Hi-Grouse Project

Air Quality Report

Prepared by: Lois J Pfeffer

Environmental Coordinator 

Reviewed by: Michael Powell

Fire Management Officer

for: 

Goosenest Ranger District

Klamath National Forest

November 9, 2009 
Hi-Grouse Project Air Quality Report

The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and 

activities on the basis of race, color, national origin, age, disability, and where applicable, sex, 

marital status, familial status, parental status, religion, sexual orientation, genetic information, 

political beliefs, reprisal, or because all or part of an individual's income is derived from any public 

assistance program. (Not all prohibited bases apply to all programs.) Persons with disabilities 

who require alternative means for communication of program information (Braille, large print, 

audiotape, etc.) should contact USDA's TARGET Center at (202) 720-2600 (voice and TDD). To 

file a complaint of discrimination, write to USDA, Director, Office of Civil Rights, 1400 

Independence Avenue, S.W., Washington, D.C. 20250-9410, or call (800) 795-3272 (voice) or 

(202) 720-6382 (TDD). USDA is an equal opportunity provider and employer.
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Table of Contents 

Summary ......................................................................................................................................... ii

Air Quality ....................................................................................................................................... 3

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

Introduction ............................................................................................................................. 3

Air Quality Regulatory Framework ......................................................................................... 4

Existing Conditions ............................................................................................................... 17

Environmental Consequences ................................................................................................... 22

Alternatives ........................................................................................................................... 22

Acronyms .............................................................................................................................. 30

Appendix A: Forest Carbon ..................................................................................................... 31

References ................................................................................................................................. 33

Table of Tables

Table 1-National and California Ambient Air Quality Standards ................................................... 5

Table 2-2008 Estimated Daily (from Annual Average) Emissions for Siskiyou County (tons/day)

 ............................................................................................................................................... 17

Table 3 Emission Production from Equipment used for Timber Sale under Alt 2 ........................ 23

Table 4 Emission Production from Equipment used for Timber Sale under Alt 3 ........................ 24

Table 5 Emission Production from Equipment used for Timber Sale under Alt 4 ........................ 24

Table - 6 Emissions (in tons) from burning activities ................................................................... 25

Table of Figures 

Figure 1-California Air Basins ........................................................................................................ 3

Figure 3- Area Designations for State Ambient Air Quality Standards PM10 ............................. 10

Figure 4-Area Designations for National Ambient Air Quality Standards PM2.5 

PM2.5 (24hr) Non-Attainment area by Federal Standards .................................................... 11

Figure 5- Area Designations for State Ambient Air Quality Standards PM2.5 

PM2.5 (24 hr) Non-Attainment areas by State Standards ..................................................... 12

Figure 6-Area Designations for National Ambient Air Quality Standards 8-Hour Ozone Standard 

(Federal) ................................................................................................................................ 13

Figure 7-Area Designations for State Ambient Air Quality Standards Ozone 

One-hour Ozone Standard (State) ......................................................................................... 14

Figure 8-Analysis data for best and worst visibility days, 2001-2004 .......................................... 21
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Summary

Air quality is managed through a complex series of federal, state, and local laws and 

regulations designed to assure compliance with the Clean Air Act. The Hi-Grouse project 

is located within the Northeast Plateau Air Basin. The Northeast Plateau Air Basin is 

comprised of three counties, Siskiyou, Modoc and Lassen. Within Siskiyou County, the 

air quality regulating authority is the Siskiyou County Air Pollution Control District, 

(SCAPCD) in Yreka, California. 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.

This project can be divided into two phases in terms of air quality impacts. First phase 

will be the timber sale that will take three to five years for completion involving 

mechanized equipment and hauling. The second phase includes prescribed fires (understory and pile burns) that will also be spread over five to ten years following harvest 

activities. 

The improved wildfire suppression characteristics created by prescribed burning and 

thinning under the action alternatives should lead to a reduction in size and intensity of 

wildfires in the treated areas. In the long term, the emissions from wildfires are expected 

to be reduced as a result of reduced fuel loading. Overall cumulative emissions are 

expected to be similar to the past years and are not expected to exceed Federal or State air 

quality standards. 
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Air Quality 

Affected Environment 

Introduction

Air quality is managed through a complex series of federal, state, and local laws and 

regulations designed to assure compliance with the Clean Air Act. A summary of the 

regulations that apply to the Hi-Grouse project are provided under the heading Air 

Quality Regulatory Framework. 

This project can be divided into two phases in terms of air quality impacts. First phase 

will be the timber sale that will take three to five years for completion followed by 

prescribed fires phase (under-story and pile burns) that will also be spread over five to ten

years. The pollutants that will be released are the criteria pollutants i.e. PM10, PM2.5, 

Carbon Monoxide (CO), Nitrogen Oxides (NOx), Volatile Organic Carbons (VOCs) and 

minute quantities of non-criteria air toxics. These pollutants and air toxics are considered 

unhealthy for the public. In addition, Green House Gases like Carbon Dioxide (CO2) and 

Methane (CH4) are also emitted. These gases are known to impact climate change.

For air quality 

management, 

California is divided 

into fifteen air basins 

whose boundaries are 

based on geographical 

and meteorological 

considerations and 

follow political 

boundaries to the 

extent practicable 

(See Figure 1).

The Hi-Grouse 

project area falls

within Siskiyou 

County in the 

Northeast Plateau Air 

Basin and is managed 

by the Siskiyou 

County Air Quality 

Management District 

(SCAQMD). 

Figure 1-California Air 

Basins
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Within Siskiyou County, the air quality regulating authority is the Siskiyou County Air 

Pollution Control District, (SCAPCD) in Yreka, California. 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. Under the authority of 

the California Code of Regulations Title 17, Subchapter 2, Smoke Management 

Guidelines for Agricultural and Prescribed Burning, the SCAPCD issues permits for 

agricultural and forested lands prescribed burning. It also issues rules and regulations, 

which set specific standards and guides of burn and no burn days, defines permit 

requirements, issues permits, and sets emission limits.

The project vicinity is forested federally managed lands with no substantial emission 

sources other than fugitive dust from logging and recreation. Other contributions would 

be smoke and haze from seasonal wildland and prescribed fires from both within and 

outside the basin. The area is located approximately 15 miles southeast of Macdoel, 

California in Siskiyou County. The project vicinity is primarily forested federal lands.

Air Quality Regulatory Framework

This section presents the air quality regulatory framework and existing air quality 

conditions applicable to the project area. 

Regulatory Agencies and Applicable Regulations

In California air quality is managed at three levels of government via federal, state, and 

local levels described below: 

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. EPA established National Ambient Air Quality Standards 

(NAAQS). The air quality rules and regulations for the EPA and the standards for these 

pollutants can be found at http://www.epa.gov/. 

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, while retaining the authority for mobile 

sources. The Districts have the primary responsibility for meeting the requirements of the 

Clean Air Act. This responsibility is carried out through the development and execution 

of implementation plans (e.g., burn plans), which must provide for the attainment and 

maintenance of air quality standards (e.g., smoke management plans). Air quality rules 

and regulations for California can be found at http://www.arb.ca.gov/homepage.htm. 

Counties within the Northeast Plateau Air Basin that exceed the standards for any of the 

six pollutants at the state level are classified as being in “non-attainment” for that 

pollutant. Air quality plans for mitigation of accedence’s for these pollutants are required 

to be filed with the county air pollution district. Currently Siskiyou County is in 

attainment for all federal and state standards for ambient air quality. Areas where 

particulate matter has exceeded state standards have been in the communities of Alturas 

and Yreka where monitoring stations are located and where there are industries and 

problems with residential wood smoke. There have only been a few instances when 
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smoke from prescribed fire or wildfires have exceeded standards in the Yreka, Mount 

Shasta, Marble Mountain Wilderness, and Lava Beds National Park vicinity. 

