Comment Submitted by John David Miller, Virginia Department of Forestry

- There is very little knowledge of the proposed revisions amongst the state forestry agencies throughout the Southeastern US. I am not certain of the method used to disseminate this information and to solicit comments, however, I am fairly certain that no other state forestry agency in the South was aware of this prior to my state DEM contact sharing the information with me this past Friday. I shared the information this past Friday afternoon, however, I find it doubtful that you will receive very many responses from this important group of contacts ahead of your Monday deadline. - The proposed changes all seem positive to me and do seem to generally support the operational needs of the applicants for FMAG assistance. - I am not sure if this review period provides an opportunity to address other needed edits to the FMAG language, however, if there is some potential to incorporate other improvements, then I would also submit the following: o The FMAG process needs to provide better allowance for the use of a “fire complex” structure of management in which multiple fires on a local level are managed collectively by a central incident management organization based out of a regionally located office. Thus structure is very commonly used by state forestry agencies throughout the southern US, yet FEMA has not historically allowed this type of management under the FMAG process. o The FMAG program needs to incorporate allowances to better recognize the organization structure of state forestry fire suppression throughout the Eastern US. The program is heavily based on the structure and organization of western response organizations, which are heavily dominated by federal response agencies who are not even covered under the FMAG program. Eastern wildfire suppression falls on the shoulders of state, rather than federal, wildfire agencies. Eastern state forestry agencies must rely on an organizational concept using swift and efficient initial attack of all wildland fires.