United States

Department of

Agriculture

Forest

Service

July 2017

Air Quality Report

Craggy Vegetation Management Project

Salmon/Scott River Ranger District, Klamath National Forest

Siskiyou County, California

Prepared By: Angie Bell

Klamath National Forest Headquarters

1711 S. Main Street, Yreka, CA 96097

Non-Discrimination Policy

The U.S. Department of Agriculture (USDA) prohibits discrimination against its customers, 

employees, and applicants for employment on the bases of race, color, national origin, age, disability, 

sex, gender identity, religion, reprisal, and where applicable, political beliefs, marital status, familial or 

parental status, sexual orientation, or all or part of an individual's income is derived from any public 

assistance program, or protected genetic information in employment or in any program or activity 

conducted or funded by the Department. (Not all prohibited bases will apply to all programs and/or 

employment activities.)

To File an Employment Complaint

If you wish to file an employment complaint, you must contact your agency's EEO Counselor (PDF) 

within 45 days of the date of the alleged discriminatory act, event, or in the case of a personnel 

action. Additional information can be found online at www.ascr.usda.gov/complaint_filing_file.html.

To File a Program Complaint

If you wish to file a Civil Rights program complaint of discrimination, complete the USDA Program 

Discrimination Complaint Form (PDF), found online at www.ascr.usda.gov/ complaint_filing_cust.html, 

or at any USDA office, or call (866) 632-9992 to request the form. You may also write a letter 

containing all of the information requested in the form. Send your completed complaint form or letter 

to us by mail at U.S. Department of Agriculture, Director, Office of Adjudication, 1400 Independence 

Avenue, S.W., Washington, D.C. 20250-9410, by fax (202) 690-7442 or email at 

program.intake@usda.gov.

Persons with Disabilities

Individuals who are deaf, hard of hearing or have speech disabilities and you wish to file either an 

EEO or program complaint please contact USDA through the Federal Relay Service at (800) 877-

8339 or (800) 845-6136 (in Spanish).

Persons with disabilities who wish to file a program complaint, please see information above on how 

to contact us by mail directly or by email. If you require alternative means of communication for 

program information (e.g., Braille, large print, audiotape, etc.) please contact USDA's TARGET 

Center at (202) 720-2600 (voice and TDD).

i

Table of Contents

Air Quality Report.......................................................................................................................1

Introduction............................................................................................................................. 1

Methodology........................................................................................................................... 1

Analysis Indicators.................................................................................................................. 2

Spatial and Temporal Bounding of Analysis Area ................................................................. 2

Affected Environment............................................................................................................. 2

Environmental Consequences................................................................................................. 3

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

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

Cumulative Effects.......................................................................................................... 3

Alternative 2........................................................................................................................ 3

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

Cumulative Effects.......................................................................................................... 3

Alternative 3........................................................................................................................ 4

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

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

Comparison of Alternatives................................................................................................ 4

Compliance with law, regulation, policy, and the Forest Plan ........................................... 4

Literature Cited ....................................................................................................................... 5

List of Tables

Table 1: Comparison of the Effects of Alternatives on Air Resources and Greenhouse Gas Emissions......4

Air Quality Report Craggy Vegetation Management Project

1

Air Quality Report

Introduction

The purpose of this report is to analyze the effects of the project and its alternatives on air quality 

including the ambient air quality standards. The analysis will also include discussion on haze 

impacts on wilderness values associated with good air quality.

Methodology

Ambient Air Quality Standards

Siskiyou County is identified as in attainment for ozone, carbon monoxide, sulfur oxides, lead, 

respirable particulate matter and fine particulate matter (criteria pollutants) for both state and 

federal standards. Under the Conformity Rule, there is no further state or federal regulation for 

project activities that generate criteria emissions and these criteria pollutants do not need to be

analyzed further.

Regional Haze Rule

The Regional Haze Rule (1999) requires a Regional Haze Plan for Class 1 designated airsheds. 

These include National Parks and Wilderness established before 1977. Human-related sources of 

haze include industry, motor vehicles, agricultural and forestry burning, and dust from disturbed 

soils. The primary concern is the reduction of visibility in wilderness areas.

