ATTACHMENTS

Attachment 1: Evidence the state has adopted the revision

1.1 Staff Report, Agenda Item I of the December 9-10, 2015 EQC meeting

Also see the Certificate and Order for Filing Permanent Administrative Rules 

in Attachment 4.2

Attachment 2: Evidence that the state has the necessary legal authority

For the legal authority, see page 5 of Attachment 1.1 

Attachment 3: Provisions submitted for approval

3.1 Amended rules submitted to Secretary of State effective December 10, 

2015: OAR 340-200-0040*

3.2 Redline strikeout version of amended rules submitted to Secretary of 

State effective December 10, 2015: OAR 340-200-0040*

3.3 Medford Limited Maintencance Plan for CO incorporated into Oregon’s 

State Implementation Plan with the submittal of amended OAR 340-200-

0040* to Secretary of State effective December 10, 2015

*Denotes rules that are not included in the State of Oregon Clean Air Act State Implementation 

Plan but are being submitted to show a complete account of the rulemaking package. 

Attachment 4: Evidence that the state followed the Administrative Procedures Act

4.1 Public notice in the Secretary of State's Oregon Bulletin, September 1, 

2015, publication

4.2 Certificate and Order for Filing Permanent Administrative Rules, filed 

and effective December 10, 2015

Attachment 5: Evidence of adequate public notice

5.1 Affidavits of Publication August 14, 2015: 

The Oregonian

Medford Mail Tribune
Attachment 6: Certification of public hearing

For certification of the public hearing, see the cover letter and page 10 of 

Attachment 1.1

Attachment 7: Compilation of public comment and department's response

For the Presiding Officer's record for rulemaking hearings, see page 10 of 

Attachment 1.1

For the Summary of comments and DEQ responses, see page 12 of Attachment 

1.1
Attachment 1

Evidence the state has adopted the revision

1.1 Staff Report, Agenda Item I of the December 9-10, 2015 EQC meeting

Also see the Certificate and Order for Filing Permanent Administrative Rules in 

Attachment 4.2
Staff Report page | 1

Oregon Department of Environmental Quality

Dec. 9, 2015

Oregon Environmental Quality Commission Meeting

Rulemaking Action Item I

Medford Carbon Monoxide Limited Maintenance Plan

DEQ recommendation to the EQC

DEQ recommends that the Environmental Quality Commission:

1. Approve the limited maintenance plan for Medford, included with this staff report as 

attachment B, as part of chapter 340 of the Oregon Administrative Rules.

2. Adopt the proposed rules in Attachment A as part of chapter 340 of the Oregon 

Administrative Rules;

3. Approve incorporating these rule amendments into the Oregon Clean Air Act State 

Implementation Plan under OAR 340-200-0040;

4. Direct DEQ to submit the SIP revision to the U.S. Environmental Protection Agency for 

approval.
Staff Report page | 2

Overview

In the 1970s and 1980s the Medford area violated the national air quality standard for carbon 

monoxide (CO). State and federal regulations applied measures that reduced CO concentrations and 

in 2002 the EPA redesignated Medford as meeting the CO standard. The redesignation included 

approval of the first Medford CO Maintenance Plan which demonstrated how the area would 

continue to meet the standard in the coming decade. EPA required the plan to include a budget for 

the amount of CO that vehicles operating on the future highway system could emit in coming 

decades. Each time a new transportation plan is adopted, planners must show that estimated CO 

emissions from the new highway system will remain within the budgeted amount. 

A second CO maintenance plan is now due under the Clean Air Act to address how the area will 

continue to meet the CO standard through September 23, 2022, the final maintenance plan period. In 

addition, DEQ recently discovered that the instructions by EPA’s consultant for calculating the 

motor vehicle emissions budget in the original plan were incorrect and the budget was set too low.

When future vehicle emissions are estimated and compared to the emissions budget, they exceed the

allowable amount. This error prevents Medford from adopting a new transportation plan under the 

original maintenance plan. The situation can be corrected by revising the budget in the original plan 

or by adopting a new CO maintenance plan. Since a second CO maintenance plan is already due, a 

new plan is the preferred way of correcting the error. 

CO monitoring was discontinued in Medford in 2009 because CO levels were well below the federal 

CO health standard, which is 27 percent of the federal CO limit.1 This low level of CO allows 

Medford to use the streamlined requirements of a “limited maintenance plan.” Under these 

streamlined requirements, a vehicle emissions budget is no longer required when preparing future 

transportation plans. 

DEQ, in consultation with EPA and the Rouge Valley Metropolitan Planning Organization 

(RVMPO), proposes this new limited maintenance plan as the most efficient way to ensure 

continued compliance with the CO standard while supporting Medford’s transportation planning 

process and schedule. A significant benefit of the proposed limited maintenance plan is that an 

emissions budget is no longer needed and the RVMPO can demonstrate conformity without a 

regional analysis. DEQ estimates this change will save the Rogue Valley MPO approximately 

$10,000 in unnecessary analysis costs every two years.

Under this plan Medford will continue to meet the federal CO standard, while eliminating 

administrative requirements that are no longer needed to protect air quality. The proposed limited 

maintenance plan updates Medford’s existing air quality plan, imposes no new control measures and 

saves the cost of emissions analyses that are no longer useful. 

 1 DEQ tracks trends in area wide CO levels through periodic emission inventory updates. DEQ will reinstate monitoring 

if CO emissions rise significantly. This is unlikely to occur given the federal and state emission reduction strategies in 

place. 
Staff Report page | 3

Regulated parties

The proposed Medford CO Limited Maintenance Plan would be an amendment to Oregon 

Administrative Rule 340-200-0040 which embodies the State of Oregon Clean Air Act 

Implementation Plan. This proposal would replace the existing Medford CO Maintenance Plan and 

Emissions Inventory. It does not change the parties regulated by the Medford Maintenance Plan as it 

continues to apply mostly to transportation planning agencies and planning departments of local 

jurisdictions. In addition, the plan retains existing control measures for industrial sources and 

therefore also applies to larger businesses in the Medford area. The proposed CO maintenance plan 

would not negatively affect large or small businesses because the rules do not create new 

requirements for businesses.

Request for other options

DEQ requested public comment on whether to consider other options for achieving the rule's 

substantive goals while reducing the rule’s negative economic impact on business. DEQ did not 

receive any comments on this topic.

Statement of Need

Proposed Rule or Topic Discussion

Incorrect Motor Vehicle Emission Budget for CO

What need would the proposed rule address? The primary purpose of this rulemaking is to 

correct an improperly calculated Motor Vehicle 

Emission Budget in the existing CO 

Maintenance Plan. Air quality rules require new 

Regional Transportation Plans to demonstrate 

that future vehicle emissions from a planned 

transportation system “conform” to the budget 

in the applicable air quality plan. The existing 

budget is incorrectly low and cannot be met.

How would the proposed rule address the need? Because the CO concentrations in Medford are 

very low, DEQ proposes adoption of a Limited 

CO Maintenance Plan. The plan removes the 

need for a Motor Vehicle Emissions Budget, 

which is now an artificial obstacle to adopting a 

new transportation plan. 

How will DEQ know the rule addressed the need? The need will be addressed if EPA declares 

removing the existing emissions budget to be 

adequate by the end of the first quarter in 2016, 

and subsequently approves the new plan.
Staff Report page | 4

Proposed Rule or Topic Discussion

Second 10-Year Maintenance Plan

What need would the proposed rule address? After EPA confirms that an area with an 

approved 10-year maintenance plan meets the 

CO standard, the state must submit a second 

maintenance plan showing how the area will 

continue to meet the standard until 20 years after 

re-designation to attainment. 

How would the proposed rule address the need? The proposed rulemaking includes a new 

Medford CO Limited Maintenance Plan as the 

area’s second maintenance plan.

How will DEQ know the rule addressed the need? This need will be met if EPA approves the new 

CO maintenance plan and the Medford area 

continues to meet the CO standard.

Verification of Continued Attainment

What need would the proposed rule address? Because CO concentrations in Medford are very 

low and the chance of exceeding the CO standard 

in the future is unlikely, CO monitoring 

equipment was removed after 2009. However, 

Medford still needs a method to determine if CO 

levels increase significantly.

How would the proposed rule address the need? The new Medford CO Limited Maintenance Plan 

requires the emission inventory prepared for 

Medford every three years to be evaluated to 

determine if CO emissions increase significantly. 

If they do, CO monitoring will be resumed.

How will DEQ know the rule addressed the need? The need will be met if EPA approves this 

technique in the new Medford CO plan as an 

appropriate way to detect a significant increase 

of CO in Medford.

Rules affected, authorities, supporting documents

Lead division Program or activity

Environmental Solutions Air Quality Planning

Chapter 340 action

Amend OAR 340-200-0040
Staff Report page | 5

 Statutory authority 

ORS 468.020, 468A

Statutes implemented

ORS 468A.035, 468A.135

Documents relied on for rulemaking ORS 183.335(2)(b)(C)

Document title Document location

State Implementation Plan Revision for Carbon 

Monoxide in the Medford Urban Growth 

Boundary

State Implementation Plan Revision for Carbon 

Monoxide in the Medford Urban Growth 

Boundary

EPA guidance document: 1995 Paisie Memo: 

Limited Maintenance Plan Option for 

Nonclassifiable CO Nonattainment Areas

EPA guidance document: 1995 Paisie Memo: 

Limited Maintenance Plan Option for 

Nonclassifiable CO Nonattainment Areas

Fee Analysis

This rulemaking does not involve fees.

Statement of fiscal and economic impact 

Fiscal and Economic Impact

The proposed limited maintenance plan has a positive fiscal and economic impact. The limited 

maintenance plan would streamline existing requirements, require no new control measures and 

reduce the need for a costly regional emissions analysis under the transportation conformity rules.

Statement of Cost of Compliance

State and federal agencies

The proposed plan would not affect state or federal agencies directly. Because the proposed rules 

would greatly simplify transportation conformity requirements, the rules would have a slight positive 

fiscal and economic effect on DEQ indirectly. That small beneficial effect comes from reduced staff 

time needed to evaluate Medford’s future conformity determinations required by transportation 

conformity rules. 

Local governments
Staff Report page | 6

The proposed limited maintenance plan would have some positive effect on local government in the 

form of cost savings. 

Under the federal Clean Air Act and Federal Transportation Act, metropolitan planning 

organizations (MPO) in maintenance areas are subject to transportation conformity rules. The MPO

for Medford is the Rogue Valley Metropolitan Planning Organization. 

Each time an MPO adopts a new regional transportation plan or transportation improvement 

program, the conformity rules require the organization to demonstrate that emissions from the future 

transportation system will not exceed the transportation emissions anticipated in the applicable 

maintenance plan. The MPO demonstrates this by preparing a regional emissions analysis that 

combines computer modeling of the highway system and of emission characteristics of the area’s 

cars and trucks. A significant benefit of the proposed limited maintenance plan is that an emissions 

budget is no longer needed and the MPO can demonstrate conformity without a regional analysis. 

DEQ estimates that not having to conduct this analysis would save the Rogue Valley Metropolitan 

Planning Organization approximately $10,000 every two years.

Public

The proposed plan would not affect the public directly. Air pollution creates public health problems 

that have indirect negative economic effects, but the area’s CO concentration is very low and is 

expected to stay low indefinitely. The proposed plan would continue positive economic effects in 

public health and welfare by maintaining compliance with the CO air quality standard.

Large businesses - businesses with more than 50 employees

The proposed CO maintenance plan would not affect large businesses directly because the rules 

would not create new requirements for businesses.

DEQ anticipates CO concentrations would remain at a very low level under the proposed plan.

However, the proposed rules could have indirect negative fiscal or economic effects on large 

businesses if CO levels were to increase substantially and the Medford area were to again violate 

federal air quality standards.

The CO limited maintenance plan provides a contingency plan that describes actions to be taken if 

CO concentrations rise significantly. In the unlikely event of a future violation of the CO standard, 

the plan would require more stringent requirements for new and expanding industry. A violation 

would trigger DEQ having to reinstate the New Source Review requirement for Lowest Achievable 

Emission Rate and emission offsets for new and expanding industrial sources under Oregon 

Administrative Rules Chapter 340 Division 224. DEQ does not anticipate substantial industrial 

growth in the Medford area, and any new or expanding emission sources that are large businesses 

may not be large enough to trigger New Source Review requirements. At this time, DEQ cannot 

accurately estimate the possible fiscal and economic impacts should the contingency plan be 

triggered, because such impacts are case specific.

Small businesses – businesses with 50 or fewer employees

The proposed rules would not affect small businesses directly because the proposed plan would not 

create new requirements. The plan would likely have no indirect effects on small businesses. In the 

unlikely event that the Medford area violates the CO standard, the contingency plan would affect 
Staff Report page | 7

small businesses in the same way as described for large businesses above. That is, a violation of the 

standard would trigger more stringent New Source Review requirements for new and expanding 

industry. However, small businesses are unlikely to have large enough emission quantities to trigger 

the requirements.

a. Estimated number of small businesses 

and types of businesses and industries 

with small businesses subject to proposed 

rule.

None

b. Projected reporting, recordkeeping and 

other administrative activities, including 

costs of professional services, required 

for small businesses to comply with the 

proposed rule.

None

c. Projected equipment, supplies, labor 

and increased administration required for 

small businesses to comply with the 

proposed rule.

None

d. Describe how DEQ involved small 

businesses in developing this proposed 

rule.

DEQ did not involve small businesses in developing 

the proposed rules because the rules would likely not 

affect small businesses.

Advisory committee

DEQ did not convene an advisory committee because the proposed new maintenance plan would not 

create new control measures. The plan only extends the current control measures as required under 

the federal Clean Air Act. 

DEQ consulted with Rogue Valley Metropolitan Planning Organization and EPA staff during 

development of the proposed limited maintenance plan.

Housing cost 

To comply with ORS 183.534, DEQ determined the proposed rules would have no effect on the 

development cost of a 6,000-square-foot parcel and construction of a 1,200-square-foot detached, 

single-family dwelling on that parcel. The change between the existing maintenance plan and the 

proposed maintenance plan primarily affects the transportation process.

Federal relationship
Staff Report page | 8

Relationship to federal requirements 

This section complies with OAR 340-011-0029 and ORS 468A.327 to clearly identify the relationship 

between the proposed rules and applicable federal requirements. 

The proposed rules are not “different from or in addition to federal requirements” and impose 

stringency equivalent to federal requirements.

The proposed limited maintenance plan would ensure that DEQ continues to comply with federal 

requirements in the Clean Air Act. The plan must demonstrate that the Medford area will continue to 

meet the federal CO standard until September 2022. EPA policy allows areas that are at low risk of 

exceeding the CO standard the option of submitting a simplified limited maintenance plan. The limited 

maintenance plan provides streamlined requirements, adds no new control measures and reduces the 

need for costly regional emissions analyses when new transportation or transportation improvement 

programs are adopted.

What alternatives did DEQ consider if any? 

Because this action is necessary to comply with requirements of the Clean Air Act, DEQ has not 

considered other options for this proposal. 

Land Use

Land-use considerations

In adopting new or amended rules, ORS 197.180 and OAR 340-018-0070 require DEQ to determine 

whether the proposed rules significantly affect land use. If so, DEQ must explain how the proposed 

rules comply with statewide land-use planning goals and local acknowledged comprehensive plans.

Under OAR 660-030-0005 and OAR 340 Division 18, DEQ considers that rules affect land use if:

• The statewide land-use planning goals specifically refer to the rule or program, or

• The rule or program is reasonably expected to have significant effects on:

o Resources, objectives or areas identified in the statewide planning goals, or

o Present or future land uses identified in acknowledged comprehensive plans

To determine whether the proposed rules involve programs or actions that affect land use, DEQ 

reviewed its Statewide Agency Coordination plan, which describes DEQ programs that significantly 

affect land use. DEQ considers that its programs specifically relate to the following statewide goals:

Goal Title

5 Open Spaces, Scenic and Historic Areas, and Natural Resources

6 Air, Water and Land Resources Quality

9 Ocean Resources

11 Public Facilities and Services
Staff Report page | 9

16 Estuarial Resources

Statewide goals also specifically reference the following DEQ programs:

• Nonpoint source discharge water quality program – Goal 16

• Water quality and sewage disposal systems – Goal 16

• Water quality permits and oil spill regulations – Goal 19

Determination

DEQ determined that the proposed rules listed under the Chapter 340 Action section above do not 

affect existing rules, programs or activities considered land-use programs and actions in OAR 340-

018-0030 or in the DEQ State Agency Coordination Program.

Stakeholder and public involvement

Advisory committee

DEQ did not convene an advisory committee because the proposed new maintenance plan would not 

create new control measures. The plan only extends the current control measures as required under 

the federal Clean Air Act. 

