United States 

Department of 

Agriculture 

Forest 

Service 

Southwestern 

Region 

Cibola 

National 

Forest and 

National 

Grasslands 

May 2011

Air Resources Specialist 

Report 

Kiowa, Rita Blanca, Black Kettle 

and McClellan Creek National 

Grasslands Plan Revision 

Environmental Impact Statement 

Analysis 

Submitted by: __/s/ _________________________ 

Livia Crowley, Forest Hydrologist 

 Cibola National Forest and National Grasslands 

Printed on recycled paper • Month Year 3 

Air Resources Specialist Report 

Introduction 

This report discloses and evaluates the potential environmental consequences on the air resources 

that may result with the adoption of a revised land management plan. It examines, in detail, three 

different alternatives for revising the management direction from the 1985 Cibola National Forest 

Land Management Plan (only that which is relevant to the National Grasslands). 

Relevant Laws, Regulations, and Policy that Apply 

The Forest and Rangeland Renewable Resource Planning Act of 1974, as amended by the 

National Forest Management Act (16 USC 1602). This Act directs the Secretary of Agriculture to 

protect, and where appropriate, improve the quality of soil, water, and air resources. 

The Clean Air Act, as amended in 1990 (42 USC 7401 et seq.), requires complying with all 

Federal, State, or local air control rules, regulations, and directives. 

Methodology and Analysis Process 

Air resources were assessed by reviewing available data relevant to air resources in the project 

area. The primary source of this data is the EPA website. The Forest Service does not have any 

air quality monitors in the project area. 

Assumptions 

In the analysis for this resource, the following assumptions have been made: 

• The land management plan provides a programmatic framework for future site-specific 

actions. 

• Land management plans do not have direct effects. They do not authorize or mandate any 

site-specific projects or activities (including ground-disturbing actions). 

• Land management plans may have implications, or environmental consequences, of 

managing the forests under a programmatic framework. 

• The plan decisions (desired conditions, objectives, standards, guidelines, management 

areas, monitoring) will be followed when planning or implementing site-specific projects 

and activities. 

• Law, policy, and regulations will be followed when planning or implementing sitespecific projects and activities. 

• Monitoring will occur and the land management plan will be amended, as needed. 

• We will be funded similar to past budget levels (past 5 years). 

• The planning timeframe is 15 years; other timeframes may be analyzed depending on the 

resource (usually a discussion of anticipated trends into the future). 

• Soil and Water Conservation Practices will be applied to all management activities as 

described in FSH 2509.22 (USDA, 1990). 
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Revision Topics Addressed in this Analysis 

There was not an air resources section in the 1985 Plan. No issues specific to air resources; 

however there are some related topics. Climate change was not addressed in the 1985 Plan for 

any resource. Information from the Southwest Region Climate Change Trends and Forest 

Planning (USDA, 2010) was used to consider climate change effects to air resources. Issues 

identified in the Notice of Intent (Federal Register, 2010) include the effect of human influences 

of the grasslands from livestock grazing, energy development, mining reclamation, miscellaneous 

forest products, mineral materials, and fire management. 

Summary of Alternatives 

Alternative A is the ‘no action’ alternative, meaning there is no change from the current 

management direct as found in the existing plan (USDA, 1985). There is no direction in the 

existing plan for air resources. 

Alternative B is the preferred alternative. Alternative B includes a desired condition for air 

resources. This condition is that air quality conditions are at acceptable attainment levels on the 

Grasslands. The Mills Canyon Management Area would be implemented to preserve the scenic 

and recreational qualities within the Canyon. 

Alternative C is similar to alternative B is all ways except that it recommends that part of the 

Canadian River Inventoried Roadless Area be designated as the Canadian River Potential 

Wilderness Area. 

Description of Affected Environment (Existing Condition) 

Of the three states that contain the Grasslands, only New Mexico has identified Airsheds. Texas 

and Oklahoma reference their air quality based on the county or descriptions of non-attainment or 

maintenance areas. 

The Kiowa NG is located within the Canadian River Airshed, as defined by the New Mexico 

Environment Department’s Smoke Management Program (NMED, 2005). Based on the EPA’s 

2010 non-attainment designations for the six criteria pollutants, the counties within the Canadian 

River Airshed are in attainment for all six pollutants (ground-level ozone, particulate matter 

pollution at 2.5 and 10 micrometers, lead, carbon monoxide, sulfur dioxide, and nitrogen oxides)

(USEPA, 2010a). The Black Kettle, McClellan Creek, and Rita Blanca NGs are split between 

Texas and Oklahoma. The associated counties covering these NGs are in attainment for all six 

pollutants (USEPA, 2010a). 