The Regional Haze Rule requires that states make reasonable progress towards achieving natural 

visibility conditions in Class 1 areas. Reasonable progress means that the worst haze days get 

less hazy and that visibility does not deteriorate on the best days when compared with the 

baseline period of 2000 to 2004 (California Air Resource Board, 2009). Federal agencies should 

not prevent this progress through management activities. The analysis will include an evaluation 

of the estimated residence time of smoke from project activities and its impact to the worst days’

haze to determine compliance with the Regional Haze Rule.

Greenhouse Gas Emissions

Prescribed burning activities for the Craggy project include prescribed underburning and pile 

burning. Pile burning may occur in any of the treatment units except for mastication. Prescribed 

burning activities release greenhouse gases including carbon dioxide and methane into the air 

which can contribute to climate change. Currently there are no thresholds for greenhouse gas 

emissions for prescribed burning activities. Emissions of greenhouse gases are commonly 

expressed in a common metric which is the carbon dioxide equivalent. Some greenhouse gases 

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

different activities with different ratios of greenhouse gases emissions. The Council on 

Environmental Quality (CEQ 2016) recommends that Federal agencies disclose in 

documentation of their NEPA analyses the estimated greenhouse gas emissions to inform the 

comparison of alternatives.

The average greenhouse gas emissions from prescribed fire are estimated using first order fire 

effects model. The modeling is based on a Douglas-fir - tanoak - madrone forest under moderate 

weather conditions with a natural or activity fuel load. The defaults of the model in this mode are 

used for the model runs. The first order fire effects model is recognized by the Forest Service 
Air Quality Report Craggy Vegetation Management Project

2

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.

Analysis Indicators

• Compliance with the Regional Haze Rule

 Estimated days of visibility impacted in the Wilderness

 Likelihood of preventing progress of the California Regional Haze Plan

• Estimated Greenhouse Gas Emission

Spatial and Temporal Bounding of Analysis Area

It is difficult to determine the spatial analysis area for effects to air quality due to the mobility of 

air. For this project, the spatial boundary includes the project area and the Marble Mountain

Wilderness Class I airshed under the Clean Air Act. Temporally, emissions from mobile sources 

such as logging trucks and tractors, as well as from prescribed burning, are transient and the 

impacts are short lived and the air quality regulations are in terms of one-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 these

emissions will be addressed at the project scale including the Marble Mountain Wilderness

which is about 16 miles away from the project.

Affected Environment

According to the California Air Resources Board website (http://www.arb.ca.gov/) Siskiyou 

County is in attainment for all criteria air pollutants.

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 will be smoke and haze from seasonal wildland and 

prescribed fires from both within and outside the County. According to the California Air 

Resources Board the nitrogen oxide emissions in the County are primarily from heavy-duty 

diesel trucks (such as from the I-5 corridor). This report was run using the following 

website: http://www.arb.ca.gov/app/emsinv/emssumcat.php (California Air Resources Board 

2012).

The Marble Mountain Wilderness which is designated as a Class 1 wilderness by the Clean Air 

Act. The haze species concentrations are measured as part of the IMPROVE (Interagency 

Monitoring of Protected Visual Environments) monitoring network deployed throughout the 

United States. The 24 days with the worst visibility are averaged each year and used to determine 

the worst days’ visibility. The visibility conditions for the Marble Mountain Wilderness are 

currently monitored by an IMPROVE monitor in the Trinity Alps. The worst air quality days are 

dominated by organic aerosols (they are particulate matter associated and cause a haze in the air). 

Organic aerosols peak during the summer months and are strongly correlated with the incidence 

of wildfires (California Air Resource Board, 2009). The amount of light extinction affects 

visibility or the clarity of objects viewed at a distance by the human eye. This is measured in 

“deciviews” which are the amount of obstruction the haze in the air causes; higher numbers 

mean you cannot see as far into the distance.
Air Quality Report Craggy Vegetation Management Project

3

Environmental Consequences

Alternative 1

Direct and Indirect Effects

Under this alternative no management action will be taken that will emit greenhouse gases or 

impact the visibility in the Marble Mountain Wilderness.

Cumulative Effects

There are no direct or indirect effects for this alternative and therefore no cumulative effects.

Alternative 2

Direct and Indirect Effects

The prescribed fire proposed in the project area will occur over a few days of any given year. 

Burning will occur in the spring or fall, outside of the wildfire season. Since the wildfire season 

is the time of the year when haze is at its worse, the project won’t impact visibility on the worst 

haze days. The likelihood that prescribed burning on a few days any given year will affect the 

average visibility on the best days over an entire year is small. The likelihood of preventing the 

progress of the Regional Haze Plan is very low for this alternative.

