Johnny O'Neil LSR Habitat Restoration and Fuels Reduction

Project

Air Quality Report

Prepared by:

Angie Bell

Geologist and Air Quality Coordinator

Klamath National Forest

for:

Oak Knoll Ranger District

Klamath National Forest

5 January 2011

Updated 21 March 2012

i

Table of Contents

Executive Summary .................................................................................................................... 3

Analysis Indicators and Methodology .................................................................................... 3

Spatial and Temporal Context ................................................................................................ 3

Affected Environment ............................................................................................................. 3

Environmental Effects ............................................................................................................ 3

Alternative 1........................................................................................................................ 3

Direct and Indirect Effects .............................................................................................. 3

Cumulative Effects.......................................................................................................... 4

Alternatives 2, 3 and 4 ........................................................................................................ 4

Direct and Indirect Effects .............................................................................................. 4

Cumulative Effects.......................................................................................................... 4

Compliance with law, policy, regulation, and the KNF Forest Plan ...................................... 5

Introduction ................................................................................................................................. 5

Regulatory Framework ........................................................................................................... 5

Overview of Issues Addressed .............................................................................................. 10

Issue Indicators ................................................................................................................. 12

Affected Environment ........................................................................................................... 12

Environmental Consequences ............................................................................................... 14

Methodology ..................................................................................................................... 14

Spatial and Temporal Context (bounding of analysis area) for Effects Analysis ............. 15

Past, Present, and Reasonably Foreseeable Future Actions Relevant to Cumulative

Effects Analysis ................................................................................................................ 15

Comparison of Alternatives .............................................................................................. 16

Alternative 1 – No Action ............................................................................................. 16

Alternatives 2, 3 and 4 – Proposed Action, Modified Proposed Action and No

Temporary Roads Alternatives ..................................................................................... 18

References (Literature Cited) ................................................................................................ 23

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List of Tables

Table 1: General Conformity Rule De Minimis Standards ........................................................................... 7

Table 2: 2010 estimated annual average emissions (tons/day) for Siskiyou County, California (retrieved

from http://www.arb.ca.gov/app/emsinv/emssumcat.php on 22 December 2010) ............................. 13

Table 3: Summary of contribution (percent) of estimated annual pollutants by source type in Siskiyou

County, California for 2010 ................................................................................................................ 14

Table 4: Estimated pollutant emissions from prescribed fire and stand treatment activities for Alternative

2, 3, and 4 ............................................................................................................................................ 20

List of Figures

Figure 1: California Air Basins ………………………………………………………………....10

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Executive Summary

Analysis Indicators and Methodology

Indicators of effects on air quality include the criteria pollutants (carbon monoxide, sulfur

oxides, lead, respirable (PM10) and fine (PM2.5) particulate matter, nitrogen oxides) and

greenhouse gases that may be emitted by the Johnny O’Neil project and their contribution to the

overall air quality and climate change in the project and analysis areas. Modeled respirable

particulate emissions represent emissions from activities over the entire project area.

Methodology is discussed in detail below and Fire and Fuels resource reports, available on the

KNF website at http://www.fs.fed.us/nepa/fs-usda-pop.php/?project=31052.

Spatial and Temporal Context

The spatial analysis areas are the communities surrounding the project area for which air quality

may be affected by the project and the Marble Mountains Wilderness (a Class I area) because

emissions cannot be contained within the project area or within specific portions of the project

area such as in RRs. For example, dust from any activities, not just from actions in the RRs, can

enter RRs due to the shifting nature of dust emissions. In temporal context, short-term effects are

exhibited during and immediately following project implementation. Long-term effects are felt

within 1 to 50 years after implementation.

Affected Environment

Siskiyou County is identified as attainment or unclassified for carbon monoxide (CO), sulfur

oxides (Sox), lead, respirable particulate matter (PM10) and fine (PM2.5) particulate matter for

both state and federal standards. Siskiyou County is in “non-attainment/transitional” status for

the state 8-hour ozone standards. Ozone will not be directly produced by the project but will be

the result of chemical reactions between the atmosphere and Nitrogen Oxides. Therefore,

compliance with the General Conformity Rule for Nitrogen Oxides (NOx) must be analyzed for

this project. Prescribed burning activities release greenhouse gases (GHG) including CO2 and

CH4 into the air which could contribute to climate change. Currently there are no thresholds for

GHG emissions for prescribed burning activities. The Council on Environmental Quality (CEQ)

recommends that Federal agencies disclose in the NEPA analysis the effects on climate change

for actions that are estimated to emit more than 25,000 metric tons of CO2 equivalents annually

(CEQ 2010).

Environmental Effects

Alternative 1

Direct and Indirect Effects

Under Alternative 1 (no action) there will be no new emissions of criteria pollutants or GHG

from activities. This will lead to increased accumulation of ground fuel leading to increased high

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intensity wildfires in future and higher potential for air quality degradation. The air pollutant

emissions from a wildfire will be 20-35% higher than for prescribed burning as discussed in the

Fire and Fuels resource report, available on the KNF website at http://www.fs.fed.us/nepa/fs-

usda-pop.php/?project=31052. If a wildfire occurs, poor air quality during the wildfire event will

result for the community of Horse Creek and may exist in the Marble Mountain Wilderness.

Under this alternative no direct emissions of criteria pollutants or GHG will be released into the

air. Therefore, the Alternative 1will comply with the Forest Plan and other relevant laws and

regulation.

Cumulative Effects

The cumulative effects of Alternative 1 on air quality are expected to be minimal because

Alternative 1 will add no criteria pollutants or GHG emissions to the emissions produced by

reasonable foreseeable future actions occurring in the surrounding area. The emissions from

these future actions are analyzed in separate environmental analyses for actions on Federal land.

The Horse Creek Road Rehabilitation project will contribute minimal, short-term, localized

fugitive dust emissions that will disperse readily due to the small size and short duration of the

project. Adding the effects of Alternative 1 to the effects of reasonable foreseeable future actions

is not anticipated to result in an adverse impact to air quality. The current attainment status for all

but ozone within the Northern Province Air Basin (NPAB) is expected to continue.