The regional emissions data were obtained from the EPA’s AirData tool for the year 2002 and 

from the National Emissions Inventory (NEI) for the year 2008. Based on emissions data from 

2002 to 2008, the overall trend was a decrease in all criteria air pollutants measured (excludes 

ozone and includes volatile organic compounds) in the four counties covering the Kiowa NG 

(USEPA, 1990, USEPA, 2008). The projected trend out to 2018, using the Forest Service’s 

Emissions Tool11, indicates a continued decrease in criteria pollutant emissions except particulate 

matter PM10 and PM2.5. It is not clear at this time why there are slight increases, but these 

increases are slight and do not exceed NAAQS or state standards. To date there have been no 
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documented exceedances of the NAAQS due to NG activities. This trend is expected to continue 

over the next five to ten years. 

Based on emissions data from 2002 to 2008 from the EPA AirData tool and the NEI, the overall 

trend was a decrease in all criteria pollutants except a small increase in sulfur dioxide emissions 

and large increase in volatile organic compounds (VOCs), in the five counties covering the Black 

Kettle, McClellan Creek, and Rita Blanca NGs. From 2002 to 2008, the VOCs doubled due to 

large increases in emissions in Hemphill County in Texas and Roger Mills County in Oklahoma, 

both of which comprise the Black Kettle National Grasslands. The increase in emissions in 2008 

can be attributed to petroleum and related industries. Although VOCs are not currently regulated 

by the USEPA, they do react with nitrogen oxides to form ozone, which is a USEPA regulated 

criteria pollutant. Even with the doubling of VOC emissions in Hemphill County, it is still in 

attainment for ozone. 

In general, the projected trend out to 2018 using the Forest Service’s Emissions Tool11 shows 

decreases in the criteria pollutant emissions. Increases in nitrogen oxides in Roger Mills County, 

Oklahoma, and carbon monoxide and sulfur dioxide in Gray County, Texas, are predicted. There 

are also projected increases in ammonia and VOCs, which may be due to further increases in oil 

and gas development or higher levels of urbanization in these counties. There have been no 

documented violations of the NAAQS in the counties the Black Kettle, McClellan Creek, or Rita 

Blanca NGs cover due to Grassland activities. This trend is expected to continue over the next 

five to ten years. 

Emissions from activities on and off the Grasslands include emissions from vehicles, dust from 

unsurfaced roads, cropland, construction sites, bare ground, campfires, prescribed fire, wildfire, 

and oil and gas developments. Oil and gas developments are regulated for emissions and required 

to have emission controls in all three states. Emissions related to fire are regulated through state’s 

smoke management plans. Emissions from vehicles, dust, and campfires are not regulated. There 

is no monitoring to know the effect, range, or variation in these emissions. Prescribed fire is the 

most notable land management activity that takes place on the Grasslands that has implications on 

air quality; however, this has not contributed to long term adverse air quality. All projects, 

including prescribed burns, must meet State air quality standards and smoke management plans 

once finalized (USDA Forest Service 1999, USDA Forest Service 2000). 

Environmental Consequences 

The land management plan provides a programmatic framework that guides site-specific actions 

but does not authorize, fund, or carryout any project or activity. Because the land management 

plan does not authorize or mandate any site-specific activities or ground-disturbing actions there 

can be no direct effects. However, there may be implications, or longer term environmental 

consequences, of managing the forests under this programmatic framework. 

The main difference between alternative is that alternatives B and C have a desired condition for 

air resources, and Alternative A does not. Since the desired condition for air resources listed in 

alternative B and C is regulatory, there really is no difference between the alternatives as to how 

air resources are managed on the Grasslands. 

Emissions from management activities include emissions from vehicles, dust from unsurfaced 

roads and bare ground, campfires, prescribed fire, wildfire, and oil and gas developments. Oil 
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and gas developments are regulated for emissions and required to have emission controls in all 

three states. Emissions related to fire are regulated through state’s smoke management plans. 

Emissions from vehicles, dust, and campfires are not regulated. There is no monitoring to know 

the effect, range, or variation in these emissions. However, they have not resulted in any 

violations of the national ambient air quality standards (NAAQS). It appears the levels of 

emissions produced by these activities are below the NAAQS and do not result in non-attainment. 

The levels of these emissions are expected to stay below NAAQS through the next 15 years. 

Cumulative Environmental Consequences 

Air quality regulation has recently required to states complete State Implementation Plans. These 

plans are enforceable documents which described how states will comply with air quality 

standards. All of the three states are working on or have completed these plans (USEPA, 2010b). 

The net effect of these plans is to reduce or maintain levels of air pollutants. Fire and oil and gas 

development is part of these plans. These plans are expected to reduce air pollution overall. As a 

result, none of the alternatives would contribute to cumulative effects from emissions to the air. 

Unavoidable Adverse Impacts 

The land management plan provides a programmatic framework that guides site-specific actions 

but does not authorize, fund, or carryout any project or activity. Before any ground-disturbing 

actions take place, they must be authorized in a subsequent environmental analysis. Therefore 

none of the alternatives cause unavoidable adverse impacts. 

