , 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. T he 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 Policy iii 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

### Summary of Interagency Working Comments on Draft Language under

EO12866/13563 Interagency Review. Subject to Further Policy Review.

6 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 res ilience 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, alte rnative 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 increas ed 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 consequ ence 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 Change iv (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

### Summary of Interagency Working Comments on Draft Language under

EO12866/13563 Interagency Review. Subject to Further Policy Review.

7 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 Wildfires v (201 2).

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 f orest 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 Assessment vi (especially C hapter 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, b y 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, d ue to projected decreases in carbon sequestration.

The March 31 , 2014 United Nations report on climate change (Climate Change 2014: Impa c ts,

### Summary of Interagency Working Comments on Draft Language under

EO12866/13563 Interagency Review. Subject to Further Policy Review.

8 Adaptation , and Vulnerability; Summary for Policymak e rs) 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 ri s ks to ecosystems a nd 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 t o mitigate that risk, including prescribed fire. Other fuel treatments may help reduce r isk, but are impractical for use on the hundreds of million s 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. Clim ate 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 w ith 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).

### Summary of Interagency Working Comments on Draft Language under

EO12866/13563 Interagency Review. Subject to Further Policy Review.

9 Historically, the long

- term imp acts 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 followi ng 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 t ransition from forested vegetation to grasslands (Lenihan, Bachelet and Draper, 2011), and a corresponding decrease in the amount of carbon stored in ecosystems.

### Summary of Interagency Working Comments on Draft Language under

EO12866/13563 Interagency Review. Subject to Further Policy Review.

10 As identified in the Interim Policy on Wildland and Prescribed Fire Emissions (EPA, 1998), th ere 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 c limate 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 e cosystem functions in fire

adapted 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

### Summary of Interagency Working Comments on Draft Language under

EO12866/13563 Interagency Review. Subject to Further Policy Review.

11 scientific literature vii , viii , ix , x , xi . The difference is that carbon o n 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 natura l 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 insec ts and pathogens, have demonstrated a continued need to focus on the management of wildland fire. In 2014, the intergovernmental National Cohesive Wildland Fire Management Strategy xii was signed by the Secretary of the Interior and the Secretary of Agricult ure. Three foundational goals of the Cohesive Strategy are:

1. Restore and maintain landscapes : Landscapes across all jurisdictions are resilient to fire

related 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 Cohes ive 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.

### Summary of Interagency Working Comments on Draft Language under

EO12866/13563 Interagency Review. Subject to Further Policy Review.

12 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 Plan xiii . 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/s telprdb1046311.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 Po licy (1995), http://www.forestsandrangelands.gov/strategy/documents/foundational/1995_fed_wildland_fire_policy_program_re po rt.pdf iv Wildfires and Air Pollution: the Hidden Health Hazards of Climate Change (Kenward et al., 2013, Climate Central), http://assets.climatecentral.org/pdfs/WildfiresAnd AirPollution.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. ; htt p://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/

### Summary of Interagency Working Comments on Draft Language under

EO12866/13563 Interagency Review. Subject to Further Policy Review.

13 xi Zhu, Z., and Stackpoole, S., 2011, Asse ssing 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