2-25-15 Redline Changes Reply
   1) Page 15.  Modify the Miscellaneous (mainly wildfire emissions, dust and some agricultural operations) 
   2) Page 135 1[st] full paragraph:
If wildfire impacts are significant, contributing to exceedances of the standard, the 
EPA proposes that air agencies should consider RACM for this source and seeks comment on this guidance.  Fires play an important ecological role across the globe, benefiting those plant and animal species that depend upon natural fires for propagation, habitat restoration, and reproduction.  Fires are one tool that can be used to reduce fuel load, unnatural understory, and tree density, helping to reduce the risk of catastrophic wildfires.  Some wildfires and the use of prescribed fire can influence the occurrence of catastrophic wildfires which may reduce the probability of fire-induced smoke impacts and subsequent health effects. RACM must be determined for each area on a case-by case basis. Possible RACM for wildfire may include measures that reduce wildland fuels through fuels management, including the use of prescribed fire and possibly allowing some wildfire to occur naturally in systems that are ecologically fire dependent. Where appropriate, states, land managers, and landowners may consider developing plans to ensure that fuel accumulations are addressed and fuels management efforts, including prescribed fire, are not delayed. The EPA also proposes that air agencies should consider RACM for managing emissions from prescribed fires (including those prescribed fires conducted to reduce future wildfire emissions) and seeks comment on this approach. Information is available from the DOI and the USDA Forest Service on smoke management programs and basic smoke management practices. The EPA requests input on practical considerations associated with RACM for wildfire and prescribed fire, including such issues as how such measures can be characterized in the emissions inventory and attainment demonstration and made federally enforceable for adoption in a 
SIP.  

   3) Page 416 combined two additions that were requested.  We are fine with the page 416 combination. However we still want the addition in the early section on emissions inventory development as initially requested (page 106 original draft) or something close such as proposed below which provides a bit more context.  This addition is needed because prescribed burns are conducted variably year-to-year depending on fire cycle and weather conditions by state, tribal and private land owners and managers.  Only federal activities are the focus of the General Conformity provisions and discussion on page 416. 

Significant tracts of wildland under federal management may also be included in nonattainment area boundaries. The role of fire in these areas should be assessed and emissions budgets developed in concert with those federal land managers and owners ment agencies. In such areas the EPA encourages states to consider in any baseline, modeling and SIP attainment inventory used and/or submitted to include emissions expected from projects subject to general conformity and , including emissions from wildland fire that may be reasonably expected in the area. Where appropriate, states may consider developing plans for addressing wildland fuels in collaboration with land managers and owners. Information is available from DOI and USDA Forest Service on the ecological role of fire and on smoke management programs and basic smoke management practices.

   4) Page 440 last sentence needs to be parallel to the Ozone Implementation Rule (see bottom of page 113 in the final rule as posted by EPA on their website). 
      
Depending on the nature and scope of international and interstate emissions events affecting air quality in the U.S., the EPA may be able to assist states in developing approvable exceptional events demonstrations. 
 