The SCAPCD also enforces the California Health and Safety Code Section 41700, the 

public nuisance statute. This rule protects the public health and welfare from emission of 

air contaminants such as smoke and dust, which constitute a nuisance, defined as injury, 

detriment, or annoyance to a considerable number of persons, the public or private 

property owners. at http://www.ncuaqmd.org/ 

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 agencies activities are summarized below:

a. Clean Air Act Amendment 1970 

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

primary Ambient Air Quality Standards to protect human health and secondary standards 

to protect welfare. The EPA Office of Air Quality Planning and Standards (OAQPS) has 

set NAAQS for the following six principal pollutants, which are called "criteria" 

pollutants: 

• Particulate Matter (PM10, 

PM2.5) 

• Ozone (O3) 

• Sulfur Dioxide (SO2) 

• Nitrogen Dioxide (NO2) 

• Carbon Monoxide (CO) 

• Lead (Pb) 

On July 16, 1997 the EPA revised Ozone 1 hour and PM10 standards. The revised ozone 

8 hour standard and PM2.5 standards (annual and 24 hour average) were announced. On 

December 18, 2006 the EPA again revised the PM2.5 (24 hour standard) by making it 

more stringent from 65 to 35 micrograms per meter cube. On March 12, 2008, the EPA 

issued a revised ozone standard. The new primary 8-hour standard is 0.075 parts per 

million (ppm) and the new secondary standard is set at a form and level identical to the 

primary standard (not shown in the table).

The primary EPA standards for these pollutants are shown in Table 1, along with the 

California standards. If federal standards are violated in any area that area is designated 

as “non-attainment” for that pollutant, and the state must develop a plan for bringing that 

area back into “attainment”. Units of measure for the standards are micrograms per cubic 

meter of air (μg/m3

Table 1-National and California Ambient Air Quality Standards

) and ppm by volume 

National and State Ambient Air Quality Standards in μg /m3* (ppm)

 Primary Standards

Pollutant Averaging Time Federal State 

PM10 Annual -- 20

24 hours 150 50

PM 2.5 Annual 15 12

24 hour (12/18/2008) 35 35
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National and State Ambient Air Quality Standards in μg /m3* (ppm)

 Primary Standards

Pollutant Averaging Time Federal State 

NO2 Annual 100 (0.053) 56 (0.03)

1 hour -- 338 (0.18)

CO 8 hours 10,000 (9.0) 10,000 (9.0)

1 hour 40,000 (35) 23,000 (20)

SO2 Annual 80 (0.03) --

24 hours 365 (0.14) 105 (0.04)

3 hours -- --

1 hour None 655 (0.25

O3 1 hour -- 180 (0.09)

8 hour 157 (0.08) 137 (0.07)

Pb Calendar Average 1.5 None

30-day Average None 1.5

*Annual standards are never to be exceeded. Other standards are not to be exceeded more than once a year.

*8hr ozone standard not to be exceeded three year average of the fourth highest 8-hour average ozone value --

b. Clean Air Act Amendment 1977 

1. Prevention of Significant Deterioration (PSD) and Air Quality Related Values (AQRVs) 

for Class I Areas

The 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 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.

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

responsibility” to protect the 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, 

p36) and include visibility. AQRVs are defined as feature or properties or properties of 

Class I area that can be changed by air pollution. (In R5, the AQRVs, beside visibility 

include flora, water, soil, cultural and archaeological values and odor). 

2. Regional Haze:

Under Regional Haze Rule, released by the EPA, each state is required to develop 

visibility State Implementation Plan (SIP) for Class I areas by December 31, 2007. The 

California Regional Haze Plan was adopted January 22, 2009. 

c. Clean Air Act Amendment 1990

i. Conformity 

Under the Clean Air Act Amendment (1990), the EPA published conformity regulations 

for non-attainment areas in the Federal Register on November 30, 1993. The conformity 
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provisions of the Clean Air Act Section 176(c) prohibit federal agencies from taking any 

action that:

• 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 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.

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

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

EPA). The new rules exempt the prescribed burn projects from conformity determination 

if burns are conducted under an approved Smoke Management Program (SMP). The 

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 R5 Conformity handbook (September, 2005). 

ii. Reasonably Available Control Measures (RACMs) and Best Available Control Measures 

(BACMs)

Section 190 of the Clean Air Act required the EPA to issue technical guidance on RACMs 

and BACMs for prescribed fires. RACMs and BACMs can be used as mitigation 

measures. Some examples of the mitigation measures include annual plans, emission 

inventory system, implementation of emission reduction techniques, monitoring, 

surveillance, and enforcement programs, local and state regulatory oversight, and public 

education /awareness programs etc. BACMs are required measures for non-attainment 

areas.

iii. Interim Air Quality Policy

On May 15, 1998, the EPA issued “Interim Air Quality Policy on Wildland and 

prescribed Fires” in response to anticipated increases in fire use that were expected to 

occur as a result of implementing the 1995 Fire Management and Policy Review , which 

outlined a need to restore fire as an ecosystem process. The interim policy was prepared 

in an effort to integrate the goals of allowing fire to function in an ecological role, for 

maintaining healthy ecosystem balanced while protecting public health and welfare, by 

mitigating the impacts of air pollutant emissions on air quality and visibility.

The policy encourages coordination between burners and regulators. It encourages states 

and tribes to develop smoke management programs (SMP) for prescribed burns. Under 

this policy provisions the EPA will ignore a violation occurred under a certified SMP and 

will not designate the area non-attainment. California has revised Title 17 in accordance 

with Interim policy requirements and the EPA has certified it as a SMP.

iv. Western Regional Air Partnership (WRAP)

WRAP was formed in 1996 to implement the Grand Canyon Commission’s 

recommendations. The commission was established in response to Clean Air Act 
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Amendments of 1990 to improve visibility in Class I areas. The commission listed smoke 

from wildland fires and Agricultural burns as one of the source contributing to visibility 

degradation. The interim policy listed seven elements to be considered by the states in the 

development of smoke management programs. (Fire Emission Joint Forum Page 6 of 30) 

(FEJF) under WRAP developed two documents called “Basic Smoke Management 

Program (BSMP)” elements and “Enhanced Smoke Management Program 

(ESMPs)”elements. BSMP consists of seven elements whereas ESMP consists of nine i.e. 

two more (interstate coordination and authorization) than BSMP. 

v. Exceptional Event Rule

On March 10, 2006 the EPA released rules pertaining to “The Treatment of the Data 

Influenced by Exceptional Events”. The “wildfire” and “wildfire use” is considered as an 

exceptional event. The EPA has proposed to implement section 319(b)(3)(B) and section 

107(d)(3) authority to exclude air quality monitoring data from regulatory determination 

to exceedances or violation of NAAQS and avoid designating an area as a nonattainment. 

Also, the EPA has proposed four options with respect to whether, and to what extent, 

states should be required to take additional actions to address public health impacts 

related to the event.

vi. Hazardous Air Pollutants (HAPs)

The 1990 amendments to the Clean Air Act include a list of 189 pollutants identified as 

hazardous to human health. These pollutants are known to or have the potential to cause 

cancer, cause mutation, be toxic to nervous tissue, or cause reproductive dysfunction. 

2. 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 

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. Figures 2, 3, 4, 

5, 6 and 7 show the designated areas for federal and state standards for PM10/PM2.5 and 

ozone. California has also established ambient air quality standards for sulfate, hydrogen 

sulfide, vinyl chloride, and visibility reducing particles. The conformity rules apply to 

federal actions for federal standards only.