Irreversible and Irretrievable Commitment of Resources 

The land management plan provides a programmatic framework that guides site-specific actions 

but does not authorize, fund, or carryout any project or activity. Because the land management 

plan does not authorize or mandate any ground-disturbing actions, none of the alternatives cause 

an irreversible or irretrievable commitment of resources. 

Adaptive Management 

All alternatives assume the use of adaptive management principles. Forest Service decisions are 

made as part of an on-going process, including planning, implementing projects, and monitoring 

and evaluation. The land management plan identifies a monitoring program. Monitoring the 

results of actions will provide a flow of information that may indicate the need to change a course 

of action or the land management plan. Scientific findings and the needs of society may also 

indicate the need to adapt resource management to new information. The Forest Supervisor 

annually evaluates the monitoring information displayed in the evaluation reports through a 

management review and determines if any changes are needed in management actions or the plan 

itself. In general, annual evaluations of the monitoring information consider the following 

questions: 

• What are the effects of resource management activities on the productivity of the land? 

• To what degree are resource management activities maintaining or making progress 

toward the desired conditions and objectives for the plan? 
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• What changes are needed to account for unanticipated changes in conditions? 

In addition to annual monitoring and evaluation, the Forest Supervisor reviews the conditions on 

the land covered by the plan at least every 5 years to determine whether conditions or demands of 

the public have changed significantly. The forest plan is ordinarily revised on a 10-year cycle and 

the Forest Supervisor may amend the plan at any time. 

Consistency with Law, Regulation, and Policy 

All alternatives are designed to guide the Kiowa, Rita Blanca, Black Kettle and McClellan Creek 

National Grasslands’ management activities in meeting federal law, regulations, and policy. 

List of Preparers 

Livia Crowley – Forest Hydrologist, B.A. Geology, Hartwick College. 23 years professional 

experience. Cibola National Forest and Grasslands 2009 - present. 

References 

Federal Register. 2010. Plan Development for Kiowa, Rita Blanca, Black Kettle, and McClellan 

Creek National Grasslands, Colfax, Harding, Mora, and Union Counties, NM: Dallam, Gray, 

and Hemphill Counties, TX; Cimarron and Roger Mills Counties, OK. USDA Forest Service. 

Federal Register, vol. 75, no. 10, Notices, pages 2477-2480. 

New Mexico Environment Department (NMED) Air Quality Bureau. 2005. New Mexico Smoke 

Management Program Guidance Document May 25, 2005. 

http://www.nmenv.state.nm.us/aqb/SMP/SmokeManagementGuidance.htm Accessed May, 

26, 2011. 

USDA. 1985. Cibola National Forest Land and resource Management Plan. USDA Forest 

Service, Southwestern Region, Albuquerque, NM. 

USDA. 1990. Forest Service Handbook 2509.22 – Soil and Water Conservations Practices

Handbook, Region 3 Supplement. Effective December 3, 1990. Albuquerque, NM. 

USDA Forest Service. 1999. Geographic Area Assessment Kiowa and Rita Blanca National 

 Grasslands, Cibola National Forest. Version 1, September 30, 1999. 

USDA Forest Service. 2000. Geographic Area Assessment Black Kettle and McClellan Creek 

National Grasslands, Cibola National Forest. Version 1, August 14, 2000. 

USDA. 2008. Ecological Sustainability Report – Kiowa, Rita Blanca, Black Kettle, and 

McClellan Creek National Grasslands. USDA Forest Service, Southwestern Region, 

Albuquerque, NM. 

USDA. 2010. Southwest Region Climate Change Trends and Forest Planning. USDA Forest 

Service, Southwestern Region, Albuquerque, NM 
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USEPA (Environmental Protection Agency). 1990. US EPA AirData Facility Emissions Report – 

Criteria Air Pollutants. http://epa.gov/airsdata/ Accessed June 12, 2006. 

USEPA (Environmental Protection Agency).. 1999. US EPA AirData Facility Emissions Report 

– Criteria Air Pollutants. http:// epa.gov/airsdata/ Accessed June 12, 2006. 

USEPA. 2008. National Emissions Inventory Data. 

http://www.epa.gov/ttn/chief/net/2008inventory.html Accessed May, 26, 2011. 

 USEPA (Environmental Protection Agency). 2010a. National Ambient Air Quality Standards. 

http://www.epa.gov/air/criteria.html. Accessed December 12, 2010. 

USEPA (Environmental Protection Agency). 2010b. Air Regulations: State Implementation Plans. 

http://yosemite.epa.gov/r6/Sip0304.nsf/home?Openview. Accessed on December 4, 2010. 

VISTAS. 2005. Visibility Improvement State and Tribal Association of the Southeast (VISTAS) 

Database. Data last updated 9/9/2005.