DEQ consulted with Rogue Valley Metropolitan Planning Organization staff during development of 

the proposed limited maintenance plan.

EQC prior involvement

DEQ shares general rulemaking information with the Oregon Environmental Quality Commission

through the monthly Director’s Report. DEQ did not present the commission additional information 

specific to this proposed rule revision. 

Public notice

DEQ notified the public of this rulemaking proposal by:

• Publishing notice in the Sept. 1, 2015 Oregon Bulletin

• Placing the rulemaking notice on the web page for this rulemaking: Medford LMP 

Rulemaking

• Emailing 9434 interested parties on the Agency Rulemaking List through GovDelivery

• Emailing the following key Oregon legislators required under ORS 183.335:
Staff Report page | 10

o Senator Chris Edwards, Chair, Senate Environment and Natural Resources 

Committee

o Representative Jessica Vega-Pederson, Chair, House Energy and Environment 

Committee

• Issuing a DEQ news release

• Posting notice about the rulemaking on Facebook and Twitter

• Emailing these additional legislators:

o Rep. Duane Stark

o Rep. Peter Buckley

o Rep. Sal Esquivel

o Sen. Baertschiger

o Sen. Alan Bates

o Sen. Doug Whitsett

• Providing legal notices in the following newspapers:

o The Oregonian - Publication date - Aug. 14, 2015

o Mail Tribune (Medford) - Publication date – Aug. 14, 2015

Public hearing

DEQ held a public hearing on this topic at DEQ’s Medford office. The table below provides 

information about that hearing.

Date Monday, Sept. 21, 2015

Time 7 p.m.

Address Line 1 221 Stewart Ave.

Address Line 2 Suite 201

City Medford

Presiding Officer Tom Peterson

Staff Presenter Dave Nordberg (by phone)

Call-in Phone Number 888-204-5984

Call-in Phone ID Code 257801

DEQ’s Tom Peterson presided as Hearings Officer and DEQ’s Dave Nordberg connected to the 

hearing via an open conference line. As author of the plan, Mr. Nordberg was available before taking 

public comment to summarize the content of the notice and respond to any questions about the 

rulemaking. No one attended the hearing and no one called to provide comments from a remote 

location. Shortly after 7:30 Mr. Peterson officially closed the proceeding.

Close of public comment period
Staff Report page | 11

The comment period closed Thursday, Sept. 24, 2015 at 4 p.m.

Request for other options

During the public comment period, DEQ requested public comment on whether to consider other 

options for achieving the rules’ substantive goals while reducing the rules’ negative economic 

impact on business. No comments responded to this request.
Staff Report page | 12

Summary of comments and DEQ responses

 

During the public comment period DEQ received a single comment submitted through the 

agency’s website.

Comment:

Stronger emissions are encouraged. Oregon’s environmental laws are lax allowing 

Multnomah County and the state as a whole to have high levels of diesel soot.

Commenter

Diane Hodiak, affiliated with 350 Deschutes, OR

Response

The proposed Maintenance Plan addresses only carbon monoxide emissions in the 

Medford area. Regional diesel particulate emissions are outside the scope of this 

rulemaking.

DEQ did not change the proposed rules in response to comment.

Implementation 

 

Notification

The proposed rules would become effective as state regulations upon filing on 

approximately Dec. 9, 2015. By approximately Dec. 29, 2015, DEQ would submit the new 

Medford CO Maintenance Plan to EPA as a revision to the Oregon’s State Implementation 

Plan. EPA has committed to promptly reviewing a new CO Plan adopted by the Oregon 

EQC in time to issue an Adequacy Determination allowing the revised motor vehicle 

emissions budget of the new plan to be implemented by Mar. 31, 2016. Once approved, 

DEQ will immediately share that information with the Rogue Valley Metropolitan 

Planning Organization, Oregon Department of Transportation, Federal Highway 

Administration and Federal Transit Administration. 

Compliance and enforcement

Compliance and enforcement of the new Maintenance Plan will be conducted through 

DEQ’s air quality permitting process for industrial sources and the transportation 

conformity requirements of the transportation planning process. The Federal Highway 

Administration and Federal Transit Administration Transportation administer conformity.
Notice page | 13

Measuring, sampling, monitoring and reporting

In order to verify continued attainment, every three years DEQ will review the National 

Emissions Estimates (NEI) of Medford’s CO emissions to identify increases over the 2008 

emission levels. DEQ will evaluate any increase in CO emissions to verify it is not due to 

a change in emission calculation methodology, an exceptional event or other factor not 

representative of an actual emissions increase. Estimated CO emissions will be compared 

to 2008 emission levels to determine if Contingency Plan provisions of the CO 

Maintenance Plan are triggered.

Systems

There are no new requirements for DEQ’s systems aside from posting the new 

Maintenance Plan once it is approved by EPA as a SIP revision.

Training

The new Maintenance Plan continues most of the existing regulatory requirements except 

those applying to conducting regional emissions analyses which are removed. There is no 

need for training.
Notice page | 14

Five-year review ORS 183.405

Requirement 

Oregon law requires DEQ to review new rules within five years after EQC adopts them. 

The law also exempts some rules from review. DEQ determined whether the rules 

described in this report are subject to the five-year review based on its analysis of the law 

in effect when EQC adopted these rules. 

Exemption from five-year rule review

The Administrative Procedures Act exempts the proposed rule from the five-year review 

because the proposed rule would amend an existing rule. ORS 183.405(4).
Attachment 2

Evidence that the state has the necessary legal authority

For the legal authority, see page 5 of Attachment 1.1
Attachment 3

Provisions submitted for approval

3.1 Amended rules submitted to Secretary of State effective December 10, 2015: 

OAR 340-200-0040*

3.2 Redline strikeout version of amended rules submitted to Secretary of State 

effective December 10, 2015: OAR 340-200-0040*

3.3 Medford Limited Maintencance Plan for CO incorporated into Oregon’s 

State Implementation Plan with the submittal of amended OAR 340-200-

0040* to Secretary of State effective December 10, 2015

*Denotes rules that are not included in the State of Oregon Clean Air Act State 

Implementation Plan but are being submitted to show a complete account of the rulemaking 

package. 
DEPARTMENT OF ENVIRONMENTAL QUALITY

340-200-0040

State of Oregon Clean Air Act Implementation Plan

(1) This implementation plan, consisting of Volumes 2 and 3 of the State of Oregon Air 

Quality Control Program, contains control strategies, rules and standards prepared by 

DEQ and is adopted as the State Implementation Plan (SIP) of the State of Oregon 

pursuant to the FCAA, 42 U.S.C.A 7401 to 7671q. 

(2) Except as provided in section (3), revisions to the SIP will be made pursuant to the 

EQC’s rulemaking procedures in OAR 340 division 11 of this chapter and any other 

requirements contained in the SIP and will be submitted to the EPA for approval. The 

SIP was last modified by the EQC on Dec. 9, 2015. 

(3) Notwithstanding any other requirement contained in the SIP, DEQ may: 

(a) Submit to the EPA any permit condition implementing a rule that is part of the 

federally-approved SIP as a source-specific SIP revision after DEQ has complied with 

the public hearings provisions of 40 CFR 51.102; and 

(b) Approve the standards submitted by LRAPA if LRAPA adopts verbatim, other than 

non-substantive differences, any standard that the EQC has adopted, and submit the 

standards to EPA for approval as a SIP revision. 

(4) Revisions to the State of Oregon Clean Air Act Implementation Plan become 

federally enforceable upon approval by the EPA. If any provision of the federally 

approved State Implementation Plan conflicts with any provision adopted by the EQC, 

DEQ must enforce the more stringent provision.

Stat. Auth.: ORS 468.020 & 468A 

Stats. Implemented: ORS 468A.035 & 468A.135 

Hist.: DEQ 35, f. 2-3-72, ef. 2-15-72; DEQ 54, f. 6-21-73, ef. 7-1-73; DEQ 19-1979, f. & 

ef. 6-25-79; DEQ 21-1979, f. & ef. 7-2-79; DEQ 22-1980, f. & ef. 9-26-80; DEQ 11-

1981, f. & ef. 3-26-81; DEQ 14-1982, f. & ef. 7-21-82; DEQ 21-1982, f. & ef. 10-27-82; 

DEQ 1-1983, f. & ef. 1-21-83; DEQ 6-1983, f. & ef. 4-18-83; DEQ 18-1984, f. & ef. 10-

16-84; DEQ 25-1984, f. & ef. 11-27-84; DEQ 3-1985, f. & ef. 2-1-85; DEQ 12-1985, f. 

& ef. 9-30-85; DEQ 5-1986, f. & ef. 2-21-86; DEQ 10-1986, f. & ef. 5-9-86; DEQ 20-

1986, f. & ef. 11-7-86; DEQ 21-1986, f. & ef. 11-7-86; DEQ 4-1987, f. & ef. 3-2-87; 

DEQ 5-1987, f. & ef. 3-2-87; DEQ 8-1987, f. & ef. 4-23-87; DEQ 21-1987, f. & ef. 12-

16-87; DEQ 31-1988, f. 12-20-88, cert. ef. 12-23-88; DEQ 2-1991, f. & cert. ef. 2-14-91; 

DEQ 19-1991, f. & cert. ef. 11-13-91; DEQ 20-1991, f. & cert. ef. 11-13-91; DEQ 21-

1991, f. & cert. ef. 11-13-91; DEQ 22-1991, f. & cert. ef. 11-13-91; DEQ 23-1991, f. & 
cert. ef. 11-13-91; DEQ 24-1991, f. & cert. ef. 11-13-91; DEQ 25-1991, f. & cert. ef. 11-

13-91; DEQ 1-1992, f. & cert. ef. 2-4-92; DEQ 3-1992, f. & cert. ef. 2-4-92; DEQ 7-

1992, f. & cert. ef. 3-30-92; DEQ 19-1992, f. & cert. ef. 8-11-92; DEQ 20-1992, f. & 

cert. ef. 8-11-92; DEQ 25-1992, f. 10-30-92, cert. ef. 11-1-92; DEQ 26-1992, f. & cert. 

ef. 11-2-92; DEQ 27-1992, f. & cert. ef. 11-12-92; DEQ 4-1993, f. & cert. ef. 3-10-93; 

DEQ 8-1993, f. & cert. ef. 5-11-93; DEQ 12-1993, f. & cert. ef. 9-24-93; DEQ 15-1993, 

f. & cert. ef. 11-4-93; DEQ 16-1993, f. & cert. ef. 11-4-93; DEQ 17-1993, f. & cert. ef. 

11-4-93; DEQ 19-1993, f. & cert. ef. 11-4-93; DEQ 1-1994, f. & cert. ef. 1-3-94; DEQ 5-

1994, f. & cert. ef. 3-21-94; DEQ 14-1994, f. & cert. ef. 5-31-94; DEQ 15-1994, f. 6-8-

94, cert. ef. 7-1-94; DEQ 25-1994, f. & cert. ef. 11-2-94; DEQ 9-1995, f. & cert. ef. 5-1-

95; DEQ 10-1995, f. & cert. ef. 5-1-95; DEQ 14-1995, f. & cert. ef. 5-25-95; DEQ 17-

1995, f. & cert. ef. 7-12-95; DEQ 19-1995, f. & cert. ef. 9-1-95; DEQ 20-1995 (Temp), f. 

& cert. ef. 9-14-95; DEQ 8-1996(Temp), f. & cert. ef. 6-3-96; DEQ 15-1996, f. & cert. 

ef. 8-14-96; DEQ 19-1996, f. & cert. ef. 9-24-96; DEQ 22-1996, f. & cert. ef. 10-22-96; 

DEQ 23-1996, f. & cert. ef. 11-4-96; DEQ 24-1996, f. & cert. ef. 11-26-96; DEQ 10-

1998, f. & cert. ef. 6-22-98; DEQ 15-1998, f. & cert. ef. 9-23-98; DEQ 16-1998, f. & 

cert. ef. 9-23-98; DEQ 17-1998, f. & cert. ef. 9-23-98; DEQ 20-1998, f. & cert. ef. 10-12-

98; DEQ 21-1998, f. & cert. ef. 10-12-98; DEQ 1-1999, f. & cert. ef. 1-25-99; DEQ 5-

1999, f. & cert. ef. 3-25-99; DEQ 6-1999, f. & cert. ef. 5-21-99; DEQ 10-1999, f. & cert. 

ef. 7-1-99; DEQ 14-1999, f. & cert. ef. 10-14-99, Renumbered from 340-020-0047; DEQ 

15-1999, f. & cert. ef. 10-22-99; DEQ 2-2000, f. 2-17-00, cert. ef. 6-1-01; DEQ 6-2000, 

f. & cert. ef. 5-22-00; DEQ 8-2000, f. & cert. ef. 6-6-00; DEQ 13-2000, f. & cert. ef. 7-

28-00; DEQ 16-2000, f. & cert. ef. 10-25-00; DEQ 17-2000, f. & cert. ef. 10-25-00; DEQ 

20-2000 f. & cert. ef. 12-15-00; DEQ 21-2000, f. & cert. ef. 12-15-00; DEQ 2-2001, f. & 

cert. ef. 2-5-01; DEQ 4-2001, f. & cert. ef. 3-27-01; DEQ 6-2001, f. 6-18-01, cert. ef. 7-

1-01; DEQ 15-2001, f. & cert. ef. 12-26-01; DEQ 16-2001, f. & cert. ef. 12-26-01; DEQ 

17-2001, f. & cert. ef. 12-28-01; DEQ 4-2002, f. & cert. ef. 3-14-02; DEQ 5-2002, f. & 

cert. ef. 5-3-02; DEQ 11-2002, f. & cert. ef. 10-8-02; DEQ 5-2003, f. & cert. ef. 2-6-03; 

DEQ 14-2003, f. & cert. ef. 10-24-03; DEQ 19-2003, f. & cert. ef. 12-12-03; DEQ 1-

2004, f. & cert. ef. 4-14-04; DEQ 10-2004, f. & cert. ef. 12-15-04; DEQ 1-2005, f. & 

cert. ef. 1-4-05; DEQ 2-2005, f. & cert. ef. 2-10-05; DEQ 4-2005, f. 5-13-05, cert. ef. 6-

1-05; DEQ 7-2005, f. & cert. ef. 7-12-05; DEQ 9-2005, f. & cert. ef. 9-9-05; DEQ 2-

2006, f. & cert. ef. 3-14-06; DEQ 4-2006, f. 3-29-06, cert. ef. 3-31-06; DEQ 3-2007, f. & 

cert. ef. 4-12-07; DEQ 4-2007, f. & cert. ef. 6-28-07; DEQ 8-2007, f. & cert. ef. 11-8-07; 

DEQ 5-2008, f. & cert. ef. 3-20-08; DEQ 11-2008, f. & cert. ef. 8-29-08; DEQ 12-2008, 

f. & cert. ef. 9-17-08; DEQ 14-2008, f. & cert. ef. 11-10-08; DEQ 15-2008, f. & cert. ef 

12-31-08; DEQ 3-2009, f. & cert. ef. 6-30-09; DEQ 8-2009, f. & cert. ef. 12-16-09; DEQ 

2-2010, f. & cert. ef. 3-5-10; DEQ 5-2010, f. & cert. ef. 5-21-10; DEQ 14-2010, f. & cert. 

ef. 12-10-10; DEQ 1-2011, f. & cert. ef. 2-24-11; DEQ 2-2011, f. 3-10-11, cert. ef. 3-15-

11; DEQ 5-2011, f. 4-29-11, cert. ef. 5-1-11; DEQ 18-2011, f. & cert. ef. 12-21-11; DEQ 

1-2012, f. & cert. ef. 5-17-12; DEQ 7-2012, f. & cert.ef 12-10-12; DEQ 10-2012, f. & 

cert. ef. 12-11-12; DEQ 4-2013, f. & cert. ef. 3-27-13; DEQ 11-2013, f. & cert. ef. 11-7-

13; DEQ 12-2013, f. & cert. ef. 12-19-13; DEQ 1-2014, f. & cert. ef. 1-6-14; DEQ 4-

2014, f. & cert. ef. 3-31-14; DEQ 5-2014, f. & cert. ef. 3-31-14; DEQ 6-2014, f. & cert. 

ef. 3-31-14; DEQ 7-2014, f. & cert. ef. 6-26-14; DEQ 6-2015, f. & cert. ef. 4-16-15; 

DEQ 7-2015, f. & cert. ef. 4-16-15
DEPARTMENT OF ENVIRONMENTAL QUALITY

340-200-0040

State of Oregon Clean Air Act Implementation Plan

(1) This implementation plan, consisting of Volumes 2 and 3 of the State of Oregon Air 

Quality Control Program, contains control strategies, rules and standards prepared by 

DEQ and is adopted as the State Implementation Plan (SIP) of the State of Oregon 

pursuant to the FCAA, 42 U.S.C.A 7401 to 7671q. 