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 sources. However, authority to regulate stationary sources has been delegated to 

air pollution control and air quality management districts at the county and regional 

levels. The state still has oversight authority to monitor the performance of district 

programs and can even assume authority to conduct district functions if the district fails 

to meet certain responsibilities. 
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Figure 2-Area Designations for National Ambient Air Quality Standards PM10
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Figure 3- Area Designations for State Ambient Air Quality Standards PM10
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Figure 4-Area Designations for National Ambient Air Quality Standards PM2.5 

PM2.5 (24hr) Non-Attainment area by Federal Standards
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Figure 5- Area Designations for State Ambient Air Quality Standards PM2.5 

PM2.5 (24 hr) Non-Attainment areas by State Standards
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Figure 6-Area Designations for National Ambient Air Quality Standards 8-Hour Ozone Standard 

(Federal)
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Figure 7-Area Designations for State Ambient Air Quality Standards Ozone 

One-hour Ozone Standard (State)

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 
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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 is required to comply with all of the requirements of a SIP, once it is 

approved by the EPA. 

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 SMP that 

collectively was certified by the EPA as a state SMP. Under the guidelines a burn plan is 

developed by a burner to get a burn permit from the local APCD/AQMD. Authorization 

is received from the regulator on the day of burn declared by the CARB as a “burn day”. 

BSMP elements are included in the Guidelines. Details about Title 17 can be downloaded 

from the site; “http://www.arb.ca.gov/smp/regs/regs.htm

D. Assembly Bill 32 ---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 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. AB 32 

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. 
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• Allow for coordination with other states and countries. 

Region 5 of the Forest Service has joined the California Climate Action Registry to 

reduce the agency’s environmental footprints. 

3. 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. As an 

example, according to South Coast the common mandates for the APCDs/AQMDs to 

follow are:

• Demonstrate the overall effectiveness of the air quality program

• Reduce non-attainment pollutants at a rate of five percent per year, or include all 

feasible measures and an expeditious adoption schedule 

• Ensure no net increase in emissions from new or modified stationary sources

• Reduce population exposure to severe non-attainment pollutants according to a 

prescribed schedule 

• Include any other feasible controls that can be implemented, or for which

implementation can begin, within 10 years of adoption of the most recent air quality 

plan 

• Rank control measures by cost-effectiveness

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) in Yreka, California. 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. Under the authority of 

the California Code of Regulations Title 17, Subchapter 2, Smoke Management 

Guidelines for Agricultural and Prescribed Burning, the SCAPCD issues permits for 

agricultural and forested lands prescribed burning. It also issues rules and regulations, 

which set specific standards and guides of burn and no burn days, defines permit 

requirements, issues permits, and sets emission limits. 

Counties within the Northeast Plateau Air Basin that exceed the standards for any of the 

six pollutants at the state level are classified as being in “non-attainment” for that 

pollutant. Air quality plans for mitigation of exceeding these pollutants are required to be 

filed with the county air pollution district. Currently Siskiyou County is in attainment for 

all federal and state standards for ambient air quality. Areas where particulate matter has 

exceeded state standards have been in the communities of Alturas and Yreka where 

monitoring stations are located and where there are industries and problems with 

residential wood smoke. There have only been a few instances when smoke from 

prescribed fire or wildfires have exceeded standards in the Yreka, Mount Shasta, Marble 

Mountain Wilderness, and Lava Beds National Park vicinity. 

The SCAPCD also enforces the California Health and Safety Code Section 41700, the 

public nuisance statute. This rule protects the public health and welfare from emission of 
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air contaminants such as smoke and dust, which constitute a nuisance, defined as injury, 

detriment, or annoyance to a considerable number of persons, the public or private 

property owners. 

Existing Conditions

Project Location and Existing Air Quality

The Hi-Grouse project area is located approximately 15 miles southeast of Macdoel, 

California which is located in Siskiyou County. Siskiyou County is a large remote county 

located in Northeastern California. The geography is rugged with heavily forested 

mountains. The project vicinity is primarily forested federal lands. The project lies in the 

Northeast Plateau Air Basin and is managed by the Siskiyou County Air Quality 

Management District (SCAQMD). Table 2 displays information from the SCAQMD. 

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 for PM10 and PM2.5 for federal standards (See figures

2 and 4). Therefore the project is exempt from conformity determination. For state 

PM10/PM2.5 standards Siskiyou County is designated as “attainment” area for PM.10

and “unclassified” for PM2.5. 

In Siskiyou County, PM10 generally comes from motor vehicles, wood burning stoves, 

dust from construction and logging operations, wildfires and slash burning. Siskiyou 

County is in “non-attainment” status for ozone, a product of volatile organic compounds 

or nitrogen oxides; and is considered “unclassified” for CO. 

Table 2-2008 Estimated Daily (from Annual Average) Emissions for Siskiyou County (tons/day)

Source Type TOG ROG CO NOX SOX PM PM10 PM2.5 

STATIONARY SOURCES

Fuel Combustion

Manufacturing and Industrial 0.17 0.07 0.42 0.08 - 0.24 0.24 0.23

Food and Agricultural Processing 0.08 0.05 0.21 0 .57 0.00 0.03 0.02 0.02

Other (Fuel Combustion) 0.00 0.00 0.01 0.02 - 0.00 0.00 0.00

* Total Fuel Combustion 0.25 0.12 0.64 0.67 0.00 0.27 0.27 0.25

Waste Disposal

Other Waste Disposal 0.00 0.00 0.01 0.00 - 0.00 0.00 0.00

*Total Waste Disposal 0.00 0.00 0.01 0.00 - 0.00 0.00 0.00

Cleaning and Surface Coatings

Laundering 0.00 0.00 - - - - - -

Degreasing 0.11 0.10 - - - - - -

Coatings and Related Process 

Solvents 

0.06 0.06 - - - - - - 

Adhesives and Sealants 0.02 0.01 - - - - - -

*Total Cleaning and Surface 

Coatings

0.19 0.17 - - - - - - 

Petroleum Production and Marketing

Petroleum Marketing 0.33 0.32 - - - - - -

*Total Petroleum Production and 

Marketing

0.33 0.32 - - - - - - 

Industrial Processes

Food and Agriculture - - - - - - - -

Mineral Processes - - - - - 0.27 0.14 0.03

Wood and Paper 0.17 0.16 - - - 0.31 0.21 0.13
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Source Type TOG ROG CO NOX SOX PM PM10 PM2.5 

* Total Industry Processes 0.17 0.16 - - - 0.58 0.35 0.16

** Total Stationary Sources 0.93 0.78 0.65 0.67 0.00 .86 0.62 0.41

AREA WIDE SOURCES

Solvent Evaporation

Consumer Products 0.35 0.29 - - - - - -

Architectural Coatings and 

Related Process 

Solvents 0.17 0.16 - - - - - -

Pesticides/Fertilizers 0.54 0.54 - - - - - -

Asphalt Paving/Roofing 1.89 1.89 - - - - - -

* Total Solvent Evaporation 2.95 2.89 - - - - - -

Miscellaneous Processes

Residential Fuel Combustion 3.37 1.48 20.34 0.38 0.20 3.39 3.17 3.05

Farming Operations 15.08 1.21 - - - 2.38 1.08 0.16

Construction and Demolition - - - - - 0.52 0.25 0.03

Paved Road Dust - - - - - 4.40 2.01 0.30

Unpaved Road Dust - - - - - 20.03 11.90 1.19

Fugitive Windblown Dust - - - - - 0.68 0.35 0.05

Fires 0.00 0.00 0.00 - - 0.00 0.00 0.00

Managed Burning and Disposal 12.60 7.18 198.22 - - 13.53 13.04 11.71

Cooking 0.02 0.01 - - - 0.05 0.03 0.02

* Total Miscellaneous Processes 31.07 9.88 218.56 0.38 0.20 44.97 31.85 16.52

** Total Area Wide Sources 34.02 12.77 218.56 0.38 0.20 44.97 31.85 16.52

MOBILE SOURCES

On-Road Motor Vehicles

Light Duty Passenger (LDA) 0.60 0.56 4.84 0.44 0.00 0.02 0.02 0.01

Light Duty Trucks - 1 (LDT1) 0.94 0.88 8.68 0.78 0.00 0.02 0.02 0.01

Light Duty Trucks - 2 (LDT2) 0.42 0.39 3.81 0 .47 0.00 0.02 0.02 0.01

Medium Duty Trucks (MDV) 0.15 0.14 1.54 0.21 0.00 0.01 0.01 0.01

Light Heavy Duty Gas Trucks - 1 

(LHDV1) 