The greenhouse gas analysis uses the same assumptions as the Ambient Air Quality Standards 

analysis. An estimated 0.26 metric tons per acre and 31 metric tons per acre of emissions of 

methane and carbon dioxide respectively from prescribed fire in activity fuels will be created. 

One metric ton of methane is equivalent to 21 metric tons of the carbon dioxide equivalent. 

Therefore, prescribed fire on one acre of activity fuels will emit about 5.5 metric tons per acre of 

carbon dioxide equivalent. This alternative proposes prescribed fire on about 9,700 acres of 

activity fuels. Therefore, the greenhouse gas emissions will be about 10,670 metric tons of 

carbon dioxide equivalent per year (assuming five years for implementation of activity fuels).

It is not currently feasible to quantify the indirect effects of individual or multiple projects on 

global climate change and, therefore, determining significant effects of those projects or project 

alternatives on global climate change cannot be made at any scale (USDA 2009). Because 

greenhouse gases mix readily into the global pool, it is not currently possible to ascertain the 

indirect effects of emissions from single or multiple sources (projects). Also, because the large 

majority of Forest Service projects are extremely small in the global atmospheric carbon dioxide 

context, it is not presently possible to conduct quantitative analysis of actual climate change 

effects based on individual or multiple projects (USDA 2009).

Cumulative Effects

Adding the effects on air quality from Alternative 2 to effects of ongoing or reasonably 

foreseeable future actions in the project area is expected to have minimal cumulative effects at

the spatial analysis scale. Criteria pollutant and greenhouse gas 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 readily. Compliance with Burn Day, Marginal Burn 

Day, and No Burn Day designations, and coordination with and permitting from the Siskiyou 

County Air Pollution Control District, will minimize cumulative effects of prescribed fire.
Air Quality Report Craggy Vegetation Management Project

4

As greenhouse gas emissions are integrated across the global atmosphere, it is not possible to 

determine the cumulative impact on global climate from emissions associated with any number 

of particular projects. Nor is it expected that such disclosure will provide a practical or 

meaningful effects analysis for project decisions (USDA 2009).

Alternative 3

Direct and Indirect Effects

The effects of Alternative 3 are the same as for Alternative 2 except there are 10,550 acres of 

burning proposed instead of 9,700 as is proposed in Alternative 2. The likelihood of the progress 

of the Regional Haze Plan will remain the same as in Alternative 2. Greenhouse gas emissions 

will be increased to 11,605 metric tons of carbon dioxide equivalent per year.

Cumulative Effects

The cumulative effects are the same as in Alternative 2.

Comparison of Alternatives

Table 1: Comparison of the Effects of Alternatives on Air Resources and Greenhouse Gas Emissions.

Indicator Alternative 1 Alternative 2 Alternative 3

Compliance with Regional 

Haze Rule Complies High likelihood of 

Compliance

High likelihood of 

Compliance

Greenhouse Gas Emissions 

(metric tons/year) 0 10,670 11,605

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

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

with Siskiyou County Air Pollution Control District burn day designations and permits has 

resulted in continued attainment status designations for both federal and state standards. The 

project meets requirements for the General Conformity Rule and the Regional Haze Rule under 

the Clean Air Act.
Air Quality Report Craggy Vegetation Management Project

5

Literature Cited

California Air Resources Board. 2009. Regional Haze Plan. Retrieved 

from http://www.arb.ca.gov/planning/reghaze/rhplan.htm on 4 April 2014.

California Air Resource Board. 2012. Almanac Emissions Projection Data – 2012 Estimated 

Annual Average Emissions: Northeast Plateau Air Basin. Retrieved on 16 April 2014 

from http://www.arb.ca.gov/app/emsinv/2013/emssumcat_query.php?F_YR=2012&F_DI

V=-4&F_SEASON=A&SP=2013&F_AREA=AB&F_AB=NEP#8

CEQ. 2016. Final Guidance for Federal Departments and Agencies on Consideration of 

Greenhouse Gas Emissions and the Effects of Climate Change in National Environmental 

Policy Act Reviews. Council on Environmental Quality.

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.

USDA. January 2009. Climate Change Considerations in Project-Level NEPA Analysis. 

Washington Office.