Alternatives 2, 3 and 4

Direct and Indirect Effects

Alternatives 2, 3 and 4 will produce criteria pollutant and GHG emissions from the exhaust of

mobile sources and hauling activities. These emissions may impact visibility and air quality for

the community of Horse Creek and the surrounding area. The criteria and GHG emissions from

prescribed burning may impact visibility and air quality in Horse Creek and possibly in the

Marble Mountain Wilderness during implementation. Siskiyou County is in non-

attainment/transitional status for 8-hour ozone. Therefore, the project has to meet the regulations

outlined in the General Conformity Rule for NOx. The emissions are not anticipated to exceed

the General Conformity Rule De Minimis values for NOx for Alternatives 2, 3 and 4.

GHG emissions from Alternatives 2, 3 and 4 will contribute to climate change as described in the

Climate Change section of this chapter. None of the actions proposed in any action alternative

will emit more than 25,000 metric tons of CO2 equivalents annually. However, the areas treated

with prescribed fire are likely to not only re-sequester the carbon released during treatment but

also be able to surpass unmanaged stands in the amount of additional carbon stored in the long-

term.

Cumulative Effects

The cumulative effects of Alternatives 2, 3 and 4 on air quality are expected to be minimal with

the oversight of the Siskiyou County Air Pollution Control District (SCAPCD). Criteria pollutant

and GHG emissions will degrade air quality cumulatively with activities occurring in the

surrounding area. However, these emissions are expected to be minimal and able to disperse

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readily. Design features, including compliance with Burn Day, Marginal Burn Day, and No Burn

Day designations, and coordination with and permitting from the SCAPCD, will minimize

cumulative effects of prescribed fire. The Horse Creek Road Rehabilitation project will

contribute minimal, short-term, localized fugitive dust emissions that will disperse readily due to

the small size and short duration of the project. Adding the effects of Alternatives 2, 3 and 4 to

the effects of reasonable foreseeable future actions is not anticipated to result in an adverse

impact to air quality. The current attainment status for all but ozone within NPAB is expected to

continue. The emissions are not anticipated to exceed the General Conformity Rule De Minimis

values for NOx. Therefore, the project also complies with the General Conformity Rule and

cumulative effects will not be significant.

Compliance with law, policy, regulation, and the KNF Forest Plan

All the alternatives proposed in this project will comply with laws, regulation, policy, direction

in the KNF Forest Plan (USDA Forest Service 1995a) related to air quality as noted on the KNF

Forest Plan checklist for this project, available on the KNF website at

http://www.fs.fed.us/nepa/fs-usda-pop.php/?project=31052.

Introduction

This report focuses on the potential effects to air quality of proposed activities in the Johnny

O’Neil LSR Habitat Restoration and Fuels Reduction Project (Project) and includes resource

protection measures (project design features) that would reduce the potential for project-related

adverse effects The project proposes to thin plantations and natural stands and reduce fuels with

underburning and mastication in portions of the Johnny O’Neil LSR, located in the Horse Creek

6th

field watershed of Siskiyou County, California.

Regulatory Framework

In California, meeting air quality standards is managed at federal, state, and local levels of

government. The Environmental Protection Agency (EPA) has the primary federal role of

ensuing compliance with the requirements of the Clean Air Act. The EPA issues national air

quality regulations, approves and oversees state implementation plans, and conducts major

enforcement actions. In California, the state agency responsible for meeting the Clean Air Act

requirements is the California Air Resource Board (CARB). The CARB has further delegated

the authorities to local Air Pollution Control Districts (APCDs) or Air Quality Management

Districts (AQMDs) for stationary sources of pollution while retaining the authority for mobile

sources. The local districts have the primary responsibility for meeting the requirements of the

Clean Air Act in their geographic areas. This responsibility is carried out through the

development and execution of implementation plans which must provide for the attainment and

maintenance of air quality standards.

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1. Federal-- Clean Air Act

The original Air Quality Act was passed in 1963. This act was followed by Clean Air Act

Amendments in 1970, 1977, and 1990. The important sections under each amendment that

impact activities of the Forest Service and other federal agencies are summarized below:

a. Clean Air Act Amendment 1970

The Clean Air Act Amendments of 1970, Section 109, required the EPA to develop

primary National Ambient Air Quality Standards (NAAQS) to protect human health

and secondary standards to protect human welfare. The EPA Office of Air Quality

Planning and Standards (OAQPS) has set NAAQS for the following six principal

pollutants (called "criteria" pollutants) including particulate matter (PM10 and PM2.5),

ozone, carbon monoxide, nitrogen oxides, sulfur oxides and lead. If NAAQS standards

are violated in any area, that area is designated as “non-attainment” for that pollutant,

and a state must develop a plan for bringing that area back into “attainment.”

b. Clean Air Act Amendment 1977

The 1977 Clean Air Act Amendments gave federal land managers an “affirmative

responsibility” to protect the Air Quality Related Values (AQRVs) of Class I areas

from adverse air pollution impacts. Class I areas include national wildernesses greater

than 5000 acres in existence on August 7, 1977, when the amendments were passed

into law. AQRVs, as defined by Congress, include “the fundamental purposes for

which Class I areas have been established and preserved by the congress and the

responsible Federal Agency” (Senate Report 95-127, p.36) and include visibility.

AQRVs are defined as feature or properties or properties of Class I area that can be

changed by air pollution. In the Pacific Southwest Region of the Forest Service (R-5),

of which the Klamath National Forest is a part, the AQRVs include flora, water, soil,

cultural and archaeological values, and odor as well as visibility.

The Prevention of Significant Deterioration (PSD) program was established in 1978 as

a result of lawsuit alleging that the Clean Air Act Amendment of 1977 required that a

program be established to prevent degradation of air quality in pristine areas in Class I

Areas, where air quality was very high. The program requires permits for new

stationary air pollution sources above a certain size. The emission from these sources

may not cause deterioration of ambient air quality beyond certain increments.

c. Clean Air Act Amendment 1990

Under the Clean Air Act Amendment of 1990, the EPA published conformity

regulations for non-attainment areas in the Federal Register on November 30, 1993.