0.06 0.06 0.46 0.06 0.00 0.00 0.00 0.00

Light Heavy Duty Gas Trucks - 2 

(LHDV2) 

0.06 0.06 0.41 0.03 0.00 0.00 0.00 0.00

Medium Heavy Duty Gas Trucks 

(MHDV) 

0.23 0.21 1.41 0.06 - 0.00 0.00 0.00

Heavy Heavy Duty Gas Trucks 

(HHDV) 

0.09 0.09 1.20 0.07 - 0.00 0.00 -

Light Heavy Duty Diesel Trucks -

1 (LHDV1) 

0.01 0.01 0.03 0.15 0.00 0.00 0.00 0.00

Light Heavy Duty Diesel Trucks -

2 (LHDV2) 

0.01 0.00 0.02 0.10 0.00 0.00 0.00 0.00

Medium Heavy Duty Diesel 

Trucks (MHDV) 

0.01 0.01 0.05 0.22 0.00 0.01 0.01 0.01

Heavy Heavy Duty Diesel Trucks 

(HHDV)

0.78 0.68 2.81 10.06 0.01 0.40 0.40 0.35

Motorcycles (MCY) 0.08 0.08 0.57 0.02 - 0.00 0.00 0.00

Heavy Duty Diesel Urban Buses 

(UB) 

0.00 0.00 0.00 0.03 - 0.00 0.00 0.00

Heavy Duty Gas Urban Buses 

(UB) 

- - 0.00 0.00 - - - -

School Buses (SB) 0.01 0.01 0.15 0.05 - 0.00 0.00 0.00

Other Buses (OB) 0.01 0.01 0.10 0.02 - 0.00 0.00 0.00

Motor Homes (MH) 0.02 0.02 0.41 0.05 0.00 0.00 0.00 0.00

* Total On-Road Motor Vehicles 3.47 3.20 26.49 12.81 0.02 0.49 0.49 0.41

Other Mobile Sources

Aircraft 0.00 0.00 0.01 0.00 - - - -

Trains 0.22 0.18 0.60 2.77 0.02 0.08 0.08 0.08

Recreational Boats 0.21 0.20 0.39 0.02 - 0.02 0.02 0.01

Off-Road Recreational Vehicles 1.57 1.45 4.73 0.05 0.00 0.04 0.04 0.03

Off-Road Equipment 0.43 0.39 3.19 0.94 0.00 0.06 0.06 0.05
Hi-Grouse Project Air Quality Report

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Source Type TOG ROG CO NOX SOX PM PM10 PM2.5 

Farm Equipment 0.22 0.19 1.17 0.99 0.00 0.06 0.06 0.05

Fuel Storage and Handling 0.03 0.03 - - - - - -

Total Other Mobile Sources 2.69 2.44 10.09 4.76 0.02 0.26 0.26 0.23

Total Mobile Sources 6.16 5.63 36.59 17.57 0.04 0.75 0.74 0.63

NATURAL NON--ANTHROPOGENIC SOURCES

Biogenic Sources 166.84 158.82 - - - - - -

Wildfires 12.43 7.58 113.00 4.06 1.25 12.28 11.80 10.02

Total Natural Sources (NonAnthropogenic Sources)179.27 166.40 113.00 4.06 1.25 12.28 11.80 10.02

GRAND TOTAL SISKIYOU 

COUNTY IN NORTHEAST 

PLATEAU 

220.38 185.58 368.80 22.68 1.50 58.86 45.01 27.58

Data (published in 2009) http://www.arb.ca.gov/app/emsinv/emseic1_query.php 

The SCAQMD is required to develop and implement an air quality attainment plan with 

the goal of achieving and maintaining compliance with air quality standards. Specific 

output tables for Siskiyou County are available through the CARB website. Table 2 

shows estimated (from annual averages) daily emissions for Siskiyou County in tons per 

day by source category. Table 2 also shows that in Siskiyou County biogenic sources are 

the biggest contributors to the production of TOGs and ROGs. Wildfires and prescribed 

burns contribute the most to CO, particulates (PM10 and PM2.5) and NOx. Mobile 

sources emit TOGs, ROGs, CO and NOx.

According to the Klamath National Forest Land and Resource Management Plan (LRMP) 

(USDA Forest Service 1995, pg 3-4), air quality on the Forest has been considered very 

good, and complies with all NAAQS standards set by the EPA. 

B. Climate

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 45o

Wind patterns fluctuate on a diurnal and seasonal basis. During summer months winds 

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

The pattern of up slope to up canyon winds during the day and down slope, down canyon 

winds at night account for the pollution transport between the Sacramento Valley and the 

foothills and mountains. Thus smoke produced from wildland or prescribed fires would 

tend to enter the valley during night and vent out by day. Winter months are often 

correlated with reduced venting during daytime hours. Atmospheric inversions can lead 

to situations of pollutants trapped in the lower elevations. Wood-burning stoves are a 

primary contributor to this situation.

F. Wind speeds range from 0 to 5 miles 

per hour on average with gusts to 10 and 20 miles per hour. The range of elevation within 

the project area is 5,400 to 6,500 feet.

C. Green House Gases (GHGs) 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 
Hi-Grouse Project Air Quality Report

20

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.

The primary anthropogenic greenhouse gases are:

• Carbon dioxide CO2, 

• Methane (CH4),

• Nitrous oxides (N2O), and 

• Halocarbons.—CFC11,CFC12, CFC 13 

A biogenic substance is a substance produced by life processes. It may be either 

constituents, or secretions, of plants or animals. 

The atmospheric concentration of CO2 has increased from a pre-industrial value of about 

280 parts per million (ppm) to 379 ppm in 2005, which is an increase of about 35 percent. 

During the last 10 years, the rate of increase of CO2 since 1980 was about 1.9 ppm 

(0.5%) per year. Most of the anthropogenic CO2 emissions are primarily attributed to 

fossil fuel burning, with land-use changes, especially deforestation, providing another 

significant contribution (Intergovernmental Panel on Climate Change [IPCC], 2007). The 

level of CO2 in the atmosphere is determined by a complex cycle that involves the 

exchange of carbon between the atmosphere, the biosphere and the oceans. It is estimated 

that the oceans and terrestrial biota absorb about half of all CO2 emissions, while the rest 

accumulates in the atmosphere (IPCC, 2001a). 

“..There are two aspects of global climate change that needs consideration:

(1) The potential for actions to influence global climatic change (increased emissions or 

sinks of greenhouse gases) and 

(2) The potential for global climatic change to affect actions.

i.e. to what extent the project activities (both continuing and proposed) contribute, 

directly or indirectly, to the emission of greenhouse gases and thus to global climate 

change and to what extent the activities will be affected by the consequences of climate 

change.

