               Environmental Protection Agency (EPA): Final Rule
       Fine Particulate Matter National Ambient Air Quality Standards: 
                    State Implementation Plan Requirements
                                 RIN 2060-AQ48
Specific Comments:
 Page 20 (RLSO): To illustrate the types of sources that emit relevant pollutants, Table 1 provides National Emissions Inventory (NEI) data for 2011 that represent nonattainment area anthropogenic and wildfire emissions estimates for direct PM2.5 and the four main PM2.5 precursor gases from major source sectors. Comment: Wildfire was added in the sentence noted here from page 20 yet nowhere is wildfire linked in Table 1 or its footnotes.  The category of "Miscellaneous Sources" notes it as mainly fire, it should include wildfire so a reader can align the table with the text description. 

EPA's reply 3 through 7 to comments reflected that EPA does not wish to discuss individual source categories, yet these sections addressing precursors do discuss major contributors to the individual precursors such as EGU's, mobile sources and others.  As "Mainly Fire" is the largest contributor to VOC emissions in Table 1, there are possible conclusions about wildfire and/or prescribed fire as the largest contributors to SOA which the previously submitted comments wish to dispel.  Several possible solutions exist. Reconsider the comments as previously submitted.  
 Page 111  -  Reviewer recommends adding the following sentence as the reviewer believes that EPA should include language that supports the flipside that it is not EPA's intent to discourage the use of prescribed fire to reduce wildfire risks, including the risk of wildfire emissions that can harm poplations.  While prescribed fire maynot rise above the threshold for RACM, the reviewer believes that prescribed fire is a form of mitigation.
 The EPA also wants to clarify that it is not the intention to in any way discourage federal, state, local or tribal agencies or private land owners from taking situation-appropriate steps to minimize impacts from prescribed fire emissions on wildland. The EPA encourages all land owners and managers to apply appropriate basic smoke management practices to reduce emissions from prescribed fires, especially where a state has determined that prescribed fires are a significant source affecting air quality.  The EPA believes that prescribed fire can be used where appropriate and with adequate oversight and diligent implementation, as prescribed fire mimics a natural process necessary to manage and maintain fire-adapted ecosystems and climate change adaptation, while reducing risk of uncontrolled emissions from catastrophic wildfires.  
 Page 113 (RLSO), please add after the following sentence:  The EPA encourages all land owners and managers to apply appropriate basic smoke management practices to reduce emissions from prescribed fires, especially where a state has determined that prescribed fires are a significant source affecting air quality.  The EPA believes that prescribed fire can be used where appropriate and with adequate oversight and diligent implementation, as prescribed fire mimics a natural process necessary to manage and maintain fire-adapted ecosystems and climate change adaptation, while reducing risk of uncontrolled emissions from catastrophic wildfires.    
 Page 114 (RLSO), please add the following: In most cases, state attainment demonstration modeling should assume that wildland prescribed fire and wildfire emissions in the attainment year will be equal to, and have the same temporal and geographic pattern as, those assumed in the baseline inventory year.  If wildfire and prescribed fire are included in the precursor analysis, note that there are substantial differences in the timing, pollutant concentration and atmospheric response of these sources which should be considered. 
 Page 115  -  Reviewer recommends adding the language below to help assure commenters (in response to comment 15):
 The EPA received many comments expressing agreement with EPA's recognition of the importance of wildland prescribed fire, and welcoming continued dialogue among states, the EPA, and other federal agencies on how best to ensure that land managers have adequate management tools available, including prescribed fire and some wildfire, but also to ensure that use of these tools does not result in unhealthy air.  The EPA is committed to a dialogue with states, tribes, federal agencies and other stakeholders on an appropriate use of prescribed fires
 Page 117 (RLSO), please add after the following sentence: The EPA received many comments expressing agreement with EPA's recognition of the importance of wildland prescribed fire, and welcoming continued dialogue among states, the EPA, and other federal agencies on how best to ensure that land managers have adequate management tools available, including prescribed fire and some wildfire, but also to ensure that use of these tools does not result in unhealthy air.  The EPA is committed to a dialogue with states, tribes, federal agencies and other stakeholders on an appropriate use of prescribed fires.  