The conformity provisions of the Clean Air Act Section 176(c) prohibit federal

agencies from taking any action that:

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• Causes or contributes to any new violation of NAAQS;

• Increases the frequency or severity of an existing violation; or

• Delays the timely attainment of a standard in these areas

All management activities must conform to a State Implementation Plan (SIP). Each

federal agency is responsible for making a conformity determination for resource

projects it conducts or approves. The conformity rules apply only to the activities

occurring in the federal non-attainment areas and do not include emissions considered

to be “de minimis.”

Table 1: General Conformity Rule De Minimis Standards

CO NOX SOX PM

De Minimis levels

(tons/year)

100 100 100 100

At present the EPA is revising the conformity rules. The draft rules were released for

public review early in 2008 and final rules are pending (personal communication T.

Coda, EPA). In the draft rules, project emissions under de minimis level are still

exempt from conformity determination. Any action subject to the conformity rule can

be determined to conform if the total emissions are specifically identified and

accounted for in the SIP. Additional details about conformity are given in R-5

Conformity handbook (September 2005).

2. Regional Haze Regulations

Under the Regional Haze Rule, released by the EPA (1999), each state is required to

develop a SIP for visibility in Class I areas by December 31, 2007. The California Regional

Haze Plan was adopted January 22, 2009. This plan established strategies for reducing

emissions and goals for improving air quality and visibility in Class I Wildernesses. The

strategy includes California’s Smoke Management Plan and the applications of best

management practices for prescribed burning.

3. State-California Clean Air Act (CCAA)

a. CCAA 1988

The California Clean Air Act of 1988 is administered by the California Air Resource

Board (CARB). The Act added several requirements concerning plans and control

measures to attain and maintain the state ambient air quality standards. One such

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requirement is for the CARB to establish designation criteria and to designate areas of

the state as attainment, non-attainment or unclassified for any state standards.

States have direct responsibility for meeting requirements of the Federal Clean Air Act

and corresponding federal regulations. As authorized by Division 26 of the California

Health and Safety Code, the CARB is directly responsible for regulating emissions

from mobile emission sources. However, authority to regulate stationary emission

sources has been delegated to air pollution control and air quality management

districts at the county and regional levels. The State of California still has oversight

authority to monitor the performance of district programs and can assume authority to

conduct district functions if the district fails to meet certain responsibilities.

b. State Implementation Plans (SIPs)

Section 110 of the Clean Air Act requires states to develop SIPs for non-attainment

areas that identify how the state will attain and maintain the NAAQS and other federal

air quality regulations. How these areas will attain the standards is often based on the

state’s controls on new or existing air pollution sources. Controls can include more

stringent pollution control requirements for industry, tighter requirements on wood-

burning stoves or prescribed burning, or more stringent controls on mobile sources of

emissions. States and districts also have authority to make air quality standards and

regulations more stringent than federal standards and regulations. The plan consists of

adopted measures, commitments to adopt new measures (including adoption and

implementation schedules), emission inventories, air quality modeling results,

contingency measures and a demonstration of emission reductions sufficient for

attainment. The Forest Service (and other federal agencies) are required to comply

with all of the requirements of a SIP under the General Conformity Rule.

c. Title 17

Title 17 of the California Code of Regulations, Sub Chapter 2, describes the “Smoke

Management Guidelines for Agricultural and Prescribed Burning” to provide direction

to air pollution control and air quality management districts in the regulation and

control of agricultural burning, including prescribed burning, in California. The

Guidelines are intended to provide for the continuation of agricultural burning,

including prescribed burning, as a resource management tool, and provide increased

opportunities for prescribed burning and agricultural burning while minimizing smoke

impacts on the public. The regulatory actions called for are intended to assure that

each air district has a program that meets air district and regional needs. These

guidelines became effective March 14, 2001. Under the guidelines each

APCD/AQMD developed a Smoke Management Plan (SMP) that, added to the SMPs

of all districts in California, was certified by the EPA as a state SMP. Under the

guidelines a burn plan is developed to acquire a burn permit (or authorization to burn)

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from the local APCD/AQMD. Authorization is received from the air quality district

on the day prescribed burning is implemented which is declared by the CARB as a

“burn day.” Smoke Management Plan elements are included in the Guidelines.

Details about Title 17 can be downloaded from the website:

http://www.arb.ca.gov/smp/regs/regs.htm

d. Assembly Bill 32 (AB32)--Global Warming Solutions Act of 2006

The state of California ranks as number 12 in the world for the highest emitted

amounts of Green House Gases (GHGs). The California Assembly and Senate have

passed Bills to curb Global Warming. One of the Bills, AB32, was passed in 2006 and

is summarized below:

In response to a warning from the scientific community that 90% of the California’s

Sierra snow-pack can be lost by 2050 if global warming emissions are not reduced by

80%, the AB32 commits the state to reduce its global warming emissions to 2000 level

by 2010, to 1990 level by 2020 and 80% below 1990 levels by 2050. AB32 codifies

the state’s goal by requiring the state to achieve 1990 level by 2020 through

enforceable statewide cap on these emissions. This reduction will be accomplished

through an enforceable statewide cap (to be phased in by 2012) on global warming

emissions. AB32 directs the CARB to develop regulations and establish a mandatory

reporting system to track and monitor global warming emission levels. To implement

the cap it requires the CARB to use the following principles for emissions reduction:

-Distribute benefits and costs equitably;

-No increase in direct, indirect or cumulative air pollution in local communities;

-Protect entities that have already taken actions; and

-Allow for coordination with other states and countries.