(2) Except as provided in section (3), revisions to the SIP will be made pursuant to the 

EQC’s rulemaking procedures in OAR 340 division 11 of this chapter and any other 

requirements contained in the SIP and will be submitted to the EPA for approval. The 

SIP was last modified by the EQC on April 16, 2015 Dec. 9, 2015. 

(3) Notwithstanding any other requirement contained in the SIP, DEQ may: 

(a) Submit to the EPA any permit condition implementing a rule that is part of the 

federally-approved SIP as a source-specific SIP revision after DEQ has complied with 

the public hearings provisions of 40 CFR 51.102; and 

(b) Approve the standards submitted by LRAPA if LRAPA adopts verbatim, other than 

non-substantive differences, any standard that the EQC has adopted, and submit the 

standards to EPA for approval as a SIP revision. 

(4) Revisions to the State of Oregon Clean Air Act Implementation Plan become 

federally enforceable upon approval by the EPA. If any provision of the federally 

approved State Implementation Plan conflicts with any provision adopted by the EQC, 

DEQ must enforce the more stringent provision.

Stat. Auth.: ORS 468.020 & 468A 

Stats. Implemented: ORS 468A.035 & 468A.135 

Hist.: DEQ 35, f. 2-3-72, ef. 2-15-72; DEQ 54, f. 6-21-73, ef. 7-1-73; DEQ 19-1979, f. & 

ef. 6-25-79; DEQ 21-1979, f. & ef. 7-2-79; DEQ 22-1980, f. & ef. 9-26-80; DEQ 11-

1981, f. & ef. 3-26-81; DEQ 14-1982, f. & ef. 7-21-82; DEQ 21-1982, f. & ef. 10-27-82; 

DEQ 1-1983, f. & ef. 1-21-83; DEQ 6-1983, f. & ef. 4-18-83; DEQ 18-1984, f. & ef. 10-

16-84; DEQ 25-1984, f. & ef. 11-27-84; DEQ 3-1985, f. & ef. 2-1-85; DEQ 12-1985, f. 

& ef. 9-30-85; DEQ 5-1986, f. & ef. 2-21-86; DEQ 10-1986, f. & ef. 5-9-86; DEQ 20-

1986, f. & ef. 11-7-86; DEQ 21-1986, f. & ef. 11-7-86; DEQ 4-1987, f. & ef. 3-2-87; 

DEQ 5-1987, f. & ef. 3-2-87; DEQ 8-1987, f. & ef. 4-23-87; DEQ 21-1987, f. & ef. 12-

16-87; DEQ 31-1988, f. 12-20-88, cert. ef. 12-23-88; DEQ 2-1991, f. & cert. ef. 2-14-91; 

DEQ 19-1991, f. & cert. ef. 11-13-91; DEQ 20-1991, f. & cert. ef. 11-13-91; DEQ 21-

1991, f. & cert. ef. 11-13-91; DEQ 22-1991, f. & cert. ef. 11-13-91; DEQ 23-1991, f. & 
cert. ef. 11-13-91; DEQ 24-1991, f. & cert. ef. 11-13-91; DEQ 25-1991, f. & cert. ef. 11-

13-91; DEQ 1-1992, f. & cert. ef. 2-4-92; DEQ 3-1992, f. & cert. ef. 2-4-92; DEQ 7-

1992, f. & cert. ef. 3-30-92; DEQ 19-1992, f. & cert. ef. 8-11-92; DEQ 20-1992, f. & 

cert. ef. 8-11-92; DEQ 25-1992, f. 10-30-92, cert. ef. 11-1-92; DEQ 26-1992, f. & cert. 

ef. 11-2-92; DEQ 27-1992, f. & cert. ef. 11-12-92; DEQ 4-1993, f. & cert. ef. 3-10-93; 

DEQ 8-1993, f. & cert. ef. 5-11-93; DEQ 12-1993, f. & cert. ef. 9-24-93; DEQ 15-1993, 

f. & cert. ef. 11-4-93; DEQ 16-1993, f. & cert. ef. 11-4-93; DEQ 17-1993, f. & cert. ef. 

11-4-93; DEQ 19-1993, f. & cert. ef. 11-4-93; DEQ 1-1994, f. & cert. ef. 1-3-94; DEQ 5-

1994, f. & cert. ef. 3-21-94; DEQ 14-1994, f. & cert. ef. 5-31-94; DEQ 15-1994, f. 6-8-

94, cert. ef. 7-1-94; DEQ 25-1994, f. & cert. ef. 11-2-94; DEQ 9-1995, f. & cert. ef. 5-1-

95; DEQ 10-1995, f. & cert. ef. 5-1-95; DEQ 14-1995, f. & cert. ef. 5-25-95; DEQ 17-

1995, f. & cert. ef. 7-12-95; DEQ 19-1995, f. & cert. ef. 9-1-95; DEQ 20-1995 (Temp), f. 

& cert. ef. 9-14-95; DEQ 8-1996(Temp), f. & cert. ef. 6-3-96; DEQ 15-1996, f. & cert. 

ef. 8-14-96; DEQ 19-1996, f. & cert. ef. 9-24-96; DEQ 22-1996, f. & cert. ef. 10-22-96; 

DEQ 23-1996, f. & cert. ef. 11-4-96; DEQ 24-1996, f. & cert. ef. 11-26-96; DEQ 10-

1998, f. & cert. ef. 6-22-98; DEQ 15-1998, f. & cert. ef. 9-23-98; DEQ 16-1998, f. & 

cert. ef. 9-23-98; DEQ 17-1998, f. & cert. ef. 9-23-98; DEQ 20-1998, f. & cert. ef. 10-12-

98; DEQ 21-1998, f. & cert. ef. 10-12-98; DEQ 1-1999, f. & cert. ef. 1-25-99; DEQ 5-

1999, f. & cert. ef. 3-25-99; DEQ 6-1999, f. & cert. ef. 5-21-99; DEQ 10-1999, f. & cert. 

ef. 7-1-99; DEQ 14-1999, f. & cert. ef. 10-14-99, Renumbered from 340-020-0047; DEQ 

15-1999, f. & cert. ef. 10-22-99; DEQ 2-2000, f. 2-17-00, cert. ef. 6-1-01; DEQ 6-2000, 

f. & cert. ef. 5-22-00; DEQ 8-2000, f. & cert. ef. 6-6-00; DEQ 13-2000, f. & cert. ef. 7-

28-00; DEQ 16-2000, f. & cert. ef. 10-25-00; DEQ 17-2000, f. & cert. ef. 10-25-00; DEQ 

20-2000 f. & cert. ef. 12-15-00; DEQ 21-2000, f. & cert. ef. 12-15-00; DEQ 2-2001, f. & 

cert. ef. 2-5-01; DEQ 4-2001, f. & cert. ef. 3-27-01; DEQ 6-2001, f. 6-18-01, cert. ef. 7-

1-01; DEQ 15-2001, f. & cert. ef. 12-26-01; DEQ 16-2001, f. & cert. ef. 12-26-01; DEQ 

17-2001, f. & cert. ef. 12-28-01; DEQ 4-2002, f. & cert. ef. 3-14-02; DEQ 5-2002, f. & 

cert. ef. 5-3-02; DEQ 11-2002, f. & cert. ef. 10-8-02; DEQ 5-2003, f. & cert. ef. 2-6-03; 

DEQ 14-2003, f. & cert. ef. 10-24-03; DEQ 19-2003, f. & cert. ef. 12-12-03; DEQ 1-

2004, f. & cert. ef. 4-14-04; DEQ 10-2004, f. & cert. ef. 12-15-04; DEQ 1-2005, f. & 

cert. ef. 1-4-05; DEQ 2-2005, f. & cert. ef. 2-10-05; DEQ 4-2005, f. 5-13-05, cert. ef. 6-

1-05; DEQ 7-2005, f. & cert. ef. 7-12-05; DEQ 9-2005, f. & cert. ef. 9-9-05; DEQ 2-

2006, f. & cert. ef. 3-14-06; DEQ 4-2006, f. 3-29-06, cert. ef. 3-31-06; DEQ 3-2007, f. & 

cert. ef. 4-12-07; DEQ 4-2007, f. & cert. ef. 6-28-07; DEQ 8-2007, f. & cert. ef. 11-8-07; 

DEQ 5-2008, f. & cert. ef. 3-20-08; DEQ 11-2008, f. & cert. ef. 8-29-08; DEQ 12-2008, 

f. & cert. ef. 9-17-08; DEQ 14-2008, f. & cert. ef. 11-10-08; DEQ 15-2008, f. & cert. ef 

12-31-08; DEQ 3-2009, f. & cert. ef. 6-30-09; DEQ 8-2009, f. & cert. ef. 12-16-09; DEQ 

2-2010, f. & cert. ef. 3-5-10; DEQ 5-2010, f. & cert. ef. 5-21-10; DEQ 14-2010, f. & cert. 

ef. 12-10-10; DEQ 1-2011, f. & cert. ef. 2-24-11; DEQ 2-2011, f. 3-10-11, cert. ef. 3-15-

11; DEQ 5-2011, f. 4-29-11, cert. ef. 5-1-11; DEQ 18-2011, f. & cert. ef. 12-21-11; DEQ 

1-2012, f. & cert. ef. 5-17-12; DEQ 7-2012, f. & cert.ef 12-10-12; DEQ 10-2012, f. & 

cert. ef. 12-11-12; DEQ 4-2013, f. & cert. ef. 3-27-13; DEQ 11-2013, f. & cert. ef. 11-7-

13; DEQ 12-2013, f. & cert. ef. 12-19-13; DEQ 1-2014, f. & cert. ef. 1-6-14; DEQ 4-

2014, f. & cert. ef. 3-31-14; DEQ 5-2014, f. & cert. ef. 3-31-14; DEQ 6-2014, f. & cert. 

ef. 3-31-14; DEQ 7-2014, f. & cert. ef. 6-26-14; DEQ 6-2015, f. & cert. ef. 4-16-15; 

DEQ 7-2015, f. & cert. ef. 4-16-15
Medford Carbon Monoxide 

Limited Maintenance Plan

By: Oregon Department of Environmental Quality

December, 2015

DEQ Environmental 

Solutions

Air Quality Program

811 SW 6th Avenue

Portland, OR 97204

Phone: (503) 229-5519

(800) 452-4011

Fax: (503) 229-5675

Contact: Dave Nordberg

www.oregon.gov/DEQ

DEQ is a leader in 

restoring, maintaining and 

enhancing the quality of 

Oregon’s air, land and 

water.
State Implementation Plan Revision

Medford Carbon Monoxide Limited 

Maintenance Plan

A Limited Maintenance Plan

for Carbon Monoxide

The Medford Urban Growth Boundary

State of Oregon Clean Air Act 

Implementation Plan

Opened for public comment 

August 14, 2015

State of Oregon

Department of Environmental Quality

811 SW Sixth Avenue

Portland, OR 97204-1390
2015 Medford CO LMP

Page i

Table of Contents

Acknowledgments........................................................................................................................... ii

Executive Summary....................................................................................................................... iii

Plan Structure................................................................................................................................. iv

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

2. Geographic Area .........................................................................................................................1

3. History of CO Problem in Medford............................................................................................2

4. Limited Maintenance Plan Option..............................................................................................5

5. Emission Inventory .....................................................................................................................6

6. Continuing Control Measures...................................................................................................10

7. Verification of Continued Attainment ......................................................................................12

8. Contingency Plan......................................................................................................................12

Table of Figures

Figure 1. Medford Urban Growth Boundary ................................................................................. 2

Figure 2. Medford Carbon Monoxide Trend 2nd highest 8-hour average, 1977-2009................. 5

Figure 3. Medford UGB Annual CO Emissions Estimates, 1993 vs. 2008 ....................................... 7

Figure 4. Medford UGB Season Day CO Emissions Estimates, 1993 vs. 2008................................ 8

Figure 5. 2008 Medford Annual CO Emissions .............................................................................. 9

Figure 6. 2008 Medford Seasonal CO Emissions............................................................................ 9

Table of Tables

Table 1. Medford Carbon Monoxide Concentrations 1977-2009....................................................4

Table 2 Medford UGB 2008 CO Annual and Seasonal Emissions Inventory................................6

Appendices

Appendix 1: EPA 1995 Paisie Memo

Appendix 2: Medford 2008 Emission Inventory

Appendix 3: EPA 2012 Approval Letter for removal of the CO monitor and Justification for 

Discontinuation of Monitoring in Carbon Monoxide and PM10 Maintenance Areas

Appendix 4: Inventory Preparation and Quality Assurance Plan
2015 Medford CO LMP

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Acknowledgments

Principal Author: Dave Nordberg, DEQ Air Quality Planning 

Principal Contributors:

Oregon Department of Environmental Quality

David Collier Air Quality Planning Manager

Brian Finneran Air Quality Planning

Anthony Barnack Air Quality Planning

Jeffrey Stocum Air Quality Technical Services Manager

Wes Risher Air Quality Technical Services

Chris Swab Air Quality Technical Services

Brandy Albertson Air Quality Technical Services

Tom Carlson Sierra Research, Inc

Environmental Protection Agency

Claudia Vaupel EPA Region X

Bob Kotchenruther EPA Region X

Medford

Dan Moore Rogue Valley Council of Governments

Jonathan David Rogue Valley Council of Governments
2015 Medford CO LMP

Page iii

Executive Summary

Medford, Oregon violated the national air quality standard for carbon monoxide in the 1970s and 

1980s. Conditions have progressively improved and Medford has not violated the carbon 

monoxide (CO) standard since 1991. In 2001 Oregon submitted a ten-year CO Maintenance Plan 

to EPA and requested that Medford be redesignated to attainment. EPA approved the request as a 

revision to the State Implementation Plan (SIP) September 23, 2002. 

Oregon DEQ has now prepared this second ten-year CO Maintenance Plan that indicates how 

Medford will continue to maintain the CO standard through September 23, 2022--the end of the 

second maintenance plan period. Once adopted by the Oregon Environmental Quality 

Commission this plan will be submitted to the EPA as a further revision of the SIP.

High levels of CO have been traditionally caused by motor vehicles emissions. The improvement 

of CO concentrations over previous decades is largely due to modern vehicle emission control 

systems which have reduced CO emissions dramatically.Because CO is so low this plan qualifies 

to use a Limited Maintenance Plan (LMP) which streamlines requirements for SIP approval. This 

technique is available to maintenance areas that have a design value of no higher than 7.65 ppm 

which is 85 percent of the 8-hour CO standard. By comparison Medford has a design value of 

2.4 ppm or 27 percent of the standard. 

All maintenance plans including LMPs need to establish the relationship between CO emissions 

and measured ambient CO concentrations. To speed development of this plan, the Rogue Valley 

Council of Governments contracted with Sierra Research to do assemable much of the Medford 

CO Emissions Inventory. DEQ and Sierra Research began with the EPA’s 2008 National 

Emission Inventory (NEI) to quantify CO emissions in the Medford area. 

This plan retains the control and contingency measures from the first CO maintenance plan. The 

primary control measure has been the emission standards for new motor vehicles under the 

Federal Motor Vehicle Control Program. Another significnat measure that continues is the New 

Source Review Program with Best Available Control Technology (BACT).

Another requirement for a LMP is to maintain a method of determining if an area’s air quality 

degrades to the point where a violation could occur. Ambient CO concentrations in Medford 

declined to such low levels that the CO measurement equipment was removed in 2010. Because

the Medford CO monitor has been removed, DEQ uses an alternate method to verify that the 

area continues to attain the CO standard. This alternate method of tracking CO emissions will be 

revised in the proposed limited maintenance plan. DEQ calculates Medford’s CO emissions 

every three years through the Statewide Emission Inventory, which is submitted to EPA for 

inclusion in the National Emission Inventory. Under the new plan DEQ will evaluate any 

increase of Medford’s CO emissions to determine if that would trigger the Contingency Plan.

Control measures in the Contingency Plan include resuming testing CO concentrations in

Medford’s air, and if needed, forming an advisory committee to develop new strategies to 

prevent or correct any violation of the CO standard.
2015 Medford CO LMP

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Plan Structure

This SIP revision includes the compliance history for Medford and describes how the

area met and will continue to meet the standard. This document is organized as follows:

Section 1 – Introduction. Describes the purpose of this second maintenance plan, and summary 

on the CO standard. 

