April 17, 2006

Docket ID NO. EPA-HQ-OAR-2001-0017

Environmental Protection Agency

Mailcode: 6102T

Pennsylvania Avenue, NW.

Washington, DC 20460

Dear Sir or Madam:

The National Association of State Foresters (NASF) is pleased to offer the following comments on the proposed rule for revising the particulate matter national ambient air quality standards (PM NAAQS), published on January 17, 2006, in the Federal Register (71FR2620). NASF is a non-profit organization that represents the directors of the fifty state forestry agencies, eight U.S. territories, and the District of Columbia. State Foresters manage and protect state and private forests across the United States. Our primary concerns with the proposed rule relate to the ability of State Forestry organizations to appropriately use prescribed fire to maintain and improve the health and productivity of our nation's state and private forests.

Given the increased stringency of the proposed PM NAAQS, NASF believes that any revised standards must be implemented in a manner that allows state forestry organizations to implement fuel management techniques, such as prescribed fire, in an environmentally appropriate manner, yet consistent with land management needs. We are concerned that a more stringent 24-hour standard for PM 2.5 could drive more areas across the country into non-attainment status. If this were to happen, states would then be compelled to revise their State Implementation Plans (SIP) and develop strategies to further reduce emissions, potentially adversely affecting the ability of state forestry organizations to conduct necessary prescribed burning.

One of the primary advantages of prescribed fire is that it allows forest managers to burn unwanted forest debris and to reduce unnatural build-ups of woody fuels in fire-dependent forests at times when atmospheric dispersion is favorable. As has been previously documented, there are significant differences between wildfire and prescribed fire in their effects on air quality. Wildfire is the air pollution source that has the greatest potential to expose parts of the human population to extremely high short-term concentrations of fine particulates. Management of wildland fuels through techniques such as prescribed burning and the federal program for wildland fire use - the use of naturally-ignited fire to accomplish resource management objectives - have the potential to minimize this significant air quality threat, particularly in regions of the country with comprehensive, interagency smoke management programs. In fire-dependent ecosystems, we believe it is significantly better to manage smoke from prescribed fires rather than to risk the serious consequences associated with wildfires, including the human health impacts from uncontrolled wildfire smoke.

A full understanding of how any new PM standards will affect the ability of state and federal land management agencies to meet their goals and mandates for forest and wildland fire management will greatly depend on the content of EPA's Exceptional Events Rule (The Treatment of Data Influenced by Exceptional Events - proposed March 10, 2006). Our analysis indicates that the proposed PM standards could have a significant negative impact on the forest and fire management activities of state forestry organizations, based on the strictest interpretation of compliance with PM standards. Therefore, we strongly encourage the EPA to finalize the Exceptional Events rulemaking prior to promulgating the PM NAAQS rule so that we can make more meaningful comments on the potential impact of any revised standards on the forest and fire management programs of state forestry organizations.

It is critical that EPA guidance support maintaining the use of prescribed fire in fire-dependent ecosystems that may be in, or have impacts on, areas that are non-attainment for particulate matter. As compared to stationary sources and other areas sources, prescribed fire is an intermittent source of particulates that can be scheduled for times when meteorological and fuel conditions will result in minimizing particulate emissions and impacts. Though the proposed rule is silent regarding EPA's intention with respect to issuing a new implementation rule for any revised PM NAAQS, we assume that EPA will develop such guidance after new standards are promulgated. We would strongly support an implementation rule that takes into account the direction provided by the Exceptional Events rule and that provides information and approaches for states to follow to ensure that the role of fire in the fire dependent ecosystems, including those in non-attainment areas, are appropriately addressed. Such approaches may include development of smoke management programs, requiring use of basic smoke management practices and consideration of biomass utilization techniques. Although biomass reduction techniques generally do not completely replace the need for fire in such ecosystems, they can significantly reduce the emissions which would result from a wildfire.

NASF appreciates the opportunity to comment on this proposed rule and we look forward to working with the EPA on finalizing both this rule and the proposed rule on Exceptional Events.

Sincerely,

James B. Hull

President