4. Local Regulators—Northeast Plateau

The California Clean Air Act established a number of legal mandates to facilitate achieving

health-based state air quality standards at the earliest practicable date. The State is currently

divided into 15 air basins and 58 counties. Some of these counties are split between two or

more air basins. Figure 1 shows the current air basin boundaries and the location of the

counties that lie within each air basin. Within Siskiyou County, the air quality regulating

authority is the Siskiyou County Air Pollution Control District (SCAPCD). The SCAPCD

monitors air quality at three sites throughout the County, and has the responsibility of

enforcement to both the federal and state air quality regulations at the local level.

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Figure 1: California Air Basins.

Overview of Issues Addressed

Criteria Pollutants

Siskiyou County is identified as attainment or unclassified for carbon monoxide (CO), Sulfur

Oxides (Sox), Lead, Respirable Particulate matter (PM10) and Fine Particulate Matter (PM2.5) for

both state and federal standards. The classification of unclassified is given to counties where

there is not enough information for status to be determined. These counties are treated as if they

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are in attainment for the criteria pollutants until further information can be gathered. Siskiyou

County is in “non-attainment/transitional” status for the state 8-hour ozone standards. Therefore,

compliance with the General Conformity Rule for ozone must be analyzed for this project.

Although the effects of the project on other criteria pollutants do not need to be analyzed per the

General Conformity Rule, they are displayed as part of the existing condition of the project area

for information purposes. The other criteria pollutants were analyzed in order to fully disclose

the impacts to all NAAQS’s of the proposed action as outlined in A Desk Reference for NEPA

Air Quality Analysis (USFS 1995, pg. 2-4).

Ozone is not directly emitted into the air. Ground-level ozone is the result of a chemical reaction

between nitrogen-oxygen compounds (NOx) and volatile organic compounds (VOCs) in the

presence of sunlight. The primary source of NOx is the combustion of fossil fuels by mobile

sources (i.e. cars, trucks, tractors, etc.). At ground level, ozone contributes to smog and can

impact vegetation growth.

Carbon Monoxide, Nitrogen-oxygen compounds (NOx) and SOx are formed when either forest

or fossil fuels are not completely combusted. These pollutants can all adversely impact human

health and environmental quality and are estimated in this analysis. Air-borne lead emissions are

usually near lead-smelters and therefore are not analyzed here.

Regional Haze Rule

The visibility of Class I Wildernesses is protected by the Regional Haze Plan. The project area is

approximately 20 miles north of the Marble Mountain Wilderness, which is a Class I Wilderness.

Emissions from stand treatment and prescribed burning would be transient and short lived. The

small community of Horse Creek, CA is within the project boundary and is on average 4 miles

away from proposed treatments. A portion of the material would likely be hauled through the

community.

Green House Gases (GHG) and Climate Change

The temperature of the earth’s atmosphere is regulated by a balance between the radiation

received from the sun, the amount reflected by the earth’s surface and clouds, and the amount of

radiation absorbed by the earth and atmosphere. The so-called greenhouse gases, which include

carbon dioxide (CO2) and water vapor, keep the earth’s surface warmer than it would be

otherwise because they absorb infrared radiation from the earth and, in turn, radiate this energy

back down to the surface. While these gases occur naturally in the atmosphere, there has been a

rapid increase in concentrations of greenhouse gases in the earth’s atmosphere from

anthropogenic sources since the start of industrialization, which has caused concerns over

potential changes in the global climate.

Prescribed burning activities release GHG including CO2 and CH4 into the air which could

contribute to climate change. Currently there are no thresholds for GHG emissions for prescribed

burning activities. The Council on Environmental Quality recommends that Federal agencies

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disclose in the NEPA analysis the effects of climate change for actions that are estimated to emit

more than 25,000 metric tons of CO2 equivalents annually (40 CFR parts 1500-1508). .

Emissions of GHG are commonly expressed in a common metric which is the carbon dioxide

equivalent (CO2e). Some GHG are more potent than others and this metric allows for the direct

comparison of impacts between different activities with different ratios of GHG emissions. This

is not a threshold for adverse effects, but rather a trigger point for when an analysis of GHG

emissions and disclosure of the results should be included in the NEPA document.

Issue Indicators

1. Estimated emissions of Criteria Pollutants (NOx, SOx, CO, and PM) for each alternative.

2. Estimated effects on CO2 and CH4 (GHG) emissions for each alternative.

Affected Environment

The project area is located approximately 2 miles north of Horse Creek, California, in Siskiyou

County. The project area is primarily forested federally managed lands with no substantial

human-caused emission sources within the area other than emission and fugitive dust from

logging and recreation. Other emission contributions would be smoke and haze from seasonal

wildland and prescribed fires from both within and outside the county. The Area-wide sources,

primarily from prescribed forest burning, account for a majority of the CO and particulate matter

emitted in the county (Table 2). The NOx emissions are primarily from heavy-duty diesel trucks.

The SOx emissions for 2010 were driven by wildfire emissions (Table 3).

The visibility of Class I Wildernesses is protected by the Regional Haze Plan. The project area is

approximately 20 miles north of the Marble Mountain Wilderness, which is a Class I Wilderness.

The climate is a Mediterranean subtype with warm dry summers and cool moist winters. The

mean annual precipitation is about 25 to 40 inches. Most of the precipitation is snow. Mean

annual temperature is about 35o F to 45

o F. Wind patterns fluctuate on a diurnal and seasonal

basis. During the dry summer months, when dust is most likely to be generated, winds are

generally terrain-driven. Mountain-valley diurnal winds characterize the surface flow. Up-valley

winds occur in the late morning and last until after sunset and down-valley winds begin as night-

time cooling occurs.

According to CARB website (www.arb.ca.gov) the ambient air in portions of the SCAQMD

exceeds the State PM10 standard during many of the winter months. Siskiyou County is

identified as attainment or unclassified for carbon monoxide (CO), Sulfur Oxides (SOx), Lead,

and Respirable Particulate matter (PM10) and Fine Particulate Matter (PM2.5) for both state and

federal standards. Therefore the project is exempt from conformity determination for these

pollutants. Siskiyou County is in “non-attainment/transitional” status for 8-hour ozone, a product

of volatile organic compounds or Nitrogen Oxides (NOx).