D. Class l Wilderness Areas

The nearest Class I Area is the Lava Bed National Monument approximately 10 airmiles 

northeast of the project. The Marble Mountain Wilderness, another Class I airshed, is 

located approximately 65 miles west of the project area. The Trinity Alps Wilderness (a 

Class II Wilderness Area) is located approximately 75 miles southeast of the project area. 

The rest of the Forest, including the other Wilderness areas are identified as Class II areas 

which have less stringent requirements (USDA Forest Service 1995). 

The EPA and CARB approved IMPROVE (Interagency Monitoring of Protected Visual 

Environment). A IMPROVE site managed by the forest service is located near Trinity 

helipad base. The collected samples are analyzed for PM10, PM2.5, SO4, NO3, Organic 

Carbon, Elemental carbon, dust and soot. The data will help identify sources that generate 
Hi-Grouse Project Air Quality Report

21

pollutants for visibility degradation. The data will be used in the development of the 

visibility SIP by the state and then showing progress towards achieving visibility goals.

Trinity monitoring station is located at clear-cut area on ridgeline at 1014 meters 

(approximate top of Central Valley inversion layer). The area is forested with no 

significant anthropogenic sources nearby, except helipad about 5 miles from recreational 

lake.

Transport of aerosols probably occurs from north along Willamette Valley and Pacific, 

east from Northeast Plateau, southeast from Sacramento Valley. Route 299 corridor along 

Trinity-Klamath Rivers allows oceanic-interior transport. 

According to CARB (2008), long-range Sulfate transport is substantial. Out-of-state 

contributions to total sulfate concentration on worst days is almost 6 times that from 

California and approximately 5 times California’s on best days. 

Analysis of data 2001 to 2004 for worst and best visibility days are shown in the figure 

below as a pie chart. Deciview or total extinction rises slightly in warmer months, but, 

worst days occur as spikes throughout the year. Organic matter carbon (OMC) is the 

overwhelming cause of worst haze days followed by sulfate and nitrate. Average Sulfate 

concentration on worst days is twice that of best days. The ammonium sulfate particles 

are very efficient at scattering light and visibility impairment. Nitrate is occasional cause 

of a winter haze day. Coarse mass and fine soils contribute extremely small amounts to 

total extinction.

Figure 8-Analysis data for best and worst visibility days, 2001-2004

Most improvement is expected from nitrate reductions from mobile sources as CARB 

regulations are implemented. Some improvements may occur from residential wood 

smoke curtailment in localized areas and application of emission reduction techniques 

(ERTs) to prescribed burns. Smoldering emissions can cause big problems near a 

highway. During night, smoldering emissions can follow drainages and can accumulate in 

low lying areas or communities. Biomass removal and timber harvest reduce forest fuel 

loading. This can result in less intense wildfires and reduced OMC contribution to worst 
Hi-Grouse Project Air Quality Report

22

visibility days. Marine shipping and other long-range transport sources affect SOx 

contributions but are “uncontrollable” by California.

Under air quality regulations prescribed burning is usually considered a temporary, 

intermittent source of air pollution and therefore is not subject to the same visibility 

requirements as a major PSD source. Besides causing visibility impairment, smoke can 

also create a nuisance and generate numerous complaints from the public. Burns are 

allowed only on declared “Burn days.” Burn-day determination is based on metrological 

conditions that tend to disperse the smoke. The burning on worst visibility days and best 

visibility days would be avoided. The burns will be conducted when the prevailing wind 

direction is away from Class I area. Public education and information release are part of 

the prescribed burning procedures and will be followed. The forest will follow North 

Coast AQMD’s SMP in order to avoid creating a nuisance, visibility impairment or 

impacts to public health.

Environmental Consequences 

Alternatives

Alternative 1 No Action

Direct and Indirect Effects of the No Action Alternative

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

emission contribution for air quality degradation. This will lead to increased 

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

If a wildfire were to occur, the potential indirect effects include degraded air quality and 

reduced visibility. Consumption of the increased fuel loads and understory biomass 

would increase the amount of smoke emissions. These emissions would also occur over 

a period of a few days to several weeks as opposed to intermittent days over several years 

for prescribed fire units. 

Cumulative Effects of the No Action Alternative

The cumulative affects area is considered to be the project area. Past, present, and 

reasonably foreseeable activities were reviewed to determine cumulative effects to air 

quality. There has been pile burning over the past ten years within the project area. 

Compliance with burn day designations and permits from the Siskiyou County Air 

Quality Management District has minimized the effects of burning so that Federal and 

State air quality standards have not been exceeded. Because impacts to air quality in 

regards to smoke from past wildfires and prescribed fire activities are short-lived, past 

activities do not contribute to cumulative effects. Past activities do influence the amount 

of available material, which would be available for consumption in the event of a future 

wildfire.

Presently and within the future gaseous pollutants and airborne particulate matter would 

continue to be present. Primary emissions sources contributing would include wood 

burning stoves, motor vehicle exhaust, emissions from recreational campfires, emission 

associated with development of private lands, prescribed fire, fugitive dust, and wildfires 

within or adjacent to the project area. Thinning and fuels projects are currently being 
Hi-Grouse Project Air Quality Report

23

carried out within the county. The Little Doe/Low Gulch Timber Sale has been awarded 

and the Kelsey Peak Project is currently being planned. Burning associated with 

foreseeable actions, as well as adjacent agencies outside of the area can be expected, and 

would have short term effects. Other foreseeable actions within the analysis area are 

precommercial thinning in plantations. There has also been an un-estimated amount of 

burning on private lands within the county. 

Future wildfire frequency is expected to continue as it has been observed in the past. The 

effects from past prescribed and wildfires activities are no longer a concern because 

smoke impacts are short-term in nature and are only a concern while smoke is being 

produced and soon thereafter. However, if an unwanted wildfire occurs in the future these 

effects could lead to negative cumulative effects. These negative cumulative effects are 

dependant upon the size and intensity of the unwanted wildfire. Visibility impairment and 

hazardous health impacts, due to sudden and dramatic releases, are likely with a large 

unwanted wildfire event. These events may temporarily reduce visibility and air quality. 

These events lead to production of high amounts of GHGs and reduced carbon 

sequestration from the burnt area for next few years following the fires. The cumulative 

effects are unknown, because the intensity and size of a wildfire is unknown. Research 

has indicated that wildfires can produce nearly twice the amount of smoke as prescribed 

fire (General Technical Report PNW-GTR-355). 

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

burning into the designated late succession stands. Wildfires present a risk to the public 

and result in damage to both the environment (e.g., increased erosion, air quality 

degradation) and property. Wildfires are known to result in high levels of including 

GHGs and 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.

Alternatives 2, 3 and 4 (action alternatives)

Direct and Indirect Effects (Air Quality)

Forest air pollutant sources with the greatest impact are wildfire and prescribed burns. 

Other lesser pollutant sources are fugitive dust and vehicle exhaust emissions. Logging 

operations will produce some dust, primarily from tractor skidding of log bundles and 

hauling over earth surface roads. Dust from hauling will be minimized by requiring 

abatement with either water or an acceptable alternative. Logging operations are 

generally done over several years and localized dust from skidding and hauling dissipates 

rapidly. 

Vehicle exhaust emissions were estimated and displayed in Tables 3, 4 and 5 in tons 

expected from logging equipment, pickup trucks, water trucks, chipper engines and 

transport vehicles for alternatives 2, 3 and 4. Primary emissions generated from the 

mobile sources include emissions from engines during idle and operation mode. 