Section 2 – Geographic Area. Describes the geographic area covered by the maintenance plan,

Section 3 – History of the Carbon Monoxide Problem. Summarizes Medford CO compliance 

history and past CO monitoring data and trends.

Section 4 – Limited Maintenance Plan Option. Describes the criteria an area must meet to

qualify for this option and how Medford qualifies.

Section 5 – Emission Inventory. Includes historical information on the most significant CO 

emission categories from the original maintenance plan and an updated inventory on these

categories.

Section 6 – Continuing Control Measures. Lists the measures that were in the original CO 

maintenance plan, and how these measures will be continued under this LMP.

Section 7 – Verification of Continued Attainment. Describes how compliance will be tracked 

and confirmed.

Section 8 – Contingency Plan. Describes the contingency measures that apply should a violation 

occur in the future.

Appendices – Supporting documentation for this LMP. 
2015 Medford CO LMP

Page 1

1. Introduction

This State Implementation Plan revision documents that the area within the Medford Urban Growth 

boundary will continue to meet the National Ambient Air Quality Standard (NAAQS) for CO through 

2022. This plan also describes steps that must be taken if the area’s carbon monoxide concentrations 

deteriorate to an to an actionable level. This plan is a “limited maintenance plan” developed in 

accordance with the federal Clean Air Act and the policies of the U.S. Environmental Protection 

Agency (EPA). See the 1995 “Paisie Memo” provided in Appendix 1. 

The Clean Air Act requires EPA to set air quality standards to protect public health for six common 

air pollutants, including carbon monoxide. In 1971 EPA set the national ambient air quality standard 

for carbon monoxide. Carbon monoxide is a colorless, odorless gas that decreases the oxygen carrying 

capacity of the blood. High concentrations can severely impair the function of oxygen-dependent 

tissues, including the brain, heart, and muscle. Prolonged exposure to even low levels can aggravate 

existing conditions in people with heart disease or circulatory disorders. Motor vehicles are the 

primary source of CO in Oregon.

EPA established the national ambient air quality standard for CO at 35 parts per million (ppm) for a 1-

hour average and 9 ppm for an 8-hour average. Two exceedances within one calendar year constitute 

a violation. Like most areas of the country that failed to meet the CO standard, Medford failed to meet 

the 8-hour portion of the standard1

. 

2. Geographic Area

The City of Medford is located in southwestern Oregon, West of the Cascade Mountains in the Rogue 

River Valley. The city is approximately 26 square miles in area, and the population in 2013 was

77,677. The surrounding hills can trap air pollution under stable meteorological conditions 

(inversions). These conditions exist most frequently during the winter and were associated with the 

majority of past carbon monoxide violations. 

Figure 1 shows the Medford Urban Growth Boundary which is also the geographic area subject to this 

limited maintenance plan. 

 1 40CFR part 50.8 states that standards defined in parts per million should be compared “in terms of integers with 

fractional parts of 0.5 or greater rounding.” This led to an interpretation by EPA that any 8-hour CO concentration of less 

than 9.5 ppm would be equivalent to attainment. Therefore, concentrations at or above 9.5 ppm represent an exceedance 

of the standard. Two exceedances in one calendar year constitute a violation.
2015 Medford CO LMP

Page 2

Figure 1. Medford Urban Growth Boundary

3. History of CO Problem in Medford

History of CO in Medford Area/Design Values

The Medford area was designated by the Environmental Protection Agency (EPA) as a nonattainment 

area for carbon monoxide (CO) on March 3, 1978. On June 20, 1979 DEQ submitted a CO Control 

Strategy and requested an extension beyond 1982 to attain the CO standard. At that time the design 

value was 13.8 parts per million (ppm). EPA approved the 1979 plan and the extension, giving DEQ
2015 Medford CO LMP

Page 3

until December 31, 1987 to bring the Medford area into compliance. An updated control strategy was 

submitted in 1982 which was revised in 1985 to include a state-operated vehicle inspection program.

Following adoption of the 1990 Clean Air Act Amendments, EPA classified Medford as a moderate 

CO nonattainment area with a design value of 12.1 ppm. The CO nonattainment boundary was 

defined as the Medford, Oregon Urban Growth Boundary (UGB) used for comprehensive land use 

planning under state law. In 2001, DEQ demonstrated that Medford had attained the 8-hour CO 

standard with a design value of 7.5 ppm and submitted a maintenance plan showing how the area 

would continue to meet the CO standard into the future. EPA approved the maintenance plan and 

redesignated Medford to attainment for CO effective September 23, 2002.

Since then, CO concentrations continued to improve and CO monitoring was ended in 2010 followed 

by EPA’s approval of an alternate approach for tracking CO as shown in Appendix 3. Now DEQ is 

submitting a second CO maintenance plan with a design value of 2.4 ppm CO based on ambient 

monitoring from 2008 and 2009. This second CO plan is based on EPA guidance for limited 

maintenance plans as detailed by a memo from Joe Paisie dated October 6, 1995 and an email from 

Meg Patulski dated October 4, 2005.

Historically, several carbon monoxide monitoring sites in the Medford nonattainment area exceeded 

the 8-hour NAAQS for CO. Exceedances were recorded for approximately half of the year in the late 

1970s. However, because the control measures in the State Implementation Plan (SIP) were effective 

at reducing CO emissions, Medford air quality has met the CO standard since 1992. This is consistent 

with CO emission inventories from 1993 and 2008 which show that CO emissions in Medford 

continued to decline.
2015 Medford CO LMP

Page 4

Table 1. Medford Carbon Monoxide Concentrations 1977-2009

8-hour CO Averages

Year Maximum 2nd Highest

1977 21.8 17.3

1978 19.8 18.3

1979 16.2 13.8

1980 19.2 15.7

1981 14.9 14.5

1982 14.3 13.2

1983 15.8 12.6

1984 15.2 12.4

1985 16.9 16.3

1986 12.7 12.6

1987 12.9 9.7

1988 12.2 10.8

1989 12.2 12.1

1990 9.2 9.0

1991 11.9 10.5

1992 7.4 7.4

1993 8.5 7.5

1994 7.4 6.7

1995 6.1 6.0

1996 6.7 6.6

1997 7.3 5.7

1998 5.5 5.3

1999 6.8 6.1

2000 4.8 4.7

2001 4.8 4.6

2002 5.9 5.5

2003 5.0 4.7

2004 4.0 4.0

2005 4.4 3.8

2006 2.9 2.8

2007 3.1 2.7

2008 2.6 2.4

2009 2.4 2.4

(When multiple monitors operated in a given year, values shown are from the CO monitor with the 

highest second-high measurement.)
2015 Medford CO LMP

Page 5

Figure 2. Medford Carbon Monoxide Trend 2nd highest 8-hour average, 1977-2009

4. Limited Maintenance Plan Option

EPA developed the Limited Maintenance Plan (LMP) option for areas with little risk of re-violating 

the carbon monoxide standard (see 1995 Paisie Memo, Appendix 1). EPA allows states to use this 

policy to prepare the required second 10-year maintenance plans, if the monitoring data show the 

design value is at or below 85 percent of the 8-hour CO standard, or 7.65 ppm. Determining the 

design value in this case is based on the higher of the two annual second highs in a two year calendar 

period. The Medford 8-hour design value is 2.4 ppm, based on the two most recent years of data 

(2008 and 2009). This is 27 percent of the the 8-hour standard and far below the 85 percent level at 

which an area is eligible for the LMP option.

The LMP approach does not require future year emission projections or a maintenance demonstration. 

A LMP must include an attainment inventory, provisions for verification of continued attainment, a 

contingency plan and a statement regarding conformity determinations. Due to the low measured CO 

values in Medford over the past 22 years, DEQ does not anticipate that CO levels will approach levels 
2015 Medford CO LMP

Page 6

that would exceed or violate the 8-hour CO standard, and as noted above, the Medford area has never 

exceeded the 1-hour CO standard.

5. Attainment Emission Inventory

The Medford area has met the National Ambient Air Quality Standards (NAAQS) for carbon 

monoxide (CO) since 1991. In 2001 DEQ submitted the first Medford CO Maintenance Plan and 

requested that the area be redesignated to attainment. EPA approved that first Medford CO 

Maintenance Plan and redesignated the to attainment September 23, 2002. The current Emissions 

Inventory describes emissions for 2008, and is part of this proposed second limited maintenance plan 

showing that the area will continue to comply with EPA requirements. The principal components 

addressed in this inventory include stationary point sources, stationary area sources, non-road sources, 

on-road mobile sources, quality assurance implementation, and emissions summaries. The geographic 

focus for this 2008 emission inventory is the Medford CO Maintenance Area, which is defined as the 

Medford Urban Growth Boundary (UGB) plus emissions from industrial sources within 25 miles.

The following table summarizes contributions by source category. Emissions are reported for two 

time periods: annual emissions (in units of tons per year) and seasonal emissions (in units of pounds 

per day). A detailed breakdown of the 2008 CO emission inventory is provided in Appendix 2. 

Table 2. Medford UGB 2008 CO Annual and Seasonal Emissions Inventory

Annual CO Season

Source Type tpy % of Category lbs/day % of Category

Stationary Point Sources 2,376.1 15% 13,159 16%

Stationary Area Sources 3,333.1 21% 30,399 37%

Non-Road Mobile Sources 4,488.2 28% 10,061 12%

On-Road Mobile Sources 5,730.0 36% 28,731 35%

Total within Medford UGB 15,927.4 100% 82,350 100%

Using the MOVES 2010b emission factor model for an average CO season 2008 day, on-road mobile 

sources contribute 35% of the total CO air emissions in the Medford UGB. Gasoline vehicles 

contribute 97% of the CO emissions within the on-road mobile category, whereas diesel vehicles 

contribute 3% of the on-road mobile category.

Stationary area sources comprise 37% of the total CO air emissions in the Medford UGB on a CO 

season day. Within the area source category, residential wood combustion accounts for 49% of the 

emissions. Wood combustion in non-certified woodstoves and inserts accounts for 28% of the total 
2015 Medford CO LMP

Page 7

area source emissions. Prescribed burning accounts for 47% of the total area source emissions on a 

CO season day.

Non-road mobile sources contribute 12% of the total CO on an average CO season day. Within this 

category, 4-cycle engines comprise 79% of the total emissions.

Permitted stationary point sources comprise 16% of the CO air emissions in the Medford UGB on an 

average CO season day. This category includes permitted stationary sources with both federal Title V 

and state Air Contaminant Discharge Permits. There are 37 point sources within the Medford UGB 

and a 25-mile buffer zone around the UGB.

Emissions summaries for CO have decreased for both annual and season day as compared to the 1993 

attainment year EI. Annual emissions have decreased 24%, and seasonal emissions have decreased

27% compared to the 1993 attainment year EI.

Figure 3. Medford UGB Annual CO Emissions Estimates, 1993 vs. 2008

4,835

2,376

2,168

3,333

2,651 4,488

11,435

5,730

0

5,000

10,000

15,000

20,000

25,000

1993 2008

Emissions (tpy)

On-road Mobile

Nonroad Sources

Area Sources

Permitted Point 

Sources
2015 Medford CO LMP

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Figure 4. Medford UGB Season Day CO Emissions Estimates, 1993 vs. 2008

Details of the Oregon 2008 Medford UGB CO Limited Maintenance Plan Emission Inventory from 

point, area, non-road, and on-road mobile sources are presented in the full emission inventory 

included as Appendix 2. The amount of annual and seasonal CO emissions from stationary point, 

stationary area, non-road mobile, and on-road mobile sources are shown in Figures 3 and 4.

28,516

13,159

19,748

30,399

6,536

10,061

57,342

28,731

0

20,000

40,000

60,000

80,000

100,000

120,000

1993 2008

Emissions (lbs/day)

On-road Mobile

Nonroad Sources

Area Sources

Permitted Point 

Sources
2015 Medford CO LMP

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Figure 5. 2008 Medford Annual CO Emissions

Figure 6. 2008 Medford Seasonal CO Emissions

0

2,000

4,000

6,000

Stationary 

Point 

Sources

Stationary 

Area 

Sources

Non-Road 

Mobile 

Sources

On-Road 

Mobile 

Sources

CO Emissions, tpy

0

15,000

30,000

45,000

Stationary 

Point 

Sources

Stationary 

Area 

Sources

Non-Road 

Mobile 

Sources

On-Road 

Mobile 

Sources

CO Emissions, lbs/day
2015 Medford CO LMP

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6. Continuing Control Measures

To qualify for the LMP option, the plan must include all control measures that were relied on to 

demonstrate attainment of the NAAQS. The primary control measure has been the emission standards 

for new motor vehicles under the Federal Motor Vehicle Control Program. Other control measures 

have been the Motor Vehicle Inspection program, New Source Review program and a Woodstove 

Curtailment program. 

Federal Motor Vehicle Emission Control Program

This limited maintenance plan continues to rely on federal emission standards for new motor vehicles. 

These requirements include the federal Tier II emission standards for new light and medium duty cars 

and trucks as well as standards for heavy duty on-road and non-road vehicles. 

As noted in Table 2 above, on-road mobile sources are responsible for the highest annual CO 

concentrations in Medford. That is because cars and trucks moving through an area can assemble in 

significant numbers at areas of heavy traffic. The highest CO concentrations typically occur in a small 

region near a congested intersection as CO dissipates quickly as it moves away from its point of 

emission.

Emission reductions mandated by the Federal Motor Vehicle Emission Control Program have been 

primarily responsible for the large decrease in ambient CO concentrations in the past. Before CO 

emissions were regulated, a typical car of the 1950s emitted approximately 87 grams of CO per mile. 

Since then, federal rules have lowered CO emissions to the point where today’s federal Tier II 

requirements limit cars to no more than 3.4 grams CO per mile - a 95% reduction of CO. This 

program will continue to be an effective control for on-road mobile source emissions in the future. 

Major New Source Review

Under this limited maintenance plan, the emission control requirement for new or expanding major 

industry in Medford area will continue to require Best Available Control Technology (BACT). BACT 

technology provides a high level of control while allowing some flexibility and consideration of the 

cost effectiveness of different control options.

Motor Vehicle Inspection Program

Oregon’s Vehicle Inspection Program (VIP) will continue to operate in the Medford area. Gasoline 

and light duty diesel vehicles up to 20 years old that are registered in the Medford-Ashland Air 

Quality Maintenance Area will continue to be subject to emissions testing and inspection when 

vehicle registrations are renewed. This program has operated since 1986 and has effectively reduced 

CO emissions by promoting proper vehicle maintenance.
2015 Medford CO LMP

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Woodsmoke Curtailment

As noted in the previous section, residential wood combustion is a leading source of CO emissions 

from stationary area sources. However these sources of DO emissions are distributed widely and do 

not concentrate as on-road CO emissions can. These emission sources do not move and therefore 

contribute to a diffuse, low-level background concentration of CO. As shown in Table 2, stationary 

area sources represent 21 percent of the total annual and 37 percent of seasonal CO emissions in

Medford. Woodsmoke emission control efforts have significantly reduced emissions through emission 

certification standards for new stoves, woodstove change-out programs to encourage removal of noncertified stoves, and a local voluntary curtailment program to reduce wood burning during stagnant 

weather periods. These efforts will be continued under this limited maintenance plan, and are 

expected to provide modest reductions in CO emissions in Medford. 

Conformity requirements

Federal transportation conformity rules (40 CFR 51.390 and 93.100 et. seq.) and general conformity

rules (40 CFR 51.851 and 93.150 et. seq.) continue to apply under a limited maintenance plan. 

However, as noted in the Paisie Memo these requirements are greatly simplified. Under a LMP 

vehicle emissions are not considered to be constraining so a Motor Vehicle Emissions Budget is not 

required. During future transportation conformity determinations, regional emissions analyses are not 

required (including modeling) as vehicle emissions are assumed to comply.2

 2 See Paise Memo in Appendix 1 for additional information on conformity requirements. 
2015 Medford CO LMP

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7. Verification of Continued Attainment

As described in this plan, CO levels in the Medford UGB have declined progressively since 1991. CO 

concentrations are not expected to increase significantly or threaten compliance with the CO standard. 

Because the Medford CO monitor was removed after 2009, DEQ implemented an alternate method of 

verifying continued attainment with the CO standard.

The proposed limited maintenance plan will change the way Medford’s continued attainment is 

verified. DEQ will calculate CO emissions every three years as part of the Statewide Emission 

Inventory, which is submitted to EPA for inclusion in the National Emission Inventory (NEI). DEQ 

will review the NEI estimates to identify increases over the 2008 emission levels and report on them 

in the annual network plan for the applicable year. Because on-road motor vehicles and stationary 

area sources emit the most CO in Medford, these categories will be the focus of this review. Any 

increase in CO emissions will be evaluated by DEQ to verify it is not due to a change in emission 

calculation methodology, an exceptional event, or other factor not representative of an actual 

emissions increase. DEQ will consider a 10 percent increase over 2008 emission levels to be a 

“significant” emission increase for the purpose of triggering the Contingency Plan described in 

Section 8. Emission categories to be assessed for a significant increase are the total annual emissions, 

total seasonal emissions, annual or seasonal on-road emissions plus annual or seasonal area source 

emissions.