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Table 2: 2010 estimated annual average emissions (tons/day) for Siskiyou County,

California (retrieved from http://www.arb.ca.gov/app/emsinv/emssumcat.php on 22

December 2010)

STATIONARY SOURCES CO NOX SOX PM10 PM2.5

FUEL COMBUSTION 0.6 0.6 0.0 0.3 0.3

WASTE DISPOSAL 0.0 0.0 - 0.0 0.0

CLEANING AND SURFACE COATINGS - - - - -

PETROLEUM PRODUCTION AND MARKETING - - - - -

INDUSTRIAL PROCESSES - - - 0.4 0.2

TOTAL STATIONARY SOURCES 0.6 0.6 0.0 0.6 0.4

AREAWIDE SOURCES CO NOX SOX PM10 PM2.5

SOLVENT EVAPORATION - - - - -

RESIDENTIAL FUEL COMBUSTION 20.05 0.38 0.19 3.13 3.01

FARMING OPERATIONS - - - 1.08 0.16

CONSTRUCTION AND DEMOLITION - - - 0.26 0.03

PAVED ROAD DUST - - - 2.09 0.31

UNPAVED ROAD DUST - - - 11.93 1.19

FUGITIVE WINDBLOWN DUST - - - 0.35 0.05

FIRES (Structural) 0.00 - - 0.00 0.00

MANAGED BURNING AND DISPOSAL 198.22 - - 13.04 11.71

COOKING - - - 0.03 0.02

TOTAL AREAWIDE SOURCES 218.3 0.4 0.2 31.9 16.5

MOBILE SOURCES CO NOX SOX PM10 PM2.5

ON-ROAD MOTOR VEHICLES 23.8 10.9 0.0 0.4 0.3

OTHER MOBILE SOURCES 10.2 4.5 0.0 0.2 0.2

TOTAL MOBILE SOURCES 34.0 15.4 0.0 0.7 0.6

NATURAL (NON-ANTHROPOGENIC) SOURCES CO NOX SOX PM10 PM2.5

NATURAL SOURCES (including wildfires) 113.0 4.1 1.2 11.8 10.0

TOTAL NATURAL (NON-ANTHROPOGENIC)

SOURCES

113.0 4.1 1.2 11.8 10.0

GRAND TOTAL FOR SISKIYOU COUNTY 365.9 20.4 1.5 45.0 27.5

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Table 3: Summary of contribution (percent) of estimated annual pollutants by source type

in Siskiyou County, California for 2010

CO NOx SOx PM10 PM2.5

Stationary Sources

0% 3% 0% 1% 1%

Area Wide Sources

60% 2% 13% 71% 60%

Mobile Sources

9% 75% 0% 2% 2%

Natural Sources

31% 20% 80% 26% 36%

Environmental Consequences

Methodology

The emissions for the criteria pollutants NOx, CO, Sox, and PM for mobile sources were

estimated using an emissions factor model as outlined in Desk Reference for NEPA Air Quality

Analysis (USFS 1995). The emissions for the criteria pollutant PM for area sources (dust from

roads) were estimated using an emissions factor model as outlined in Compilation of Air

Pollution Emission Factors (EPA 1995).

The NOx, CO, PM and SOx analysis makes several assumptions in order to estimate the amount

of emissions per year from mobile sources and fugitive dust for the proposed activities. These

assumptions make this analysis a worst case scenario and provide a maximum emissions

estimate for the alternatives. This analysis assumes all equipment will run (moving or idling) for

5 hours a day for 80 days a year (4 months). The analysis also assumes that all the equipment

uses diesel fuel. The emissions factor is taken from the USFS Desk Reference for NEPA Air

Quality Analysis (USFS 1995, page 3.3.1-4 & 3.3.2-4). These factors do not account for all the

emissions reduction technology for vehicles and fuel currently in place, therefore the emissions

estimates are an over-estimate. The PM10 and PM2.5 analysis assumes 5 miles is the average haul

length and that every haul is a round trip.

The emissions and impacts of prescribed burning and wildfire on air quality are difficult to

quantify because of the many site-specific factors involved: fuel type, fuel loading, moisture

conditions, combustion rate, and meteorological conditions. Emissions of PM10, PM2.5, NOx,

SO2and CO can be estimated through the use of the fire model First Order Fire Effects Model

(FOFEM). The GHG CO2 and CH4 were also estimated using FOFEM. FOFEM is recognized by

the Forest Service Pacific Southwest Region as being the most current and accurate analysis tool

available for emissions prediction (Reinhardt et. al 1997). It is based on extensive research in

western forest ecosystems.

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FOFEM was used to estimate emissions from a wildfire in the Johnny O’Neil LSR Habitat

Restoration and Fuels Reduction Project area compared to a prescribed burn. Both scenarios

used the same fuel model and fuel loading approximations. The wildfire assumes drier

conditions. The prescribed burn scenario assumes moderate moisture conditions.

The criteria pollutant emissions are presented as US tons per year for ease of comparison to the

General Conformity Rules De Minimis thresholds (Table 1). GHG are presented in metric tons

per year which is the standard metric for presenting GHG. Emissions of GHG are commonly

expressed in a common metric which is the carbon dioxide equivalent (CO2e). Some GHG are

more potent than others and this metric allows for the direct comparison of impacts between

different activities with different ratios of GHG emissions.

Spatial and Temporal Context (bounding of analysis area) for Effects Analysis

Emissions from mobile sources such as logging trucks and tractors, as well as from prescribed

burning, are transient and the impacts are short-lived. Along with this the air quality regulations

are in terms of 1-year emissions. In light of this, the temporal analyses are on an annual basis and

this is considered short-term. Impacts are considered long-term if they persist for more than a

year. The cumulative effects of the mobile source emissions, fugitive dust and smoke emission

will be addressed on the 6th

field watershed scale (Horse Creek and Seiad Creek). The smoke

emissions will be addressed at the basin-wide scale (Siskiyou County). The cumulative effects of

GHG emissions impact on climate change is on the global scale.