Table 3 Emission Production from Equipment used for Timber Sale under Alt 2

Activity Total Hours CO Nox VOCs PM10

Skidding and Yarding 43 0.077 0.027 0.004 0.003

Loading 3592 1.027 3.395 0.449 0.309
Hi-Grouse Project Air Quality Report

24

Hauling 33676 30.14 70.146 3.233 4.310

New road construction 12 0.0016 0.0055 0.0005 0.0005

Road Reconstruction 16 0.009 0.019 0.0011 0.0016

Road Maintenance 2 0.177 0.179 0.0166 0.0276

Post Sale Treatment 1629 0.282 1.026 0.0985 0.0912

Total for Alt 2 31.7 74.9 3.8 4.7

Alternative 4 generates higher amounts of CO, NOx, VOCs and PM10 than alternatives 

3. The emissions shown in the tables are over the life of timber sale. The timber sale is 

anticipated to last three to five years, therefore annual emissions will be 3 to 5 times less 

than shown in the tables. For comparison with Siskiyou County Daily Emissions (Table 

2) these emissions will have to be divided by 1095, to derive a daily emission estimates. 

The result will be 0.00 in every case. Therefore, the pollutants correlated with equipment 

emissions associated with this project are estimated to be almost negligible and 

insignificant.

Table 4 Emission Production from Equipment used for Timber Sale under Alt 3

Activity Total Hours CO Nox VOCs PM10

Skidding and Yarding 10 0.018 0.006 0.0009 0.0007

Loading 830 0.237 0.784 0.104 0.071

Hauling 7780 6.963 16.205 0.747 0.996

New road construction 12 0.002 0.0055 0.0005 0.0005

Road Reconstruction 10 0.005 0.0095 0.0006 0.0008

Road Maintenance 3 0.163 0.256 0.0153 0.0254

Post Sale Treatment (machine piling) 0 0 0 0 0

Total for Alt 3 7.39 17.27 0.87 1.09

Table 5 Emission Production from Equipment used for Timber Sale under Alt 4

Activity Total Hours CO Nox VOCs PM10

Skidding and Yarding 26 0.046 0.162 0.002 0.002

Loading 2126 0.608 2.009 0.266 0.183

Hauling 19933 17.840 41.52 1.914 2.551

New road construction 19 0.003 0.010 0.001 0.001

Road Reconstruction 10 0.005 0.011 0.001 0.001

Road Maintenance 2 0.171 0.268 0.016 0.027

Post Sale Treatment 1157 0.200 0.729 0.070 0.065

Total for Alt 4 18.9 44.6 2.3 2.8

Vegetation Combustion: The action alternatives would produce smoke from burning 

activities. Table - 6 shows emissions under alternative 2, 3 and 4. Smoke from the 

proposed project is expected to remain in the area for about one to two days each time 

burning occurs. Permissive burn days are determined by the Siskiyou County Air Quality 

Management District. The burning of slash piles, concentrations, and prescribed burning 

will produce smoke and ash from partially burned plant matter. This burning of organic 

matter will produce emission of particulates suspended in the atmosphere for one to 
Hi-Grouse Project Air Quality Report

25

several days. An estimated 1,190 tons (alt. 2); 3,446 tons (alt. 3); and 477 tons (alt.4) of 

particulate matter (PM10) would be produced from prescribed burning activities in the 

Hi-Grouse project area. These emissions would be spread out time with the scheduling of 

prescribed burn units. The tables also show emissions (in tons) of PM2.5, NOx, CO, 

CO2, CH4 and NMHC (non-methane hydrocarbons) from burning activities. 

NOx and VOCs (precursors of ozone) emissions are below the minimum even for nonattainment area under the action alternatives. In addition, the burns are generally 

conducted under low temperatures and high humidity (a situation not conducive for 

ozone formation). The project area is in attainment for all criteria pollutants for federal 

standards so no Conformity determination is required. 

Emissions estimates for burning were quantified through the First Order Fire Effects 

Model, version 5.0 (FOFEM). FOFEM is recognized by the Forest Service Pacific 

Southwest Region (R5) 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. Due to the use of whole tree yarding and biomass to remove tops of 

trees, minimal activity fuels would be created under any alternative. Machine and hand

pile units were considered for the estimated actual acres of burning. Wildfires burning on 

the same affected acres would result in the similar levels of emissions as noted for the 

acres burned under each of the action alternatives. 

Table - 6 Emissions (in tons) from burning activities 

Emissions (in tons) from prescribed burning under Alternatives, 2, 3 and 4 

Alternative Burn Acres PM10 PM2.5 NOx CO CO2 CH4 SO2

2 2405 1190 1415 21 13251 59482 607 49

3 1177 3446 341 10 3817 21003 176 15

4 1133 477 405 7 5337 21265 3817 20

Emissions reflect the total emissions for the alternatives. However, burn emissions would 

occur over three to five years under approved burn plans. Calculations were made 

assuming that hand pile burning will occur during the fall after significant moisture that 

prevents the spread of fire from the piles. Hand piles to be burned can be covered to keep 

them dry and reduce smoldering.

Based on the above information, estimated 24-hour emissions are very unlikely to exceed 

the 24-hour standard (California) for PM 10 and PM 2.5. Emissions at the project site 

(burn location) are not expected to exceed annual State or Federal standards, and would 

not degrade air quality or attainment status.

Under Title 17 burns must be authorized by the APCD/AQMD on the day of the burn. 

The California and Nevada Smoke and Air Consortium (CANSAC) has an MOU with the 

Desert Research Institute (DRI University of Nevada, Reno) to run MM5 and BlueSky 

models to predict smoke dispersion and PM2.5 concentrations from prescribed fires and 

wildfire. The model will help local regulators to avoid situations that can lead to NAAQS 

violation. The model is operational now but will be fully refined by the time the HiGrouse project is implemented.

The action alternatives will reduce the overall fuel loading on approximately 5,109 acres 

for alternative 2; 3,654 acres for alternative 3; and 3,955 acres for alternative 4, treated 
Hi-Grouse Project Air Quality Report

26

with various prescriptions. This will decrease the expected emissions from a wildland fire 

if it occurs in the project area.

Action Alternatives Cumulative Effects (Air Quality)

The cumulative affects area is considered to be the project area. Past, present, and 

reasonably foreseeable activities were reviewed to determine cumulative effects to air 

quality. There has been pile burning over the past ten years within the project area. 

Compliance with burn day designations and permits from the Siskiyou County Air 

Quality Management District has minimized the effects of burning so that Federal and 

State air quality standards have not been exceeded. Because impacts to air quality in 

regards to smoke from past wildfires and prescribed fire activities are short-lived, past 

activities do not contribute to cumulative effects. Past activities do influence the amount 

of available material, which would be available for consumption in the event of a future 

wildfire.

Presently and within the future gaseous pollutants and airborne particulate matter would 

continue to be present. Primary emissions sources contributing would include wood 

burning stoves, motor vehicle exhaust, emissions from recreational campfires, emission 

associated with development of private lands, prescribed fire, fugitive dust, and wildfires 

within or adjacent to the project area. Similar thinning and fuels projects are currently 

being carried out within the county. The Pumice Project is currently being planned. 

Burning associated with foreseeable actions, as well as adjacent agencies outside of the 

area can be expected, and would have short term effects. Other foreseeable actions within 

the analysis area are precommercial thinning in plantations. There has also been an unestimated amount of burning on private lands within the county. 

Proposed management activities under alternatives 2, 3 and 4 combined with past, 

present, and foreseeable activities noted above would contribute to the emissions that 

effect air quality. These alternatives and their impacts on air quality are difficult to 

address in terms of cumulative effects. Large fires have occurred near the project over 

the past century as described in the Fire/Fuels Analysis (Helmbrecht and Kurth 2009); 

however, those effects on air quality are gone and cannot be viewed cumulatively. If a 

wildfire occurred, there is a potential for the NAAQS to be exceeded depending on the 

size and duration of wildfire. 