8. Contingency Plan

Section 175(A) of the Clean Air Act requires a maintenance plan to include contingency measures 

necessary to ensure prompt correction of any future violation of the the air quality standard. The first

Medford maintenance plan contained contingency measures that would be implemented based on 

monitoring data--if CO concentrations exceeded 90 percent of the 8-hour standard (8.1 ppm) or if a 

violation of the standard were to occur. After the Medford CO monitor was removed in 2009, an 

alternate method of triggering the contingency measures was implemented.

Under the proposed limited maintenance plan a different Contingency Plan will apply. The new plan

has three levels of action depending on the severity of the circumstances:

Phase 1. If DEQ’s three-year periodic review of CO emissions shows a significant increase in 

emissions, as described in Section 7 of this plan, DEQ will resume monitoring ambient CO in

Medford. 

Phase 2. If the highest measured 8-hour CO concentration in a given year in Medford exceeds 7.65 

ppm (the level at which an area is eligible for a Limited Maintenance plan), DEQ will evaluate the 

cause of the CO increase, and consider forming an advisory committee to recommend corrective 

strategies. Within 6 months of the validated 7.65 ppm or higher CO concentration, DEQ will prepare 
2015 Medford CO LMP

Page 13

a list of strategies to prevent or correct a violation of the 8-hour CO standard. This list is to facilitate a

choice of strategies that might be implemented to reduce ambient CO concentrations. 

The contingency strategies that will be considered include, but are not limited to:

• Improvements to parking and traffic circulation

• Aggressive signal retiming program

• Increased transit funding

• More stringent vehicle Inspection/Maintenance requirements, and

• Accelerated bicycle and pedestrian improvements.

DEQ (and the advisory group if needed) may also choose to conduct further evaluation, to determine 

if other strategies are necessary, or to take no further action if the problem was caused by an 

exceptional event. 

Phase 3. If a violation of the CO standard occurs, and is validated by DEQ, in addition to Phase 2 

above, DEQ will replace the requirement for new and expanding industry to apply Best Achievable 

Control Technlogy (BACT) with the requirement to apply Lowest Achievable Emission Rate (LAER)

technology. In addition, DEQ will reinstate the requirement for new and expanding industry to offset 

any new CO emissions. More CO emission reduction measures identified in the evaluation of 

contingency Phase 2 may also be considered. Committing to further study in this way gives DEQ 

flexibility in choosing an appropriate approach should the need arise.
Appendix 1 - EPA 1995 Paisie Memo




Appendix 2 - 2015 Medford CO LMP

Page i

(DRAFT)

Appendix 2 To

Medford 2015 CO Limited Maintenance Plan

2008 Year Emission Inventory

For Carbon Monoxide (CO)

Medford Urban Growth Boundary

June 2015

Oregon Department of Environmental Quality

Environmental Solutions Division

Air Quality Technical Services Section

811 SW 6th Avenue

Portland, Oregon 97204
Appendix 2 - 2015 Medford CO LMP

Page ii

Table of Contents

Table of Contents.................................................................................................................. ii

Table of Figures..................................................................................................................... v

Table of Tables......................................................................................................................vi

1 Executive Summary......................................................................................................... 2

2 Introduction.................................................................................................................... 6

2.1 Purpose of the Report..................................................................................................... 6

2.2 Inventory Time Frame and Area Covered....................................................................... 6

2.3 Report Contents.............................................................................................................. 9

2.4 Automated Systems...................................................................................................... 10

2.5 Sources Not Inventoried ............................................................................................... 10

2.6 Guidance Documents.................................................................................................... 10

2.7 Contact Personnel......................................................................................................... 11

3 Medford Carbon Monoxide Attainment Area Inventory................................................. 13

3.1 Inventory Area Maps and Descriptions ........................................................................ 13

3.1.1 Inventory Area Maps .............................................................................................. 13

3.1.2 Legal Descriptions................................................................................................... 17

3.1.2.1 Legal Description of Medford Urban Growth Boundary / CO Inventory Area

17

3.1.2.2 Legal Description of Open Burning Control Areas........................................ 18

3.1.2.3 Legal Description of Medford Area Woodstove Curtailment Ordinance / 

Critical PM10 Control Area ............................................................................................... 19

3.1.2.4 Legal Description of the Medford-Ashland Air Quality Maintenance Area / 

Vehicle Inspection Program Boundary ............................................................................. 19

3.2 Summary of Emissions Data.......................................................................................... 20

3.3 Stationary Permitted Point Sources.............................................................................. 23

3.3.1 Introduction ............................................................................................................ 23

3.3.2 Geographic Area and Sources Included.................................................................. 23

3.3.3 Point Source Determination ................................................................................... 23

3.3.3.1 2008 Point Source Determination ................................................................ 24

3.3.4 Methodology and Approach................................................................................... 25

3.3.4.1 Data Collection.............................................................................................. 25

3.3.4.2 Emission Basis............................................................................................... 25

3.3.4.3 Activity Data.................................................................................................. 25
Appendix 2 - 2015 Medford CO LMP

Page iii

3.3.4.4 Plant Site Emission Limits (PSELs)................................................................. 26

3.3.4.5 Annual Emissons Calculations....................................................................... 26

3.3.4.5.1 Emissions Estimation Methodologies for TV Sources................................. 26

3.3.4.5.2 Emissions Estimation Methodlogies for ACDP Sources.............................. 26

3.3.4.6 Seasonal Emissions Calculations................................................................... 27

3.3.4.6.1 Seasonal Adjustment Factors...................................................................... 27

3.3.4.6.2 Season Day Emissions Calculations............................................................. 27

3.3.5 Summary of Stationary Point Source Emissions..................................................... 29

3.3.6 Control Efficiency (CE) and Rule Effectiveness (RE)................................................ 30

3.4 Stationary Nonpoint (Area) Sources............................................................................. 31

3.4.1 Introduction and Scope........................................................................................... 31

3.4.2 Methodology and Approach................................................................................... 31

3.4.2.1 Source Category Identification and General Methodology Overview ......... 31

3.4.2.2 Reconciliation with Point Source Emissions (double count prevention)...... 32

3.4.3 Discussion of Area Source Categories..................................................................... 32

3.4.3.1 Waste Disposal, Treatment and Recovery.................................................... 32

3.4.3.1.1 Incineration ................................................................................................. 32

3.4.3.1.1.1 Industrial Incineration........................................................................................32

3.4.3.1.1.2 Commercial/Institutional Incineration ..............................................................33

3.4.3.1.1.3 Residential Incineration.....................................................................................33

3.4.3.1.2 Open Burning .............................................................................................. 33

3.4.3.1.2.1 Industrial Open Burning.....................................................................................33

3.4.3.1.2.2 Commercial/Institutional Open Burning............................................................33

3.4.3.1.2.3 Residential Open Burning (back yard burning)..................................................34

3.4.3.2 Small Stationary Fossil Fuel and Wood Use.................................................. 35

3.4.3.2.1 Fuel Oil Combustion.................................................................................... 35

3.4.3.2.2 Natural Gas (NG) and Liquified Petroleum Gas (LPG)................................. 36

3.4.3.2.3 Coal and Biomass Combustion.................................................................... 37

3.4.3.3 Residential Wood Combustion ..................................................................... 38

3.4.3.4 Miscellaneous Area Sources......................................................................... 38

3.4.3.4.1 Forest Wildfires........................................................................................... 38
Appendix 2 - 2015 Medford CO LMP

Page iv

3.4.3.4.2 Prescribed Burning...................................................................................... 38

3.4.3.4.3 Structure Fires............................................................................................. 39

3.5 Nonroad Vehicles and Equipment................................................................................ 55

3.5.1 Introduction and Scope........................................................................................... 55

3.5.2 Nonroad Vehicles and Equipment.......................................................................... 55

3.5.2.1 Vehicle Categories ........................................................................................ 55

3.5.2.2 Methodology................................................................................................. 55

3.5.3 Aircraft and Airport Operations Emissions............................................................. 56

3.5.4 Waterborne Vessels................................................................................................ 56

3.5.5 Rail........................................................................................................................... 56

3.6 On-Road Mobile Sources.............................................................................................. 72

3.6.1 Introduction and Scope........................................................................................... 72

3.6.2 Spatial and Temporal Allocation of 2008 NEI Data................................................. 72

3.6.2.1 Spatial Allocation .......................................................................................... 72

3.6.2.2 Temporal Allocation...................................................................................... 72

3.6.3 Summary of On-Road Mobile Source Emissions .................................................... 72

4 Quality Assurance and Quality Control .......................................................................... 78

4.1 Introduction .................................................................................................................. 78

4.2 Organization and Personnel.......................................................................................... 78

4.3 Data Collection and Analysis......................................................................................... 79

4.3.1 Data Collection and Analysis................................................................................... 79

4.4 DATA HANDLING........................................................................................................... 79

4.5 Data Coding and Recording .......................................................................................... 79

4.6 Data Tracking ................................................................................................................ 79

4.7 QA/QC Procedures - Checking and Correcting ............................................................. 80

4.7.1 Checking Data ......................................................................................................... 80

4.7.1.1 Inventory Completeness............................................................................... 80

4.7.1.2 Missing Data.................................................................................................. 80

4.7.1.3 Incorrect Calculations................................................................................... 80

4.7.1.4 Incorrect Information ................................................................................... 81

4.7.1.5 Reasonableness............................................................................................. 81

4.7.1.6 Emissions Summary Reasonableness ........................................................... 81
Appendix 2 - 2015 Medford CO LMP

Page v

4.8 Data Reporting.............................................................................................................. 81

5 References.................................................................................................................... 82

6 Appendices to the Emission Inventory........................................................................... 84

Table of Figures

Executive Summary, Figure 1: 2008 Medford UGB annual CO emissions, percentage by source category 3

Executive Summary, Figure 2: 2008 Medford UGB CO season day emissions, percentage by source 

category ........................................................................................................................................................3

Executive Summary, Figure 3: Medford UGB Annual CO Emissions Estimates, 1993 vs. 2008....................4

Executive Summary, Figure 4: Medford UGB Season Day CO Emissions Estimates, 1993 vs. 2008.............5

Figure 1: Medford Urban Growth Boundary ................................................................................................7

Figure 2: 2008 Medford CO LMP, 25-mile buffer and permitted point source locations.............................8

Figure 3: Open Burning Control Areas and Rogue Basin Open Burning Control Area................................14

Figure 4: Woodstove Curtailment Ordinance Area / Critical PM10 Control Area .......................................15

Figure 5: Medford-Ashland Air Quality Maintenance Area / Vehicle Inspection Program Boundary........16

Figure 6: Distribution of 2008 Annual CO Emissions ..................................................................................20

Figure 7: Annual CO Emissions by Percentage............................................... Error! Bookmark not defined.

Figure 8: Distribution of 2008 Season Day CO Emissions...........................................................................21

Figure 9: Season Day CO Emissions by Percentage.....................................................................................21

Figure 10: 2008 Commercial Open Burning Locations................................................................................34

Figure 11: 2008 Residential Open Burning Locations.................................................................................35

Figure 12: Area Source Annual Emissions by Percentage...........................................................................40

Figure 13: Area Source Season Day Emissions By Percentage....................................................................40

Figure 14: Distribution of Medford UGB Annual Nonroad Source CO Emissions, 2008.............................58

Figure 15: Percentage of Medford Annual Nonroad CO Source Emissions, 2008......................................58

Figure 16: Distribution of Medford CO Season Day Nonroad Source Emissions, 2008..............................59

Figure 17: Percentage of Medford UGB CO Season Day Nonroad Source Emission, 2008 ........................59

Appendix A, Figure A- 1: 2008 Medford CO LMP Permitted Point Source Locations.................................86

Appendix B, Figure B- 1: Wildfire and Prescribed Burn Location and Date................................................92
Appendix 2 - 2015 Medford CO LMP

Page vi

Table of Tables

Executive Summary, Table 1 Medford UGB 2008 Estimated CO Emissions Contribution by Source 

Category........................................................................................................................................................2

Table 2.1: Summary of 2008 CO Emissions Data ........................................................................................22

Table 2.3. 1: 1993 Attainment Year Inventory List of Permitted Point Sources.........................................24

Table 2.3. 2: Medford UGB CO Season: Summary of Point Source Emissions by SIC.................................29

Table 2.3. 3: Medford UGB CO Season, Summary of Top 5 :Point Source Emitters...................................30

Table 2.4. 1: Medford 2008 CO EI Summary of Estimation Procedures for Area Sources .........................41

Table 2.4. 2: Medford 2008 CO EI Summary of Emissions Estimates for Area Sources .............................41

Table 2.4. 3: Area Source Emissions From Fuel Oil Use..............................................................................42

Table 2.4. 4: Area Source Emissions From Natural Gas (NG) Use...............................................................43

Table 2.4. 5: Area Source Emissions From Liquified Petroleum Gas (LPG) Use..........................................45

Table 2.4. 6: Area Source Emissions From Residential Wood Combustion................................................47

Table 2.4. 7: Area Source Emissions From Wildfires...................................................................................48

Table 2.4. 8: Area Source Emissions From Prescribed (RX) Burning...........................................................49

Table 2.4. 9: Area Source Emissions From Structure Fires .........................................................................50

Table 2.4. 10: Area Source Emissions From Residential Open Burning ......................................................51

Table 2.4. 11: Area Source Emissions From Industrial Open Burning.........................................................52

Table 2.4. 12: Area Source Emissions From Commercial/Institutional Open BUrning...............................52

Table 2.4. 13: Area Source Emissions From Coal Use .................................................................................53

Table 2.4. 14: Area Source Emissions From Biomass Burning ...................................................................54

Table 2.5. 1: Medford UGB 2008 CO Summary of Emissions from Nonroad Sources................................60

Table 2.5. 2: Medford UGB 2008 CO, Summary of Emissions from Nonroad Gasoline Vehicles * 

Equipment, 2-Cycle.....................................................................................................................................61

Table 2. 5. 3. 2008 Medford UGB CO: Summary of Emissions from Nonroad Gasoline Vehicles and 

Equipment, 4-Cycle.....................................................................................................................................63

Table 2. 5. 4. 2008 Medford UGB CO: Summary of Emissions from Nonroad CNG/LPG Vehicles and 

Equipment...................................................................................................................................................65

Table 2. 5. 5. 2008 Medford UGB CO: Summary of Emissions from Nonroad Diesel Vehicles and 

Equipment...................................................................................................................................................67

Table 2.5. 6. 2008 Medford UGB CO: Summary of Emissions from Aircraft and Airport GSE....................69

Table 2.5. 7. 2008 Medford UGB CO: Summary of Emissions from Railroads............................................71

Table 2.6. 1. 2008 Medford UGB CO: Summary of On-Road Mobile Emissions by Vehicle Type..............75

Table 2.6. 2. 2008 Medford UGB CO: Summary of On-Road Mobile Emissions by Road Type ..................77

Appendix A, Table A- 1: Stationary Point Source Determination for 2008 CO Inventory ..........................87

Appendix A, Table A- 2: Exclusion of 1993 and some 2008 Facilities from CO Emission Inventory...........87

Appendix A, Table A- 3: Stationary Point Source Emission Estimation Details...........................................89

Appendix B, Table B- 1: GIS Allocation Results: Josephine County Zones, County-Wide and by UGB......93
Appendix 2 - 2015 Medford CO LMP

Page ii

1 Executive Summary

The Medford Carbon Monoxide (CO) Maintenance Area has met the National Ambient Air 

Quality Standards (NAAQS) for carbon monoxide. In accordance with the 1990 Federal Clean 

Air Act Amendments, the area has been redesignated to attainment status through the 

development of a Redesignation Request / Maintenance Plan. This limited maintenance plan 

inventory is for 2008, and is provided as part of the maintenance plan package to show 

compliance with published EPA requirements. The principal components for development and 

documentation that have been addressed in this inventory include stationary point sources, 

stationary area sources, non-road sources, on-road mobile sources, quality assurance 

implementation, and emissions summaries. The geographic focus for this 2008 emission 

inventory is the Medford CO Maintenance Area, which is defined as the Medford Urban

Growth Boundary (UGB).

The following table summarizes contributions by source category for annual and seasonal CO 

emissions within the Medford UGB for 2008.

