NASF Responds to the EPA’s Revisions to Air Emissions Reporting Requirement in Official Comments

NASF submitted official comments to the Environmental Protection Agency’s (EPA) proposed Revisions to the Air Emissions Reporting Requirements (AERR). In the letter, NASF emphasizes the burden to State Forestry agencies that the proposal would create for the collection and reporting of prescribed fire data. Ensuring that the use of prescribed fire remains in the toolbox of land managers across the country is critical not only for state forestry agencies’ missions but also for many of EPA’s other mandates, such as community safety and water quality.

“While the collection of all the prescribed fire data proposed in the AERR would be ideal, especially in its contribution to better understanding the emissions impacts of prescribed fire compared to unplanned wildfire, it needs to be tempered with the reality of the added workload of collecting the data…While not impossible, the AERR for prescribed burning as proposed would be a heavy regulatory and reporting lift, requiring coordination amongst State Forestry Agencies, State Air Quality Agencies, and local government.

This will all have a cost, between the dedicated federal funding needed to implement the requirements and the exhaustive process of implementation. Without federal support, this proposal represents an unfunded mandate that will induce significant cost and responsibility on state agencies in order to achieve compliance.”

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