It is acknowledged that multiple prescribed burn activities, occurring at the same time, 

could cumulatively increase particulate levels. Generally, 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 rather short-lived, because once the burn is over and the 

smoke has dissipated, the effect is over. However it is more likely that the current 

projects will be completed before the Hi-Grouse project treatments would be 

implemented.

The SCAQMD regulates permissible burn days for prescribed fire use within their 

district. A Smoke Management Plan (contained in all prescribed burn plans) must be 

submitted and approved by the SCAQMD prior to using prescribed fire on federal lands. 

Compliance with burn day designations and permits from the SCAQMD has minimized 

the effects so that Federal and State air quality standards have not been exceeded from 
Hi-Grouse Project Air Quality Report

27

past activities. Overall cumulative emissions are expected to be similar to the past years 

and are not expected to exceed Federal or State air quality standards.

The improved wildfire suppression characteristics created by these combined thinning 

and fuel treatment activities should lead to a reduction in size and intensity of wildfires in 

the treated areas. In the long term, the emissions from wildfires are expected to be 

reduced as a result of reduced fuel loading.

Future wildfire frequency is expected to continue as it has been observed in the past. The 

effects from past prescribed and wildfires activities are no longer a concern because 

smoke impacts are short-term in nature and are only a concern while smoke is being 

produced and soon thereafter. However, if an unwanted wildfire occurs in the future these 

effects could lead to negative cumulative effects. These negative cumulative effects are 

dependant upon the size and intensity of the unwanted wildfire. Visibility impairment and 

hazardous health impacts, due to sudden and dramatic releases, are likely with a large 

unwanted wildfire event. These events may temporarily reduce visibility and air quality. 

These events lead to production of high amounts of GHGs and reduced carbon 

sequestration from the burnt area for next few years following the fires. The cumulative 

effects are unknown, because the intensity and size of a wildfire is unknown. Research 

has indicated that wildfires can produce nearly twice the amount of smoke as prescribed 

fire (General Technical Report PNW-GTR-355). 

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

burning into the designated late succession stands. Wildfires present a risk to the public 

and result in damage to both the environment (e.g., increased erosion, air quality 

degradation) and property. Wildfires are known to result in high levels of including 

GHGs and 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.

The Hi-Grouse project fuels treatments will not occur until harvesting is completed, 

which could be four to six years from now. In that time the average number of acres of 

underburning should be about the same as the current ten year average.

The Siskiyou County Air Quality Management District regulates permissible burn days 

for prescribed fire use within their district. A Smoke Management Plan (contained in all 

prescribed burn plans) must be submitted and approved by the SCAQMD prior to using 

prescribed fire on federal lands. Overall cumulative emissions are expected to be similar 

to the past years and are not expected to exceed Federal or State air quality standards.

The improved wildfire suppression characteristics created by prescribed burning and 

thinning should lead to a reduction in size and intensity of wildfires in the treated areas. 

In the long term, the emissions from wildfires are expected to be reduced as a result of 

reduced fuel loading. Overall cumulative emissions are expected to be similar to the past 

years and are not expected to exceed Federal or State air quality standards.

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

and Plans 

All project activities including prescribed burning would be implemented in full 

compliance with the Siskiyou County Air Quality Management District (SCAQMD) and 
Hi-Grouse Project Air Quality Report

28

California Air Resource Board (CARB) air programs and the Klamath National Forest 

Land and Resource Management Plan Standards and Guides. The project complies with 

the Federal Clean Air Act.

Mitigation Measures (Air Quality)

Mitigations for PM10/ PM2.5 include: 

1) Reduce Fuels Loading - Pretreatment methods will be used to minimize smoke 

emissions and/or reduce fuel loadings, such as biomass removal, and public firewood 

utilization opportunities. 

2) Fuel Moisture Content - Burning when piles are dry increases the combustion 

efficiency and therefore reduces the emissions from the burn. The burn prescription shall 

specify an acceptable range of fuel moisture contents for the burn to proceed. Allow for 

adequate cure time before igniting slash material, and cover hand-piled slash where 

necessary for more efficient burning conditions. 

3) Smoke Management - A Smoke Management Plan (SMP)(contained in all prescribed 

fire plans) must be submitted and approved by the SCAQMD prior to using prescribed 

fire on federal lands. As part of the SMP the Forest Service must provide a detailed 

meteorological prescription that must be met prior to igniting a prescribed burn. At a 

minimum the prescription must include acceptable wind direction. Other considerations 

include wind speed, temperature profile, winds aloft, humidity, temperature, actual and 

predicted inversions, burn day status and forecast, precipitation forecast, and any other 

meteorological conditions which may effect smoke dispersion and/or the fire behavior. 

The SMP also has to contain actions the Forest Service will take if smoke from burning 

unexpectedly impacts smoke sensitive areas, including the ability to extinguishing the fire 

with equipment on hand. Smoke sensitive areas include any towns and or major roads 

within a 5 mile radius that could be impacted by smoke from the burn project. If the 

project exceeds one hundred acres a map showing sensitive areas within a radius of 

twenty miles from the burn site and the expected direction of smoke travel is required as 

part of the prescribed fire plan 

4) Burn Plan - All burning on Forest Service managed land must have an approved 

prescribed fire plan prior to any ignitions. Burning activities will be coordinated with 

affected landowners and control agencies. In addition to a management approved 

prescribed fire plan (which contains a smoke management plan) the unit has to submit a 

written request to the SCAQMD and receive their permission prior to all burning. Smoke 

production and emissions are within State and local government guidelines, are of short 

duration (a few days), and will not adversely effect the Class I Air Sheds. 

5) Fugitive Dust - Driving speeds on native surface roads are not expected to exceed 15 

mph. This speed control is accepted fugitive dust mitigation. Native surfaced roadways 

will be watered to suppress dust when needed. 

When logs are being transported from sale area all dirt based roads are required to be 

watered, by the timber sale purchaser, to abate dust that would be created by the 

increased road usage. Dust generated and the resultant particulate matter (PM10) is 

directly related to vehicle miles traveled on un-surfaced roads in the project area. It can 
Hi-Grouse Project Air Quality Report

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also be attributed to tractor work on harvest units. If agreed upon, a temporary road 

surface material especially made for dust reduction maybe applied to the roads instead of 

water. A Forest Service Timber Sale Administrator oversees all such operations, ensuring 

their implementation to contract specified requirements.

Mitigation Measures (GHGs emissions reduction and CO2 sequestration)

Analyses of the impacts of such emissions or sinks at the project level are too low to 

provide meaningful information to translate the information into climate change. Efforts 

would be spent that lead to reduced GHG emissions or increased sinks of these gases. 

Any mitigation measure outlined above that result in reduced fuel combustion will also 

release less GHGs. Any above measure that leads to production of greater biomass will 

result in greater carbon sequestration. 

Some of the mitigation measures/strategies that the agency is heading towards include the 

following: 

• Reducing Overstocking- Forest thinning leads to reduced fuels and lowers risks of 

catastrophic wildfires, insect and disease. The healthy forest acts as a better CO2 

sink. 

• Encouraging species mixes that can act as a better sink and tolerant to 

environmental factors like higher temperatures, droughts. 

• Encouraging environmentally sound human use through public outreach and other 

incentives – 

• Restoring degraded ecosystems 

• Implementing Emission Reduction Techniques that generate less emissions and 

create better CO2 sink

• Applying non-burning alternatives for fuel reduction where ever possible 

• Developing/manufacturing/transferring waste/dead wood into other useable form 

that has longer life for carbon sequestration. 
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Acronyms 

PM or PMT or TSP: Particulate matter, Total suspended particulate matter. PM and 

PMT actually refer to TSP (total suspended particulate matter)

PM10: Particulate matter less than 10 microns.