Executive Summary, Table 1 Medford UGB 2008 Estimated CO Emissions Contribution by 

Source Category.

Annual CO Season

Source Type tpy % of Category lbs/day % of Category

Stationary Point Sources 2,376.1 15% 13,159 16%

Stationary Area Sources 3,333.1 21% 30,399 37%

Non-Road Mobile Sources 4,488.2 28% 10,061 12%

On-Road Mobile Sources 5,730.0 36% 28,731 35%

Total within Medford UGB 15,927.4 100% 82,350 100%

During the average CO season 2008 day, on-road mobile sources contribute 35% of the total 

carbon monoxide (CO) air emissions in the Medford UGB. Gasoline vehicles contribute 97% of 

the CO emissions within the on-road mobile category, whereas diesel vehicles contribute 3% of 

the on-road mobile category.

Stationary area sources comprise 37% of the total CO air emissions in the Medford UGB on a CO 

season day. Within the area source category, residential wood combustion accounts for 49% of 

the emissions. Wood combustion in non-certified woodstoves and inserts accounts for 28% of
Appendix 2 - 2015 Medford CO LMP

Page 2

the total area source emissions. Prescribed burning accounts for 47% of the total area source 

emissions on a CO season day.

Non-road mobile sources contribute 12% of the total CO on an average winter day. Within this 

category, 4-cycle engines comprise 79% of the total emissions.

Permitted stationary point sources comprise 16% of the CO air emissions in the Medford UGB 

on an average CO season day. This category includes permitted stationary sources with both 

federal TV and state ACDP permits. There are 37 point sources within the Medford UGB and a 

25-mile buffer zone around the UGB.

Emissions summaries for CO have decreased for both annual and season day as compared to 

the 1993 attainment year EI. Emissions have decreased 24% annually, and 27% for a season 

day as compared to the 1993 attainment year EI.

Details of the Oregon 2008 Medford UGB CO Limited Maintenance Plan Emission Inventory 

from point, area, non-road, and on-road mobile sources are presented in the following 

document. The relative percentage of annual and seasonal CO emissions from stationary point, 

stationary area, non-road mobile, and on-road mobile sources are shown in the Executive 

Summary Figures 1 through 4
Appendix 2 - 2015 Medford CO LMP

Page 3

Executive Summary, Figure 1: 2008 Medford UGB annual CO emissions, percentage by source 

category

Executive Summary, Figure 2: 2008 Medford UGB CO season day emissions, percentage by 

source category

Stationary 

Point Sources

14%

Stationary 

Area Sources

26%

Non-Road 

Mobile 

Sources

26%

On-Road 

Mobile 

Sources

34%

Stationary 

Point Sources

16%

Stationary 

Area Sources

37%

Non-Road 

Mobile 

Sources

12%

On-Road 

Mobile 

Sources

35%
Appendix 2 - 2015 Medford CO LMP

Page 4

Executive Summary, Figure 3: Medford UGB Annual CO Emissions Estimates, 1993 vs. 2008

4,835

2,376

2,168

3,333

2,651

4,488

11,435

5,730

0

5,000

10,000

15,000

20,000

25,000

1993 2008

Emissions (tpy)

On-road Mobile

Nonroad Sources

Area Sources

Permitted Point 

Sources
Appendix 2 - 2015 Medford CO LMP

Page 5

Executive Summary, Figure 4: Medford UGB Season Day CO Emissions Estimates, 1993 vs. 

2008

28,516

13,159

19,748

30,399

6,536

10,061

57,342

28,731

0

20,000

40,000

60,000

80,000

100,000

120,000

1993 2008

Emissions (lbs/day)

On-road Mobile

Nonroad Sources

Area Sources

Permitted Point 

Sources
Appendix 2 – 2015 Medford CO LMP

6

2 Introduction

2.1 Purpose of the Report

The Clean Air Act Amendments (CAAA) of 1990 authorized the U.S. Environmental Protection 

Agency (EPA) to designate nonattainment areas with respect to the National Ambient Air 

Quality Standards (NAAQS). Under the 1990 CAAA, pre-enactment carbon monoxide 

nonattainment areas were classified according to the severity of nonattainment. Each state 

was required to submit a list designating nonattainment areas within the state.

Oregon submitted a list of areas that were in nonattainment to EPA on 15 March 1991. The 

area within the Medford Urban Growth Boundary was listed as nonattainment for carbon 

monoxide (Medford UGB / NAA). The nonattainment area had a design value of 7.5 parts per 

million (ppm) for carbon monoxide, and exceeded the NAAQS in the period 1977 through 1991. 

The NAAQS limit is 9 ppm, but it must reach 9.5 ppm to be considered an exceedance. The 

highest recorded CO value measured in Medford was 21.8 ppm at the Brophy building site in 

1977. Previous nonattainment boundaries included the entire Medford Air Quality 

Maintenance Area (AQMA) under former Governor Straub in 1978. Due to hot spot problems 

within the downtown region of Medford in 1982, the nonattainment area was revised to 

include only the central business district. The nonattainment area was again modified in 1992 

when the Federal Register promulgated the designation of the Medford UGB / NAA as 

nonattainment for CO on November 30, 1992 by letter from Governor Roberts.

The emission inventory area for the Medford CO nonattainment area was delineated as the 

Medford UGB in the Inventory Preparation Plan (IPP) submitted September 15, 1997. The 

Oregon CO IPP was approved by EPA Region X on June, 10, 1998 by letter from Joan Cabreza. 

This document fulfills the EPA requirements for preparing the limited maintenance plan 2008

year emission inventory, specified in the provisions of the 1990 CAAA, and EPA guidance 

documents.

2.2 Inventory Time Frame and Area Covered

The 2008 limited maintenance plan inventory covers carbon monoxide emissions for the 

Medford Urban Growth Boundary (UGB) maintenance area. 2008 was chosen as the bse year 

because it is the most recent National Emission Inventory (NEI) year for which the DEQ has 

PM2.5 monitoring data for the Medford area. Emissions are reported in this inventory for two 

representative time periods: Annual Emissions (in units of “tons per year”) and Seasonal 

Emissions (in units of “pounds per day”). Annual emissions represent CO emissions generated 

over the 2008 Maintenance Year. Seasonal emissions represent CO emissions generated on an 

average day in a three-month period - called the CO season - when ambient CO accumulations 

are typically the highest. For the Medford UGB, the CO Season is defined as the period of three 

consecutive months: December through February.
Appendix 2 – 2015 Medford CO LMP

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The geographic area of the Medford UGB is shown in Figure 1. Figure 2 shows boundaries used 

for the permitted point source section of the 2008 emission inventory. As in the 1993 

attainment year inventory, a 25-mile buffer zone is the starting point for point source boundary 

definition. The 25-mile extension to the UGB area includes incorporated and unincorporated 

Jackson County and a part of Josephine County. Populated areas within the 25 mile buffer 

included in this inventory are Medford, Rogue River, Grants Pass, and White City.

Figure 1: Medford Urban Growth Boundary
Appendix 2 – 2015 Medford CO LMP

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Figure 2: 2008 Medford CO LMP, 25-mile buffer and permitted point source locations
Appendix 2 – 2015 Medford CO LMP

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2.3 Report Contents

The Report is divided into the following components:

Part 1: Introduction to the Report

Part 2: Medford CO 2008 Limited Maintenance Plan Emission Inventory

Part 3: Quality Assurance and Quality Control

Part 4: References

Part 5: Appendices

 Part 1 provides an introduction to this Report and its purpose. Contents of the Report are 

briefly described. Information concerning automated systems is included. Sources not 

inventoried for the inventory are described along with a rationale for the exclusions. EPA 

procedure and guidance documents used in preparing the inventory are described. Finally, 

information on the personnel responsible for the preparation of the inventory is outlined.

 Part 2 describes in detail the methodologies and approaches taken to estimate emissions in 

the Medford UGB for the 2008 Limited Maintenance Plan inventory. Part 2 is divided into 

sections describing the inventory process and the types of emission sources that are 

addressed in the inventory, as follows:

 Section 1.0 provides maps of open burning control areas and the MedfordAshland Air Quality Maintenance Area / Vehicle Inspection Boundary. These 

maps are included for consistency with the 1993 Medford CO Attainment 

Year Inventory. This section also provides legal descriptions of the inventory 

and open burning control areas, as well as the AQMA/VIP boundary.

 Section 2.0 contains summary tables for stationary point, stationary area, 

non-road mobile, and on-road mobile sources in the Medford UGB.

 Section 3.0 contains a discussion of the stationary point source emission 

category methodology and emissions estimate approach. Tables 

summarizing point source emissions estimates follow the discussion.

 Section 4.0 addresses stationary area sources and contains a discussion of 

the approaches used in estimating emissions. Each area source category 

inventoried is described in detail, including the methodology used in making 

the calculations. Tables summarizing stationary area source emissions 

estimates follow the discussion.

 Section 5.0 provides a discussion of the approach and methodology used in 

evaluating emissions from non-road mobile sources. Tables summarizing 

non-road mobile source emissions estimates follow the discussion.
Appendix 2 – 2015 Medford CO LMP

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 Section 6.0 provides a description of the approach and methodology used in 

evaluating emissions from on-road mobile sources. Tables summarizing onroad mobile source emissions estimates follow the discussion.

 Part 3 describes the quality assurance procedures utilized in preparing the 2008 inventory.

 Part 4 contains an extensive list of references utilized for the Medford CO emission 

inventory.

 Part 5 contains Appendices with supplemental data used to estimate emissions. 

Tables and figures for each emission category are located at the end of the discussion section 

for that category. For example, summary emission tables for all stationary point source types in

the Medford UGB are located at the end of Part 2, Section 3. Please note that some references 

listed in the tables are numbered as ‘DEQ master references’ (See Part 5 for this classification at 

the end of each entry).

2.4 Automated Systems

The inventory has been assembled by the staff of the Technical Services Section, Air Quality 

Division of the Oregon Department of Environmental Quality (DEQ), and by Sierra Research, a 

consulting firm specializing in air quality and pollution control. The point source emissions are 

specifically drawn from the DEQ Tracking Reporting and Administration of Air Contaminant 

Sources (TRAACS) database. The TRAACS data is used for tracking compliance with plant site 

emission limits and for reporting compliance status to the EPA EIS system. TRAACS is also used 

to store actual emission data also reported to EIS. TRAACS contains annual emission levels for 

each permitted point source as well as, emission factors, and annual activity levels (fuel use and 

production levels). Nonpoint emissions, except where indicated, were extracted from the EPA 

Emission Inventory System (EIS) EIS Gateway. The EPA EIS database houses National Emissions 

Inventory (NEI) data that includes submittals from states.

2.5 Sources Not Inventoried

For consistency, the 1993 attainment year emission inventory was used as a reference, and all 

sources in the 1993 inventory are addressed in the 2008 inventory. Calculations and 

methodology for sources emitting 0 emissions during a typical CO season day are included in 

the 2008 inventory as well.

2.6 Guidance Documents

For consistency, DEQ and Sierra followed the format and outline of the 1993 Medford UGB CO 

Attainment Year Emission Inventory1. For those sources inventoried by DEQ, inventory 

methodology followed applicable EPA procedure and guidance documents. Two primary 

documents utilized were Procedures for the Preparation of Emission Inventories for Carbon 

Monoxide and Precursors of Ozone, Volume I3, and Emission Inventory Requirements for Carbon 

Monoxide State Implementation Plans2.
Appendix 2 – 2015 Medford CO LMP

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2.7 Contact Personnel

Due to existing workload and staffing commitments, DEQ entered into an agreement with the 

Rogue Valley Council of Governments (RVCOG) and Sierra Research for assistance with the 

Medford CO LMP emission inventory (please see Appendix C for the work proposal from Sierra). 

The work breakdown was as follows:

• DEQ

o Permitted point sources

o Open burning

o Wildfires and prescribed burning

• RVCOG/Sierra Research

o Small, stationary fuel combustion (non-permitted)

o Residential wood combustion

o Structure fires

o Aircraft and airport related

o Locomotives

o Recreational marine

o Nonroad vehicles & equipment

o On-road mobile (exhaust)

The abbreviated list of those conducting this Medford 2008 Limited Maintenance Plan emission 

inventory is shown below:

DEQ 

Wendy Wiles

Environmental Solutions Division Administrator

Jeffrey Stocum,

Air Quality Technical Services Manager

Emission Inventory

Christopher Swab, Senior Emission Inventory Analyst

Brandy Albertson, Emission Inventory Analyst

Miyoung Park, Emission Inventory Specialist

Wayne Kauzlarich, ACDP Permit Writer

Dana Bailey, Permit Coordinator

Quality Assurance

Wesley Risher, Emission Inventory Analyst

David Collier,

Air Quality Planning Manager

Dave Nordberg, Air Quality Planner

Sierra Research

Tom Carlson, Principal Scientist
Appendix 2 – 2015 Medford CO LMP

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Wenxian Zhang, Associate Engineer

Starcrest Consulting Group, LLC

Wayne Elson, Air Quality Planner and Mobile Source Emissions Expert

Rogue Valley Council of Governments

Dan Moore, Planning Coordinator, AICP
Appendix 2 – 2015 Medford CO LMP

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3 Medford Carbon Monoxide Attainment Area Inventory

3.1 Inventory Area Maps and Descriptions

3.1.1 Inventory Area Maps

The following maps are presented here for consistency with the Medford CO 1993 Attainment 

Year SIP Emissions Inventory1:

• Figure 1 (previous): Medford UGB Carbon Monoxide Attainment Area 

• Figure 2 (previous): Medford UGB with 25-mile point source buffer zone

• Figure 3: Open Burning Control Areas as defined in (OAR) 340-264-0078(1) and Rogue 

Basin Open Burning Control Area as defined in 340-264-0078(3)

• Figure 4: Woodstove Curtailment Ordinance Area / Critical PM10 Control Area

• Figure 5: Medford-Ashland Air Quality Maintenance Area / Vehicle Inspection Program 

Boundary
Appendix 2 – 2015 Medford CO LMP

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Figure 3: Open Burning Control Areas and Rogue Basin Open Burning Control Area
Appendix 2 – 2015 Medford CO LMP

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Figure 4: Woodstove Curtailment Ordinance Area / Critical PM10 Control Area
Appendix 2 – 2015 Medford CO LMP

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Figure 5: Medford-Ashland Air Quality Maintenance Area / Vehicle Inspection Program Boundary
Appendix 2 – 2015 Medford CO LMP

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3.1.2 Legal Descriptions

3.1.2.1 Legal Description of Medford Urban Growth Boundary / CO Inventory Area

Legal description of the Medford Urban Growth Boundary Attainment Area as adopted by Oregon DEQ define 

the boundaries as shown in Figure 1 and can be found in the Oregon Administrative Rules (OAR) 340-204-

0010(12):

(12) “Medford UGB” means the area beginning at the line separating Range 1 West and Range 2 West at a point 

approximately 1/4 mile south of the northwest corner of Section 31, T36S, R1W; thence west approximately 1/2 mile; 

thence south to the north bank of Bear Creek; thence west to the south bank of Bear Creek; thence south to the 

intersection with the Medford Corporate Boundary; thence following the Medford Corporate Boundary west and 

southwesterly to the intersection with Merriman Road; thence northwesterly along Merriman Road to the intersection 

with the eastern boundary of Section 10, T36S, R2W; thence south along said boundary line approximately 3/4 mile; 

thence west approximately 1/3 mile; thence south to the intersection with the Hopkins Canal; thence east along the 

Hopkins Canal approximately 200 feet; thence south to Rossanely Drive; thence east along Rossanely Drive 

approximately 200 feet; thence south approximately 1200 feet; thence west approximately 700 feet; thence south 

approximately 1400 feet; thence east approximately 1400 feet; thence north approximately 100 feet; thence east 

approximately 700 feet; thence south to Finley Lane; thence west to the end of Finley Lane; thence approximately 1200 

feet; thence west approximately 1300 feet; thence north approximately 150 feet; thence west approximately 500 feet; 

thence south to Highway 238; thence west along Highway 238 approximately 250 feet; thence south approximately 1250 

feet to a point even with the end of Renault Avenue to the east; thence east approximately 2200 feet; thence south 

approximately 1100 feet to a point even with Sunset Court to the east; thence east to and along Sunset Court to the first 

(nameless) road to the south; thence approximately 850 feet; thence west approximately 600 feet; thence south to 

Stewart Avenue; thence west along Stewart Avenue approximately 750 feet; thence south approximately 1100 feet; 

thence west approximately 100 feet; thence south approximately 800 feet; thence east approximately 800 feet; thence 

south approximately 1000 feet; thence west approximately 350 feet to a point even with the north-south connector 

street between Sunset Drive and South Stage Road; thence south to and along said connecting road and continuing along 

South Stage Road to Fairlane Road; thence south to the end of Fairlane Road and extending beyond it approximately 250 

feet; thence east approximately 250 feet; thence south approximately 250 feet to the intersection with Judy Way; thence 

east on Judy Way to Griffin Creek Road; thence north on Griffin Creek Road to South Stage Road; thence east on South 

Stage Road to Orchard Home Drive; thence north on Orchard Home Drive approximately 800 feet; thence east to 

Columbus Avenue; thence south along Columbus Avenue to South Stage Road; thence east along South Stage Road to the 

first road to the north after Sunnyview Lane; thence north approximately 300 feet; thence east approximately 300 feet; 

thence north approximately 700 feet; thence east to King’s Highway; thence north along King’s Highway to Experiment 

Station Road; thence east along Experiment Station Road to Marsh Lane; thence east along Marsh Lane to the northern 

boundary of Section 6, T38S, R1W; thence east along said boundary approximately 1100 feet; thence north 

approximately 1200 feet; thence east approximately 1/3 mile; thence north approximately 400 feet; thence east 

approximately 1000 feet to a drainage ditch; thence following the drainage ditch southeasterly approximately 500 feet; 

thence east to the eastern boundary of Section 31, T37S, R1W; thence south along said boundary approximately 1900 

feet; thence east to and along the loop off of Rogue Valley Boulevard, following that loop to the Southern Pacific Railroad 

Line (SPRR); thence following SPRR approximately 500 feet; thence south to South Stage Road; thence east along South 

Stage Road to SPRR; thence southeasterly along SPRR to the intersection with the west fork of Bear Creek; thence 

northeasterly along the west fork of Bear Creek to the intersection with U.S. Highway 99; thence southeasterly along U.S. 

