Summary	of	Interagency	Working	Comments	on	Draft	Language	under	

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

1

Environmental Protection Agency (EPA): Proposed Rule

Cross-State Air Pollution Rule for the 2008 Ozone 

National Ambient Air Quality Standards

RIN 2060-AS05

General Comments

1. The proposed rule clearly intends to manage ozone transport through CSAPR, focusing 

on EGUs. However, anthropogenic emissions from Canada and Mexico and Fires are 

specifically identified as contribution categories in the “source apportionment run” (page 

103 of the preamble). The reviewer believes that states could propose controls on 

wildland fire emissions, since these emissions are specifically included as a contribution 

category, even if the primary control mechanism focuses on EGUs. The reviewer also

believes that wildland fire emissions may contribute to ozone NAAQS exceedances in 

nonattainment and maintenance areas in a number of the 23 states. 

2. Wildland fire emissions are highly variable annually in source, impact, geographic area, 

and extent. In 2015, emissions impacts the CSAPR area from Alaska, California, the 

Pacific Northwest, and especially, from Canada. In other years, wildland fire emissions 

from Mexico, Texas or the Southeastern states have impacted the CSAPR. Therefore, the 

reviewer recommends clarifying that the modeled baseline year of 2017 in the RIA 

includes the range of possible wildland fire emissions.

3. Despite the impacts of wildland fire emissions, there are very positive effects from 

prescribed fire and other wildland fire management actions that reduce wildfire risks. 

Therefore, the reviewer recommends that language included in the attachment to the 

EPA October 1, 2015 Memorandum on Implementing the 2015 Ozone National Ambient 

Air Quality Standards to Regional Administrators be incorporated within the preamble of 

this proposed rule. This language provides a succinct summary of many concepts 

regarding the ecological role of fire, and the relationship between wildland fire (wildfire 

and prescribed fire) and the management of ozone and ozone precursor emissions, that 

have been published over the past year and have been included in other air quality

rulemaking packages.

a. “Emissions from Wildland Fires. We understand that fire is an unavoidable 

occurrence on many types of wildland, and that changing climate conditions will 

increase the occurrence of damaging wildfires unless fuel loads are managed by

other means including science-based use of prescribed fire.12,13,14 Emissions from 

fires on wildland, particularly large wildfires, can impact concentrations of ozone 

and other harmful pollutants, such as PM2.5, both in the locations with fire and 

down wind. In areas where wildfire have been prevalent or are likely we 

encourage air agencies to work with state, federal and private land managers on 

promoting prescribed fire and other strategies that may reduce wildfire emissions 

and their effects on ozone exceedances; we appreciate that such strategies may

have other public safety, ecological, and property protection benefits as well. 

Recognizing the importance of various fire management strategies, in the 
Summary	of	Interagency	Working	Comments	on	Draft	Language	under	

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

2

proposed revisions to the Exceptional Events Rule we intend to encourage air 

agencies to rely on burn managers’ use of basic smoke management practices15 

by identifying a set of generally applicable practices that would be employed 

during prescribed fires. The EPA and the federal land management agencies will 

support state efforts to educate the public on the ecological role of fire, and 

wildfire and prescribed fire concepts. Where a prescribed fire program has been 

developed and is being implemented in and/or upwind of a nonattainment area, 

the EPA recommends that air agencies account for the expected prescribed fire 

emissions in the attainment and maintenance planning process. In those areas 

where prescribed fires are known to be capable of causing occasional ozone 

exceedances, the EPA will continue to work with air agencies and stakeholders to 

improve the long-term effectiveness of the existing basic smoke management 

practices and smoke management programs.”

4. Reviewer recommends referencing the pending Exceptional Events Rule proposal that 

was referred to in the 2015 Ozone NAAQS.

Regulatory Impact Analysis

1. Page 3-8, Table 3-1. Reviewer recommends using standard language for wildland fires 

and therefore changing “Wild and Prescribed Fires” to “Wildfires and Prescribed Fires.