PM2.5: Particulate matter less than 2.5 microns.

ROG: Reactive organic gases: Compounds of carbon, excluding: Carbon monoxide, 

carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium 

carbonate, and the list of excluded compounds that can be found on the ROG 

definitions page, on this web site. 

TOG: Total organic gases: Compounds of carbon, excluding carbon monoxide, 

carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium 

carbonate.

NO2, NOx nitrogen dioxide, nitrogen oxides 

SO2, SOx sulfur dioxide, sulfur oxides 

CO carbon monoxide 

CO2 carbon dioxide 

Pb lead

VOCs volatile organic compounds 
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Appendix A: Forest Carbon 

Each of the action alternatives will remove biomass as a result of timber harvest and 

prescribed burning. This will reduce the amount of carbon stored in the treated stands. 

A portion of the carbon removed will remain stored for a period of time in wood 

products. 

The regeneration harvest with green tree retention and shelterwood with green tree 

retention will substantially reduce existing carbon stocks. The harvest of live trees, 

combined with the likely increase in down, dead wood will temporarily convert stands 

from a carbon sink that removes more carbon from the atmosphere than it emits to a 

carbon source that emits more carbon through respiration than it absorbs. These stands 

will remain a source of carbon to the atmosphere until carbon uptake by new trees 

exceeds the emissions from decomposing dead organic material. The stands will likely 

remain a carbon source for several years, and perhaps for more than a decade, depending 

on the amount of dead biomass left on site, the length of time before new trees become 

reestablished, and their rate of growth once reestablished. As the stands continue to 

develop, the strength of the carbon sink will increase until peaking at an intermediate age 

and then gradually decline but remain positive. Similarly, once new trees are established, 

carbon stocks will accumulate rapidly for several decades. The rate of accumulation will 

slow as the stands age. Carbon stocks will continue to accumulate, although at a 

declining rate, until impacted by future disturbances. 

Recent scientific literature confirms this general pattern of changes in net ecosystem 

productivity (NEP) and carbon stocks over the period of forest stand development. Law 

et al. (2003) evaluated changes in carbon storage and fluxes for Ponderosa pine stands in 

central Oregon. Their evaluation concluded that NEP is lowest and negative (carbon 

source) in young stands (9 – 23 years), moderate in young stands (56 – 89 years), highest 

in mature stands (95-106 years), and low in old stands (190-360 years). Most mature and 

old stands remained a net sink of carbon. Pregitzer and Euskirchen (2004) synthesized 

results from 120 separate studies of carbon stocks and carbon fluxes for boreal, 

temperate, and tropical biomes. They found that in temperate forests NEP is lowest, and 

most variable, in young stands (0-30 years), highest in stands 31-70 years, and declines 

thereafter as stands age. These studies also reveal a general pattern of total carbon stocks 

declining after disturbance and then increasing, rapidly during intermediate years and 

then at a declining rate, over time until another significant disturbance (timber harvest or 

tree mortality resulting from drought, fire, insects, disease or other causes) kills large 

numbers of trees and again converts the stands to a carbon source where carbon 

emissions from decay of dead biomass exceeds that amount of carbon removed from the 

atmosphere by photosynthesis within the stand. Over the long-term (centuries) net 

carbon storage is often zero, if stands regenerate, because re-growth of trees recovers the 

carbon lost in the disturbance and in decomposition of trees killed by the disturbance 

(Kashian et al. 2006). 

The intermediate thinning actions in both action alternatives will have similar effects on 

carbon fluxes and storage. However, the initial reduction in aboveground biomass will be 

less than the reductions with shelterwood with green tree retention and regeneration with 

green tree retention units. Commercial thinning will reduce the strength of the current 

carbon sink of these stands, but it is not clear whether commercial thinning activities will 
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convert the treated stands from a carbon sink to a carbon source. Future prescribed 

burning and thinning will continue to maintain carbon stocks and NEP at a lower level 

than would occur if the stands were permitted to develop higher tree densities. Although 

commercial thinning will reduce standing carbon stocks, compared to the no action 

alternative, these treatments will reduce the amount of carbon likely to be released to the 

atmosphere due to insect, disease and fire disturbance (Finkral and Evans 2008). 

By increasing the probability that large, fire and insect resistant trees will persist over 

time, commercial thinning of stands may sustain large carbon stocks and positive NEP 

over a longer time period than stands more prone to high severity fire and other 

disturbances (Canadell et al. 2007; Fellows and Goulden 2008). Krankina and Harmon 

(2007) observe that “higher carbon stores on land might mean the risk of higher future 

carbon emissions as the changing climate is expected to cause a higher rate of forest 

disturbance.” They suggest several general measures that can increase the stability of 

forests in changing environments and reduce the risk of losses of carbon. These 

recommended measures include: (1) selecting for species with relatively high resistance 

to drought, fire, insects, and pathogens; and (2) reducing fuel loads through thinning to 

improve stand resilience. The action alternatives in the proposal are consistent with these 

recommendations for protecting carbon gains against the potential impacts of future 

climate change. 

The impacts of the action alternatives on global carbon sequestration and atmospheric 

concentrations of CO2 are miniscule. However, the forests of the United States 

significantly reduce atmospheric concentrations of CO2 resulting from fossil fuel 

emissions. The forest and wood products of the United States currently sequester 

approximately 200 teragrams of carbon per year (Heath and Smith 2004). This rate of 

carbon sequestration offsets approximately 10% of CO2 emissions from burning fossil 

fuels (Birdsey et al. 2006). U.S. Forests currently contain 66,600 teragrams of carbon. 

The short-term reduction in carbon stocks and sequestration rates resulting from the 

proposed project are imperceptibly small on global and national scales, as are the 

potential long-term benefits. 

The currently large carbon sink in U.S. forests is a result of past land use changes, 

including the re-growth of forests on large areas of the eastern U.S. harvested in the 19th 

century, and 20th century fire suppression in the western U.S. (Birdsey et al. 2006). The 

continuation of this large carbon sink is uncertain because some of the processes 

promoting the current sink are likely to decline and projected increases in disturbance 

rates such as fire and large-scale insect mortality may release a significant fraction of 

existing carbon stocks (Pacala et al. 2008; Canadell et al. 2007). Management actions - 

such as those proposed – that improve the resilience of forests to climate-induced 

increases in frequency and intensity of disturbances such as fire, and utilize harvested 

trees for long-lived forest products and renewable energy sources may help sustain the 

current strength of the carbon sink in U.S. forests (Birdsey et al. 2007). 
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References 

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States: 1600-2100. Journal of Environmental Quality 35: 1461-1469. 

Birdsey, R.; Jenkins, J.; Johnston, M.; Huber-Sannwald, E.; 2007. North American 

Forests. In King, A.W.; Dilling, L.; Zimmerman, G.P.; Fairman, d.M.; Houghton, R.A.; 

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Canadell, J.G.; Pataki, D.E.; Gifford, R.; Houghton, R.A.; Luo, Y.; Raupach, M.R.; Smith, 

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Fellows, A.W. and M. L. Goulden 2008. Has fire suppression increased the amount of 

carbon stored in Western U.S. forests? Geophysical Research Letters 35, L12404, 

doi:10.1029/2008GL033965, 2008 

Finkral, A.J. and Evans, A.M. 2008. The effects of a thinning treatment on carbon stocks 

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Kashian, D.M.; Romme, W.H.; Tinker, D.B.; Turner, M.G.; Ryan, M.G. 2006. Carbon 

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d.M.; Houghton, R.A.; Marland, G.; Rose, A.Z.; Wilbanks, T.J.; eds. The First State of 

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