Highway 99 approximately 250 feet; thence east approximately 1600 feet; thence south to East Glenwood Road; thence 

east along East Glenwood Road approximately 1250 feet; thence north approximately 1/2 mile; thence west 

approximately 250 feet; thence north approximately 1/2 mile to the Medford City Limits; thence east along the city limits 

to Phoenix Road; thence south along Phoenix Road to Coal Mine Road; thence east along Coal Mine Road approximately 

9/10 mile to the western boundary of Section 35, T37S, R1W; thence north to the midpoint of the western boundary of 

Section 35, T37S, R1W; thence west approximately 800 feet; thence north approximately 1700 feet to the intersection 

with Barnett Road; thence easterly along Barnett Road to the southeast corner of Section 27, T37S, R1W; thence north 
Appendix 2 – 2015 Medford CO LMP

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along the eastern boundary line of said section approximately 1/2 mile to the intersection with the 1800 foot contour 

line; thence east to the intersection with Cherry Lane; thence following Cherry Lane southeasterly and then northerly to

the intersection with Hillcrest Road; thence east along Hillcrest Road to the southeast corner of Section 23, T37S, R1W; 

thence north to the northeast corner of Section 23, T37S, R1W; thence west to the midpoint of the northern boundary of 

Section 22; T37S, R1W; thence north to the midpoint of Section 15, T37S, R1W; thence west to the midpoint of the 

western boundary of Section 15, T37S, R1W; thence south along said boundary approximately 600 feet; thence west 

approximately 1200 feet; thence north approximately 600 feet; thence west to Foothill Road; thence north along Foothill 

Road to a point approximately 500 feet north of Butte Road; thence west approximately 300 feet; thence south 

approximately 250 feet; thence west on a line parallel to and approximately 250 feet north of Butte Road to the eastern 

boundary of Section 8, T37S, R1W; thence north approximately 2200 feet; thence west approximately 1800 feet; thence 

north approximately 2000 feet; thence west approximately 500 feet; thence north to Coker Butte Road; thence east 

along Coker Butte Road approximately 550 feet; thence north approximately 1250 feet; thence west to U.S. Highway 62; 

thence north approximately 3000 feet; thence east approximately 400 feet to the 1340 foot contour line; thence north 

approximately 800 feet; thence west approximately 200 feet; thence north approximately 250 feet to East Vilas Road; 

thence east along East Vilas Road approximately 450 feet; thence north approximately 2000 feet to a point 

approximately 150 feet north of Swanson Creek; thence east approximately 600 feet; thence north approximately 850 

feet; thence west approximately 750 feet; thence north approximately 650 feet; thence west approximately 2100 feet; 

thence on a line southeast approximately 600 feet; thence east approximately 450 feet; thence south approximately 

1600 feet; thence west approximately 2000 feet to the continuance of the private logging road north of East Vilas Road; 

thence south along said logging road approximately 850 feet; thence west approximately 750 feet; thence south 

approximately 150 feet; thence west approximately 550 feet to Peace Lane; thence north along Peace Lane 

approximately 100 feet; thence west approximately 350 feet; thence north approximately 950 feet; thence west 

approximately 1000 feet to the western boundary of Section 31, T36S, R1W; thence north approximately 1300 feet along 

said boundary to the point of beginning.

3.1.2.2 Legal Description of Open Burning Control Areas

In addition to the UGB, DEQ has specific rules that address commercial, demolition, construction and industrial 

open burning. The rules are identified for densely populated locations in the state, including cities over 4,000 

people in population and within three miles of the corporate city limits of these cities. The boundaries defined 

by the rules are termed Open Burning Control Areas. The rules pertaining to the Medford area may be found 

in the Oregon Administrative Rules (OAR) 340-264-0078, summarized below.

Generally, areas around the more densely populated locations in the state and valleys or basins that restrict atmospheric 

ventilation are designated "Open Burning Control Areas". The practice of open burning may be more restrictive in open 

burning control areas than in other areas of the state. The specific open burning restrictions associated with these open 

burning control areas are listed in OAR 340-264-0100 through 340-264-0170 by county. The open burning control areas 

of the state are defined as follows:

(1) All areas in or within three miles of the incorporated city limit of all cities with a population of 4,000 or more.

(3) The Rogue Basin Open Burning Control Area is located in Jackson and Josephine Counties with boundaries as generally 

depicted in Figure 4 Rogue Basin Open Burning Control Area. The area is enclosed by a line beginning at a point 

approximately 4-1/2 miles NE of the City of Shady Cove at the NE corner of T34S, R1W, Willamette Meridian, thence 

south along the Willamette Meridian to the SW corner of T37S, R1W; thence east to the NE corner of T38S, R1E; thence 

south to the SE corner of T38S, R1E; thence east to the NE corner of T39S, R2E; thence south to the SE corner of T39S, 

R2E; thence west to the SW corner of T39S, R1E; thence NW along a line to the NW corner of T39S, R1W; thence west to 

the SW corner of T38S, R2W; thence north to the SW corner of T36S, R2W; thence west to the SW corner of T36S, R4W; 

thence south to the SE corner of T37S, R5W; thence west to the SW corner of T37S, R6W; thence north to the NW corner 

of T36S, R6W; thence east to the SW corner of T35S, R1W; thence north to the NW corner of T34S, R1W; thence east to 

the point of beginning.
Appendix 2 – 2015 Medford CO LMP

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3.1.2.3 Legal Description of Medford Area Woodstove Curtailment Ordinance / Critical PM10 

Control Area

In order to strengthen overall woodstove strategies in the Medford AQMA, local ordinances in the Medford 

area were unified in 1998, resulting in a Woodstove Curtailment Ordinance Area, also known as the Critical 

PM10 Control Area. The unified ordinance applies in Jackson County, as well as the cities of Ashland, Central 

Point, Jacksonville, Medford, Phoenix, and Talent. The legal description is as follows:

Beginning on I-5 and Tolo Road, crossover north on Tolo Road to Old Hwy 99. East on Old Hwy 99 to Kirtland Road. 

Northeasterly on Kirtland Road to Tablerock Road. North on Tablerock Road to the Rogue River. Northeasterly along the 

southern bank of the Rogue River to the mouth of Little Butte Creek. Northeasterly along Little Butte Creek to Antelope 

Creek. Southeasterly along Antelope Creek to Dry Creek. Southeasterly on Dry Creek to Hwy 140. Southwesterly on Hwy 

140 to Kershaw Road. South on Kershaw Road to Corey Road. West on Corey Road to Foothill Road. South on Foothill 

Road to Medford Urban Growth Boundary (UGB) (near Delta Waters Road). Follow eastern UGB south to North Phoenix 

Road. South on North Phoenix Road to Phoenix UGB. Follow eastern UGB south to I-5. Southeasterly on I-5 to Talent 

UGB. Follow the eastern, southern, and western UGB until intersection with Southern Pacific Railroad Track (which 

became Union Pacific / Central Oregon & Pacific Railroad in 1994). Southern Pacific Railroad track north to Hartley Lane 

(Road). West on Hartley Lane (Road) to Talent-Phoenix Road (Colver Road). North on Talent-Phoenix Road (Colver Road) 

to Phoenix UGB. West along southern boundary of Phoenix UGB to Camp Baker Road. West on Camp Baker Road to 

Coleman Creek Road. North on Coleman Creek Road to Carpenter Hill Road. West on Carpenter Hill Road to Pioneer 

Road. Northwest on Pioneer Road to Griffin Creek Road. North on Griffin Creek Road to Medford UGB. North along 

Medford UGB to South Stage Road. West on South Stage Road to Arnold Lane. North on Arnold Lane to Jacksonville 

Hwy. West on Jacksonville Hwy to Hanley Road. Northeast on Hanley Road to Ross Lane. West on Ross Lane to 

Redwood Drive. South on Redwood Drive to LaPine Avenue (which becomes Wendt Road). West on LaPine Avenue 

(Wendt Road) to Old Stage Road. North on Old Stage Road to Old Military Road. North on Old Military Road to Old 

Stage Road. Northwest on Old Stage Road to Scenic Avenue. Northwest on Scenic Avenue to Tolo Road. North on Tolo 

Road to Willow Springs Road. East on Willow Springs Road to Ventura Lane. North on Ventura Lane to I-5. Northwest

on I-5 to crossover of Tolo Road.

3.1.2.4 Legal Description of the Medford-Ashland Air Quality Maintenance Area / Vehicle Inspection 

Program Boundary

Vehicle owners residing within the Medford-Ashland Air Quality Maintenance Area are subject to DEQ vehicle 

inspection per OAR 340-256-0300(2) and (3). The legal description of the Medford – Ashland air quality 

maintenance area is as follows:

340-204-0010(10) “Medford-Ashland Air Quality Maintenance Area” (AQMA) means the area defined as beginning at a 

point approximately two and quarter miles northeast of the town of Eagle Point, Jackson County, Oregon at the 

northeast corner of Section 36, Township 35 South, Range 1 West (T35S, R1W); thence South along the Willamette 

Meridian to the southeast corner of Section 25, T37S, R1W; thence southeast along a line to the southeast corner of 

Section 9, T39S, R2E; thence south-southeast along line to the southeast corner of Section 22, T39S, R2E; thence South to 

the southeast corner of Section 27, T39S, R2E; thence southwest along a line to the southeast corner of Section 33, T39S, 

R2E; thence West to the southwest corner of Section 31, T39S, R2E; thence northwest along a line to the northwest 

corner of Section 36, T39S, R1E; thence West to the southwest corner of Section 26, T39S, R1E; thence northwest along a 

line to the southeast corner of Section 7, T39S, R1E; thence West to the southwest corner of Section 12, T39S, R1W, T39S, 

R1W; thence northwest along a line to southwest corner of Section 20, T38S, R1W; thence West to the southwest corner 

of Section 24, T38S, R2W; thence northwest along a line to the southwest corner of Section 4, T38S, R2W; thence West to 

the southwest corner of Section 6, T38S, R2W; thence northwest along a line to the southwest corner of Section 31, T37S, 

R2W; thence North and East along the Rogue River to the north boundary of Section 32, T35S, R1W; thence East along a 

line to the point of beginning. 
Appendix 2 – 2015 Medford CO LMP

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3.2 Summary of Emissions Data

Summary tables of emission data that are presented here include stationary point sources, stationary 

area sources, non-road mobile sources, and on-road mobile sources. Summary emissions are expressed as 

charts in Figures 6 through 8. Table 2.1 provides a summary of the 2008 emissions estimates.

Figure 6: Distribution of 2008 Annual CO Emissions

Figure 7: Annual CO Emissions by Percentage

0

2,000

4,000

6,000

Stationary 

Point 

Sources

Stationary 

Area 

Sources

Non-Road 

Mobile 

Sources

On-Road 

Mobile 

Sources

CO Emissions, tpy

Stationary 

Point Sources

14%

Stationary 

Area Sources

26%

Non-Road 

Mobile 

Sources

26%

On-Road 

Mobile 

Sources

34%
Appendix 2 – 2015 Medford CO LMP

Page 21

Figure 8: Distribution of 2008 Season Day CO Emissions

Figure 9: Season Day CO Emissions by Percentage

0

15,000

30,000

45,000

Stationary 

Point 

Sources

Stationary 

Area 

Sources

Non-Road 

Mobile 

Sources

On-Road 

Mobile 

Sources

CO Emissions, lbs/day

Stationary 

Point Sources

16%

Stationary 

Area Sources

37%

Non-Road 

Mobile 

Sources

12%

On-Road 

Mobile 

Sources

35%
Appendix 2 – 2015 Medford CO LMP

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Table 3.1: Summary of 2008 CO Emissions Data

Annual CO Season

Source Type tpy % of Category lbs/day % of Category

Stationary Point Sources 2,376.1 15% 13,159 16%

Stationary Area Sources 3,333.1 21% 30,399 37%

Non-Road Mobile Sources 4,488.2 28% 10,061 12%

On-Road Mobile Sources 5,730.0 36% 28,731 35%

Total within Medford UGB 15,927.4 100% 82,350 100%
Appendix 2 – 2015 Medford CO LMP

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3.3 Stationary Permitted Point Sources

3.3.1 Introduction

The following section is an overview and summary of the 2008 CO Point Source Emission Inventory developed 

for the Medford CO Limited Maintenance Plan (LMP) due in 2015. The 2008 CO inventory is an update to the 

original 1993 Attainment Year inventory1. However, 1993 and 2008 emission results were not compared 

because of discrepancies caused by a significant lapse in time between inventories and the change in point source 

determination methodology. This inventory includes both annual and seasonal emission estimates that establish 

both short and long term CO trends from industrial sources during 2008. This write up details the steps used to 

develop the 2008 Medford Point Source Emission Inventory and is a discussion of the results. 

3.3.2 Geographic Area and Sources Included

The geographic focus for this inventory is the former Medford CO nonattainment area which is the Urban 

Growth Boundary (UGB) for the city. The UGB is represented by the red outline above in Section 1, Figure 1. A 

25-mile buffer zone was also added to Medford’s UGB to include industrial sources from other cities such as 

White City, Central Point, Ashland, Grants Pass, and Rogue River. Section 1, Figure 2 shows the UGB and 25-

mile buffer zone as the inventory boundary.

Grants Pass industrial sources were not included in the Medford 1993 inventory because they were already 

inventoried for the 1993 Grants Pass State Implementation Plan9. The 1993 inventory for the Grants Pass SIP 

was updated in July 2014. Industrial sources from Grants Pass will be included in the 2008 CO inventory for 

Medford. 

3.3.3 Point Source Determination

Point sources within the Medford UGB and 25-mile buffer zone include both industrial and non-industrial 

sources. Industrial sources are included under Part 2.3 Stationary Point Sources of this inventory and nonindustrial sources are covered under Part 2.4 Stationary AREA Sources. This is a discussion on the point source 

determination for industrial sources included in both the 1993 Attainment Year Inventory and the 2008 Point 

Source CO Inventory for Medford.

Point sources for the 1993 Attainment Year Inventory were defined as stationary industrial sources that 

emitted more than 100 tons CO within the Medford UGB and a 25-mile buffer zone. Smaller stationary 

industrial sources that emitted less than 100 tons were included with non-industrial sources under Part 2.4 

Stationary AREA Sources in the 1993 inventory. 

Table 2.3.1 is the original list of large stationary industrial sources included in the 1993 inventory. See 

Reference 618, Appendix A, Point Source Data and Table A-1 Individual Stationary Point Source 

Determinations. 
Appendix 2 – 2015 Medford CO LMP

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Table 2.3. 1: 1993 Attainment Year Inventory List of Permitted Point Sources

Source 

Number Source Name Permit Type

CO 

PSEL

Current 

Operating 

Status

SIC

15-0004 Boise Cascade Corporation TV 2974 Active 2436

15-0012 U.S. Forest Industries ACDP 99 Active 2435

15-0014 Medite Corporation ACDP 99 Active 2436

15-0020 Boise Cascade Corporation TV 796 Active 2436

15-0025 Timber Products Company TV 237 Active 2436

15-0041 Dyno Polymers Incorporated ACDP 1900 Closed 2861

15-0048 Medford Corporation ACDP 947 Closed 2493

15-0058 Royal Oak Enterprises, Inc. ACDP 613 Closed 2861

15-0073 Medford Corporation TV 235 Active 2493

15-0159 Biomass One, L.P. TV 570 Active 4961

Three facilities have since closed and the other seven operated in 2008 so they were added to the 2008 

Medford CO EI.