Past, Present, and Reasonably Foreseeable Future Actions Relevant to

Cumulative Effects Analysis

The following reasonably foreseeable actions were specifically considered in the cumulative

effects analysis in the report (see Appendix C of the FEIS for more details).

• Thom-Seider Fuels Reduction and Vegetation Management Project (planning ongoing)

o The project includes timber stand treatments and prescribed burning that may be

implemented at the same time as the Johnny O’Neil project.

• Middle Creek Project (planning ongoing)

o The action within the Horse Creek Watershed includes thinning and burning. It is

likely to have a minimal impact to air quality due to the small size of the project

but may be implemented at the same time as the Johnny O’Neil project.

The following reasonably foreseeable actions considered to have negligible interaction with the

proposed actions.

• Horse Heli (planning complete in 2007, implementation ongoing)

o This project is being implemented within the Horse Creek Watershed; therefore,

emissions from the project are incorporated into the existing condition of Siskiyou

County’s air quality.

• Checkerboard Roadside Hazard Tree Removal Project (implementation ongoing)

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o Part of this action is being implemented in the Horse Creek Watershed. It is likely

to have a small impact to air quality due to the intermittent and dispersed nature

of the action.

• Motorized Travel Management (implementation in 2012)

o About 0.03 miles (1 road) is being added to the National Forest Transportation

System (NFTS) in the Lower Horse Creek 7th

field sub-watershed (within the

treatment area) to provide motor vehicle access to a dispersed recreation site, and

0.44 miles (2 routes to access dispersed recreation sites) are being added in the

Buckhorn Creek 7th

field sub-watershed (outside the treatment area). No other

roads are being added to the NFTS for motor vehicle use in the Horse Creek 6th

field watershed. Motor vehicle use will be prohibited other than on NFTS roads

within the watershed and no motor vehicle use will be allowed on unauthorized

routes. The air quality analysis for this project showed no new impact to air

quality in Siskiyou County; therefore, the impacts are incorporated into the

existing condition.

Comparison of Alternatives

Alternative 1 – No Action

Direct Effects and Indirect Effects

Under this alternative, no treatments would occur, and there would be no anthropogenic emission

contribution associated with this action for air quality degradation. This will lead to increased

accumulation of ground fuel leading to increased high intensity wildfires in future and higher

potential for air quality degradation. Air quality can be degraded by smoke from wildfires to the

point of human illness in some instances. Estimates of emissions for wildfire smoke emissions

are not quantified due to the unpredictable nature of the spatial and temporal extent of a potential

wildfire on the landscape. FOFEM outputs, however, indicate that emissions per acre of wildfire

are between 20-35% greater for each pollutant than prescribed burning. It is important to note

that emissions from a wildfire would be on a much shorter time frame than prescribed burning

and may even be a one-time event.

Smoke from wildfire could also cause visual impacts to the surrounding areas, and create

hazardous driving conditions on adjacent State, County, and Forest Service Roads for extended

periods of time. A wildfire event is most likely to occur during the summer season which

coincides with high recreation use in the Marble Mountain Wilderness and other parts of the

Forest. Smoke emissions could impact visibility in the Marble Mountain Wilderness which is a

Class I Wilderness and protected under the Regional Haze Plan. Should a catastrophic wildfire

occur, dust emissions, resulting from fire suppression equipment (both on and off roads) could

show a marked increase until seasonal rains soak the surface of the burned area.

One objective of the project is to prevent the occurrence of large uncontrolled wildfires.

Wildfires present a risk to the public health and result in damage to both the environment and

property. Wildfires are known to result in high levels of emissions including GHGs and

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associated NAAQS violation and worst visibility. Vegetation management treatments provide

the opportunity on a long-term basis to reduce the magnitude of wildfire air quality problems.

Cumulative Effects

Under the No Action Alternative the trend of emissions would not be expected to change from

the existing conditions. The primary sources contributing to air pollution would include wood

burning, motor vehicle exhaust, prescribed fire and wildfire (

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Table 2). Activities associated with the Thom-Seider Fuels Reduction and Vegetation

Management Project and Middle Creek Project activity would increase the criteria pollutants and

GHG during implementation of the project. These activities would not, however, lead to a

violation of air quality standards for Siskiyou County.

Wildfire activity is expected to continue as it has occurred in the past. A large, unplanned

wildfire could potentially lead to a severe increase in air pollutants and GHG emissions that

would reduce visibility and may result in the release of emissions that may exceed air quality

standards in Siskiyou County. GHG emissions would cumulatively contribute to climate change

globally.

Compliance with Forest Plan and Other Relevant Laws, Regulations, Policies and

Plans

Under this alternative no direct emissions of criteria pollutants or GHG would be released into

the air. Therefore, the No Action Alternative would comply with the Forest Plan and other

relevant laws and regulation.

Summary of Effects

Under the No Action Alternative there would be no new emissions of criteria pollutants or GHG

from activities. This will lead to increased accumulation of ground fuel leading to increased high

intensity wildfires in future and higher potential for air quality degradation. The air pollutant

emissions from a wildfire would be 20-35% higher than for prescribed burning. If a wildfire

should occur it would result in poor air quality during the wildfire event for Horse Creek, CA

and may impact the Marble Mountain Wilderness during high use times.

Alternatives 2, 3 and 4 – Proposed Action, Modified Proposed Action and No

Temporary Roads Alternatives

Direct and Indirect Effects

In Alternatives 2, 3, and 4 the stand treatment operations will produce criteria pollutant

emissions from the exhaust of mobile sources such as logging and hauling machinery and

operations equipment. Fugitive dust (PM10 and PM2.5) would also be released by traffic and

logging equipment. Emissions from mobile sources and fugitive dust can lead to short-term air

quality degradation and adverse health impacts to those with cardiovascular and respiratory

ailments. The increase in fugitive dust and air pollution may be apparent locally by Horse Creek

Residence during implementation. These impacts will be minimized by the project design

features for fugitive dust mitigation outlined in this report. The Marble Mountain Wilderness is

over 20 miles away and it is unlikely that the emissions from mobile sources and fugitive dust

would noticeably adversely impact the visibility for any of the action alternatives.

