The National Association of State Foresters sent a letter to the Environmental Protection Agency (EPA) to emphasize the importance of the exceptional events demonstration for prescribed fire and the need for increased use of the process at the EPA regional offices.
Prescribed fire is a critical tool for state forestry agencies to reduce hazardous fuel loads and protect communities from catastrophic wildfire. However, the EPA’s recent lowering of the PM2.5 National Ambient Air Quality Standard (NAAQS) has impacted how readily states can deploy this tool.
Many states will now need to utilize the EPA’s exceptional event demonstration process to maintain compliance with the Clean Air Act, though up until now there has only been one exceptional event demonstration permit ever issued for prescribed fire in the nation. The letter requests that EPA prepare to accommodate the submission of exceptional event demonstrations.
“…We ask that EPA proactively prepares, in partnership with state foresters and state air quality agencies, for significantly increased use of the prescribed fire exceptional events process at each of its regional offices…In particular, we request your support in ensuring that each EPA regional office:
- Is adequately oriented to handle and process exceptional events demonstrations, with at least one staff person designated as the point of contact for state engagement throughout the process;
- Issues clear guidance to state agencies on what documentation is needed for an exceptional events demonstration to be approved, which, to the extent possible, is aligned across EPA regions; and
- Establishes clear internal and external timelines for processing and approval of exceptional events demonstrations that adequately meet state data needs.”