### 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**
**- A**  **S05 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 specificall y identified as contribution categories in the “source apportionment run” (page 1 03 of the preamble). The reviewer believes that states could propose controls on wildland fire emissions, since these emissions are specificall y 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 highl y variable annually in source, impact, geographic area, and extent. In 2015, emissions impacts the CSAPR area from Alaska, California, the Pacific Northwest, and especiall y, from Canada. In other years, wildland fire emissions from Mexico, Texas or the Southeastern states have impacted the CSAPR. Therefore, the reviewer re commends clarify ing that the modeled baseline y ear 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 manag ement 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 man y 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 y ear and have been included in other air quality rulemaking packages. a. “Emissions from W

ildland Fires. We understand that fire is an unavoidable occurrence on man y ty

pes 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 likel y we encourage air agencies to work with state, federal and private land manage rs 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 safet y, ecological, and propert y protection benefits as well. Recognizi ng 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 rel y on burn managers’ use of basic smoke management practices15 by identify ing a set of generall y appl icable practices that would be employ ed 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 w here 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 manage ment 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.