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Prescribed burning would produce smoke. The burning also produces PM, CO, SOx and NOx

emissions which are criteria pollutants. Emissions from prescribed burning can lead to air quality

degradation and adverse health impacts to those with cardiovascular and respiratory ailments.

Indirect effects of prescribed fire include the potential for a decrease in wildfire emissions due to

a reduction of overall fuel loading. Prescribed burning, depending on the wind direction and

smoke dispersal, could also impact visibility and air quality in Horse Creek and along Highway

96 temporality. Smoke can also add to regional haze and reduce visibility from vistas and Class I

Wildernesses. This impact would be minimized by implementation of the project design features.

Prescribed burning will directly emitted CO2 and CH4 which are GHG by releasing the carbon

stored in organic material such as vegetation and duff. GHG emissions would ultimately

cumulatively add to climate change. Prescribed burning and other fuels treatments also increase

the forest’s ability to sequester carbon in the long-term. Zhang et al. (2010) found that active

density control increased carbon sequestering, decrease tree mortality due to wildfire and

decreased sensitivity of stand health to climate change. In the short-term (1 – 10 years) the

carbon sequestered by managed forest stands would decrease. In the long-term (>10 years),

however, the carbon sequestered would be higher managed stands than in unmanaged stands.

The areas treated with prescribed fire would likely not only re-sequester the carbon released

during treatment but be able to surpass unmanaged stands in the amount of additional carbon

stored in the long-term (Zhang et al 2010, Hurteau & North 2010).

Adverse effects could be minimized through implementation of Smoke Management Plans

(SMP), which are required for all burning activities greater than 10 acres in size. The SMP,

administered through the SCAPCD, mitigate smoke impacts by regulating and coordinating

regional land managers' large burn projects in order to prevent any violations of state and federal

ambient air quality standards. In addition, the implementation of dust abatement measures help

to control dust emissions from ground disturbance activities and unpaved road travel. The project

emissions for Alternative 2, 3 and 4 are compared in In Alternatives 2, 3, and 4 the stand

treatment operations will produce criteria pollutant emissions from the exhaust of mobile sources

such as logging and hauling machinery and operations equipment. Fugitive dust (PM10 and

PM2.5) would also be released by traffic and logging equipment. Emissions from mobile sources

and fugitive dust can lead to short-term air quality degradation and adverse health impacts to

those with cardiovascular and respiratory ailments. The increase in fugitive dust and air pollution

may be apparent locally by Horse Creek Residence during implementation. These impacts will

be minimized by the project design features for fugitive dust mitigation outlined in this report.

The Marble Mountain Wilderness is over 20 miles away and it is unlikely that the emissions

from mobile sources and fugitive dust would noticeably adversely impact the visibility for any of

the action alternatives.

Prescribed burning would produce smoke. The burning also produces PM, CO, SOx and NOx

emissions which are criteria pollutants. Emissions from prescribed burning can lead to air quality

degradation and adverse health impacts to those with cardiovascular and respiratory ailments.

Indirect effects of prescribed fire include the potential for a decrease in wildfire emissions due to

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a reduction of overall fuel loading. Prescribed burning, depending on the wind direction and

smoke dispersal, could also impact visibility and air quality in Horse Creek and along Highway

96 temporality. Smoke can also add to regional haze and reduce visibility from vistas and Class I

Wildernesses. This impact would be minimized by implementation of the project design features.

Prescribed burning will directly emitted CO2 and CH4 which are GHG by releasing the carbon

stored in organic material such as vegetation and duff. GHG emissions would ultimately

cumulatively add to climate change. Prescribed burning and other fuels treatments also increase

the forest’s ability to sequester carbon in the long-term. Zhang et al. (2010) found that active

density control increased carbon sequestering, decrease tree mortality due to wildfire and

decreased sensitivity of stand health to climate change. In the short-term (1 – 10 years) the

carbon sequestered by managed forest stands would decrease. In the long-term (>10 years),

however, the carbon sequestered would be higher managed stands than in unmanaged stands.

The areas treated with prescribed fire would likely not only re-sequester the carbon released

during treatment but be able to surpass unmanaged stands in the amount of additional carbon

stored in the long-term (Zhang et al 2010, Hurteau & North 2010).

The Northeast Plateau Air Basin (NPAB) is in a non-attainment/transitional status for 8-hour

Ozone emissions, therefore this project is subject to the General Conformity Rule. Under this

regulation if the activities result in emissions above the De Minimis emissions, it must be

reviewed for conformity with the state implementation plan. The emissions are not anticipated to

exceed the General Conformity Rule De Minimis values for NOx.

Comparison of Alternatives

Alternatives 2, 3, and 4 are nearly identical in their emissions for criteria pollutants and GHG

(Table 4). The NOx and SOx emission estimates are identical for Alternatives 2, 3, and 4.

Alternative 2 has the lowest CO, PM10, and CO2e emissions. However, the differences in the

estimates are nominal with <1% difference in emissions between Alternatives 2, 3, and 4.

Table 4: Estimated pollutant emissions from prescribed fire and stand treatment activities

for Alternative 2, 3, and 4

Alternative Activity NOx CO SOx PM10 CO2 CH4 CO2e

Tons/year Metric Tons/year

Alt. 2 Hauling 1.6 0.6 0.2 5.1 -- -- --

Yarding 0.6 0.8 0.2 0.3 -- -- --

Prescribed Fire 16 6804 28 615 33174 283 39117

Total Emissions

(tons/year) 18.2 6805.8 28.4 620.4 33174 283 39117

Alt. 3 Hauling 1.6 0.6 0.2 5.1 -- -- --

Yarding 0.6 0.8 0.2 0.3 -- -- --

Prescribed Fire 16 6845 28 618 33186 285 39171

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Cumulative Effects

Emissions under Alternatives 2, 3 and 4 would contribute to local, air basin, and global pollutant

loading. At the local scale, there would be some impact on air quality from engines used to

operate vehicles, equipment, and chainsaws during thinning and burning operations associated

with the proposed activities as well as the Thom-Seider and Middle Creek Projects. Thom-Seider

project was compliant with the General Conformity Rule for NOx and was not expected to

violate the air quality regulations. Middle Creek project is small and would be accomplished

over a relatively short period of time. Cumulatively these emissions are expected to be minimal,

able to disperse readily and would not likely lead violation of air quality standards.

Local and basin-wide effects would include cumulative prescribed burn emissions from federal,

state, and private lands in the area. The proposed management activities would result in

emissions that can affect local and regional air quality that may cumulatively contribute to

regional haze, which results from the accumulation of diffuse pollutants from multiple sources

within the NPAB. Burning may occur simultaneously in other areas within the NPAB, which

may combine and result in a cumulatively considerable increase in pollutants. Multiple

prescribed burn activities, occurring at the same time, could cumulatively increase pollutant

levels.

Compliance with Burn Day, Marginal Burn Day, and No Burn Day designation, and

coordination with and permitting from the SCAPCD, would minimize cumulative effects of

prescribed fire. The number of days to accomplish prescribed burning in this project would

compete with other burning nearby and within the NPAB on any given day. Ideally, the effects

of one burn activity are completed before another burn activity begins. Impacts to air quality

would generally be confined to no more than a few hours, or at most a few days. The cumulative

effect of prescribed fire on air quality is short-term, because once the burn is over and the smoke

has dissipated, the effect is over.

Alternatives 2, 3 and 4 would result in direct GHG emissions that would contribute to the

cumulative effects of global climate change. Carbon sequestration in forests and wood products

helps to offset sources of CO2 to the atmosphere, such as deforestation, forest fires, and fossil

fuel emissions. It is likely that Alternatives 2, 3 and 4 would result in a forest ecosystem that is

burned with less intensity, allowing biomass to accumulate and carbon sequestration to continue.

Also, management activities allow for an increase in the forests ability to sequester carbon

(Zhang et al 2010). This will help to offset the GHGs associated with prescribed burning

Total Emissions

(tons/year) 18.2 6846.3 28.4 623.4 33186 285 39171

Alt. 4 Hauling 1.6 0.6 0.2 5.1 -- -- --

Yarding 0.6 0.8 0.2 0.3 -- -- --

Prescribed Fire 16 6841 28 618 33137 285 39122

Total Emissions

(tons/year) 18.2 6842.3 28.4 623.4 33137 285 39122

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activities. Therefore, Alternatives 2, 3 and 4 would result in minimal cumulative impacts on air

quality associated with GHG emissions.

Compliance with Forest Plan and Other Relevant Laws, Regulations, Policies and

Plans

The project is not anticipated to result in an adverse impact to air quality because compliance

with SCAPCD burn day designations and permits has resulted in continued attainment status

designations for both federal and state standards (with the exception of ozone) within the NPAB.

In addition, the proposed action would reduce fuel loadings and crown fire potential, thereby

reducing fire intensity and associated smoke generation that would otherwise occur during a

wildfire with no fuels management. Therefore, the current attainment status for all but ozone

within NPAB is expected to continue. The emissions are not anticipated to exceed the General

Conformity Rule De Minimis values for NOx. Therefore, the project complies with the General

Conformity Rule as well.

Summary of Effects

Alternatives 2, 3 and 4 will produce criteria pollutant and GHG emissions from the exhaust of

mobile sources and hauling activities. These emissions may impact visibility and air quality for

Horse Creek, CA and the surrounding area. The criteria and GHG emissions from prescribed

burning may impact visibility and air quality in Horse Creek and possibly in the Marble

Mountain Wilderness during implementation. The NPAB is in non-attainment/transitional status

for 8-hour ozone. Therefore, the project has to meet the regulations outlined in the General

Conformity Rule for NOx. The emissions are not anticipated to exceed the General Conformity

Rule De Minimis values for NOx for Alternatives 2, 3 and 4.

GHG emissions would contribute to climate change. However, the areas treated with prescribed

fire would likely not only re-sequester the carbon released during treatment but be able to

surpass unmanaged stands in the amount of additional carbon stored in the long-term.

The cumulative effects of Alternatives 2, 3 and 4 on air quality is expected to be minimal with

the oversight of the SCAPCD. Criteria pollutant and GHG emissions would degrade air quality

cumulatively with activities occurring in the surrounding area. However, these emissions are

expected to be minimal and able to disperse readily. Compliance with Burn Day, Marginal Burn

Day, and No Burn Day designation, and coordination with and permitting from the SCAPCD,

would minimize cumulative effects of prescribed fire.

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References (Literature Cited)

CEQ. 2010. Memorandum for Heads of Federal Departments and Agencies: Draft NEPA guidance on

Consideration of the Effects of Climate Change and Greenhouse Gas Emissions.

EPA. 1995. Compilation of Air Pollutant Emission Factors. Volume I: Stationary Point and Area Sources.

US Department of Interior, US Environmental Protection Agency.

Hurteau, M. and North, M. 2010. Carbon Recovery Rates Following Different Wildfire Risk

Mitigation Treatments. Forest Ecology and Management.

Reinhardt, E., Keane, R., Brown, J. (1997) First Order Fire Effects Model: FOFEM 4.0 User’s

Guide. USDA, US Forest Service. Intermountain Research Station General Technical

Report. INT-GTR-344.

USFS. 1995a. A Desk Reference for NEPA Air Quality Analysis. US Department of Agriculture, US

Forest Service.

USFS. 1995b. Air Quality Conformity Handbook. US Department of Agriculture, US Forest Service.

Zhang, J., Powers, R., and Skinner, C. 2010. To Manage or Not to Manage: The Role of

Silviculture in Sequestering Carbon in the Specter of Climate Change. USDA, US Forest

Service Proceedings. RMRS-P-61.