3.3.3.1 2008 Point Source Determination

Point sources included in the 2008 CO Inventory are defined as stationary industrial sources that have a state 

or federal air operating permit and are located within the UGB and 25-mile buffer for Medford. These 

stationary industrial sources would fall under one of two permit programs that DEQ administers:

• Air Contaminant Discharge Permit (ACDP): a state operating permit for small industrial sources that 

emit 99 tons or less per year of any criteria pollutant, or

• Title V Permit (TV): a federal operating permit for large industrial sources that emit 100 tons or greater 

per year of any criteria pollutant. 

One major change for the 2008 inventory was to include ACDP sources, reported as Area Sources in 1993, with 

the TV sources. DEQ has better data now to estimate CO emissions from ACDP sources. 

The conditions used in 1993 for point source determination no longer apply and so the new conditions for 

inclusion in the 2008 inventory are as follows:

• Sources are located within the UGB and 25-mile buffer,

• Sources had an active ACDP or Title V permit in 2008

• Sources operated in 2008,

• Sources actually emit CO emissions

All ACDP and TV sources in Jackson and Josephine Counties were mapped using ArcGIS 10 in order to eliminate 

sources located outside the UGB and 25-mile buffer zone. The remaining ACDP and TV sources that fell within 

the inventory boundary were compared against the other conditions listed above to determine if they would 

be included in the 2008 CO EI for Medford. The list was narrowed down to 28 ACDP and 9 TV sources that met 

all the conditions above. Table A-1 is the final list of 37 sources by source number, name, site location, permit 

types, operating status, CO PSEL, and standard industrial classification codes (SIC) included in the 2008 

inventory. Section 1, Figure 2 provides the geographical locations for the Medford sources included in 2008 CO 

inventory.
Appendix 2 – 2015 Medford CO LMP

Page 25

Appendix A, Table A-1.1 provides a list of 37 sources that were excluded from the 2008 inventory because 

they did not meet one or more of the conditions listed above. Ten sources were not included because, 

although they had a CO PSEL in their permit, they did not actually operate equipment that emits CO. This is 

fairly common with General ACDPs because they list all possible emission units and processes based on a 

source category and assign a facility based on the type of business they operate. An example of this is when a 

source is assigned to a General permit for millwork and the emission units/processes identified in the permit 

are boilers, veneer dryers, kilns, cyclones, target boxes, etc. The source may only operate cyclones and target 

boxes and nothing else in the list that may emit CO emissions.

27 sources were closed sometime between 1993 and 2008; therefore, they were not included in the 2008 CO 

EI for Medford

3.3.4 Methodology and Approach

The Medford inventory was developed using existing TV emissions data submitted by DEQ to EPA’s 2008

National Emission Inventory (NEl) and by putting together estimates for ACDP sources where no data was 

readily available. Since ACDP sources are typically reported to the NEI as Area Sources by county and source 

classification, CO emission estimates needed to be calculated down to individual source levels. The following is 

the methodology and approach used to develop the 2008 Medford Point Source CO Emission inventory.

3.3.4.1 Data Collection

Data collection is necessary to gather information used to calculate both annual and seasonal emissions. 

Information such as a source’s emission basis, activity/throughput data, operating schedules, and Plant Site 

Emission Limits (PSELs) were collected for the inventory. This data was collected from 2008 annual reports, 

permits, or retrieved electronically from a permitting database. Most emissions and compliance information 

for TV sources is already stored in DEQ’s Tracking Reporting and Administration of Air Contaminant Sources

(TRAACS) permitting database. However, some information for ACDP sources such as emission basis and 

emission estimates are stored in an external database. 

3.3.4.2 Emission Basis

Emission basis details the emission units and processes permitted at a source. The basis is developed by using 

information from emission detail sheets found in permits or permit review reports. For TV sources emission 

basis is organized in a workbook, a delivery mechanism for importing data into TRAACS. The workbook 

contains emission source and process descriptions, activity data, emission factors or other data used in 

estimating emissions, and potential to emit emissions used to develop Plant Site Emission Limits (PSELs). The 

workbook imports the emission basis into TRAACS where this information is used in preparing emission 

inventories. Further, the emission basis and emissions are submitted to EPA’s EIS database annually. 

ACDP emission basis is collected and stored by inventory project in an MS Access database, known as Final 

ACDP EI database. This database stores the same type of information as TRAACS such as the emission 

units/process descriptions, emission factors, and other data necessary for calculating emissions. The 

information is obtained from ACDP permits and/or annual reports. 

3.3.4.3 Activity Data

Activity data, also called throughput, was collected from 2008 annual reports for Title V and ACDP sources. 

Activity data consists of fuel use, production activity, or other annual throughput types used to estimate 

emissions. Sources must fulfill permit conditions for annual reporting by submitting annual activity 

information, emissions factors, and emission estimates for criteria air pollutants. The activity data is used to 
Appendix 2 – 2015 Medford CO LMP

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verify existing emissions estimates from the reports as well as to calculate emissions not typically reported by 

the sources themselves

3.3.4.4 Plant Site Emission Limits (PSELs)

PSELs were found in the DEQ TRAACS database (see Section 1.4) or permits

3.3.4.5 Annual Emissons Calculations

Point source annual emissions were estimated at the process level for each source. Emission basis and activity 

data used to estimate process level emissions were collected from ACDP and TV permits and 2008 annual 

reports. Below are the estimation methodologies used to prepare TV source annual emissions for the 2008 

NEI and ACDP source emissions for the Medford inventory. 

3.3.4.5.1 Emissions Estimation Methodologies for TV Sources

Emissions for this inventory were estimated 1 of 2 ways using: 

• emission factors, or 

• Continuous Emissions Monitoring System (CEMS) 

Emission factors, the most common methodology, are derived by the source and permit writer to determine 

PSELs and compliance. Emission factors are developed using such resources as AP-42, industry standards, or 

by source testing. Emission factors relate the quantity of a pollutant to its activity such as lb of pollutant per 

gallon of fuel oil. Emission factors may be based on assumptions or conversions not likely defined in the 

permit or emission detail sheets. These assumptions include capture efficiencies, control efficiencies, 

conversion constants, %LEL (lower explosive limit), and transfer efficiency. 

Most of the CO emission estimates were developed using emission factors from permits and activity from 

2008 annual reports. The following formula was used to estimate annual CO emissions:

2008 Annual CO Emissions (tpy) = (2008 Activity * Emission Factor)/2000 lbs/ton

Some CO emission estimates were derived via CEMS which is the most accurate representation of emissions at 

a source. Permit conditions may require direct measurement of stack emissions and recordkeeping for 

reporting hourly or daily CO emitted at a facility. Emission factors and CEMS are the most common estimation 

methodologies used to develop large industrial point source emissions for the 2008 CO inventory.

3.3.4.5.2 Emissions Estimation Methodlogies for ACDP Sources

Emissions from ACDP sources are generally not reported as point sources to the NEI but as AREA sources at 

the county-level and source classification code (SCC). Since ACDP sources were reported on a county-level to 

the 2008 NEI, emission estimates had to be developed for each individual source for this inventory. 

CO emission estimates were developed using emission factors from permits and activity from 2008 annual 

reports. The following formula was used to estimate annual CO emissions:

2008 Annual CO Emissions (tpy) = (2008 Activity * Emission Factor)/2000 lbs/ton

See Appendix A, Table A-2 Stationary Point Source Emission Estimation Details. The table provides annual 

emission details down to process-level for both ACDP and TV sources. This table includes emission unit level 

information such as annual activity, emission factors, and operating details. The 2008 annual emissions for both 

ACDP and TV sources were used next to calculate seasonal emissions.
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3.3.4.6 Seasonal Emissions Calculations

Emissions are generally not static and fluctuate during different times of the year for various reasons such as 

changes in source activity or temperature. For example, CO emissions may peak during winter months in 

urban areas due to incomplete combustion of carbon-based fuels (i.e. automobiles, woodstove, open-burning, 

fuel combustion of industrial boilers, etc.). The winter months of December through February is defined as 

the CO season, the period for which emissions are more likely to peak. The reason for this is cooler

temperatures during these months prevent complete combustion of the fuel which may result in excess CO 

emissions trapped near the ground by atmospheric inversions. 

2008 annual CO emissions were temporally allocated from annual to seasonal emissions for the CO season. 

Typical Season Day (TSD) emissions are average daily CO emissions calculated over the CO season and 

recorded in pounds per day (lbs/day). To complete seasonal emission estimates data components such as 

annual emissions (tpy), seasonal adjustment factors, and annual activity days are required. The following is the 

allocation and development methods and data components needed to calculate seasonal emissions.

3.3.4.6.1 Seasonal Adjustment Factors

Seasonal Adjustment Factors (SAF) were calculated using temporal files of peak season activity by source 

classification code (SCC) from EPA’s Sparse Matrix Operator Kernal Emissions (SMOKE) modeling program. 

The data components from these files are used in the following equation to calculate SAF:

SAF = 

((Sum of Peak Season Activity) (12 months)) / ((Annual Activity) (Peak Season Activity Months))

An example of how this calculation works is:

Use SCC 10200502, 

Determine the peak season months and % activity for the peak season months:

Peak Season Activity Months: % Activity During Peak Season 

Months

December 83

January 83

February 83

Total Annual Activity: 996

Insert information into pertinent components of SAF calculation:

SAF = ((83+83+83) (12 months)) / ((996) (3 months)) = 1.00

Both ACDP and TV sources required SAFs to complete seasonal calculations. See Appendix B, Table B-1: 

Seasonal Adjustment Factors by SCC Used for 2008 CO Inventory.

3.3.4.6.2 Season Day Emissions Calculations

Typical Season Day (TSD) emissions are average daily CO emissions calculated over the CO season (i.e. 

December 1st through end of February the following year). The following data components are needed to 

calculate TSD emissions:

• 2008 Annual CO Emissions (AE) 

• SAF

• Activity Days (AD) 

TSD emissions = (AE*SAF*2000 lb/ton) / (AD)
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The following is an example calculation for natural gas fuel combusted in a veneer dryer. In order to complete the 

TSD calculation 2008 annual CO emissions, seasonal adjustment factor by SCC and annual activity days are 

needed. This formula breaks the annual emissions down to lbs/day over the CO season.

Dryer Emissions (SCC 30700716):

• AE = 140 tons

• SAF = 1.00

• AD = 365 days/yr 

TSD Emissions = (140*1.00*2000) / (365) = 767 lbs/day

TSD emission calculations were performed for all 37 ACDP and TV sources. TSD emission estimates for TV and 

ACDP sources cannot be calculated nor stored in TRAACS. TV and ACDP seasonal emissions were calculated and 

housed in MS Access Final_SIP_MP_PSD_EITool database. Appendix A, Table A-2 Stationary Point Source 

Emission Estimation Details also provides TSD emission estimates down to the process-level for both ACDP 

and TV sources.
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3.3.5 Summary of Stationary Point Source Emissions

Inventory results were organized into tables summarizing 2008 annual and seasonal CO emissions by source 

industrial classification (SIC) and at source and process levels. Appendix C, Tables 2.3.1, 2.3.2, and 2.3.3 

summarize stationary point source CO emissions for the 2008 Medford inventory. See Figures 8 through 11

for how stationary point source annual and season day emissions are distributed amongst the other source

categories of the inventory.

Total 2008 annual and seasonal CO emissions for industrial sources located within the Medford UGB and 25-

mile buffer are 2,376.1 tons per year and 13,159 lbs per day, respectively. The major industries permitted in 

Medford and the surrounding cities are wood products manufacturing, concrete production, steam supply for 

operating processes or heating dwellings, sewer systems, crematories, and landfills. 

Table 2.3.2 summarizes 2008 CO annual and seasonal emissions by SIC for the Medford UGB and 25-mile 

buffer area. The table reveals three industrial classifications that contribute over 96% of total point source CO 

emissions in 2008. 

Table 2.3. 2: Medford UGB CO Season: Summary of Point Source Emissions by SIC

(1) (2)

CO Emissions

SIC 

Code SIC Name Annual and TSD Emissions

tpy lbs/day

2048 OTHER PREPARED FEEDS 0.1 1

2421 SAWMILLS AND PLANING MILLS 2.4 20

2431 MILLWORK 1.2 9

2434 WOOD KITCHEN CABINETS 0.2 1

2435 HARDWOOD VENEER AND PLYWOOD 22.4 123

2436 SOFTWOOD VENEER AND PLYWOOD 1803.6 9943

2439 STRUCTURAL WOOD MEMBERS 0.3 2

2493 RECONSTITUTED WOOD PRODUCTS 36.3 207

2951 PAVING MIXTURES AND BLOCKS 12.3 74

3272 OTHER CONCRETE PRODUCTS 5.2 37

3861 PHOTOGRAPHIC EQUIPMENT & SUPPLY 3.8 21

4952 SEWERAGE SYSTEMS 10.7 59

4953 REFUSE SYSTEMS 211.1 1160

4961 STEAM SUPPLY 266.6 1501

Pollutant Total 2376.1 13159

Softwood veneer and plywood (SIC 2436) contributes 75.9% while steam supply (SIC 4961) and refuse systems 

(SIC 4953) only emit 11.2% and 8% of total CO emissions, respectively. This leaves a wide margin between 

softwood veneer and plywood products manufacturing and other industrial classifications. 

Further evaluation required identification of sources in each SIC. Table 2.3.3 in Appendix C, is a list of sources 

with annual and seasonal CO emissions for each SIC. This table reveals which sources are contributing 
Appendix 2 – 2015 Medford CO LMP

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significantly to CO emissions in the three primary SIC’s listed above. A 100 tpy annual emissions cut-off was 

applied to these sources to determine the top emitters of CO emissions for this inventory.

Table 2.3.3 lists five sources that contribute the most CO emissions within the Medford UGB and 25-mile 

buffer. These five sources emit together 88% of the total annual and seasonal CO emissions. Boise Cascade 

Wood Products, L.L.C. (15-0004) produces over half the 2008 CO emissions out of the five sources. CO 

emissions for these sources occur because of fuel combustion activities such as the operation of boilers, 

landfill engines, and veneer dryers. All other source contributions to 2008 annual and seasonal CO emissions 

are considered minimal. 

Table 2.3. 3: Medford UGB CO Season, Summary of Top 5 :Point Source Emitters

(1) (2)

CO Emissions

Emission 

Year

SIC 

Code

Source 

Number Source Name Annual Emissions

Typical 

Season 

Day 

tpy lbs/day

2008 2436 15-0004 Boise Cascade Wood Products, L.L.C. 1087.6 5943

2008 2436 15-0020 Boise Cascade Wood Products, L.L.C. 513.1 2812

2008 4961 15-0159 Biomass One, L.P. 232.7 1278

2008 4953 15-0026 Dry Creek Landfill, Inc. 162.6 891

2008 2436 17-0030 TP Grants Pass, LLC 111.4 598

Pollutant Total 2,107.4 11,521

(1) And (2), see Appendix A, Table A-2

In summation, wood product companies (Boise Cascade (15-0004) and (15-0020)) and TP Grants Pass L.L.C 

(17-0030) account for 81% of total CO emissions during 2008. Biomass One, L.P. (15-0159) and Dry Creek 

Landfill (15-0026) only account for 19% of the industrial source CO emissions in 2008. These sources 

contributed 2107.4 tpy out of 2376.1 tpy and 11521 lbs/day out of 13159 lbs/day over the CO season. All 

these sources are still in operation today.

3.3.6 Control Efficiency (CE) and Rule Effectiveness (RE)

EPA requires control efficiency and rule effectiveness to be calculated for SIPs. According to EPA’s Air 

Emissions Reporting Requirements (AERR) rule (40 CFR Part 51) these concepts are defined as:

• Control Efficiency (CE): the capture and reduction efficiency of primary control devices

• Rule effectiveness (RE): a generic term for identifying and estimating the uncertainties in emission 

control programs. Rule effectiveness adjusts the control efficiency from what could be realized under 

ideal conditions to what is actually emitted in practice due to less than ideal conditions. It is a measure 

of the extent to which a rule actually achieves its desired emission reductions. 

The 1993 baseline control efficiencies were zero and rule effectiveness did not apply because no CO controls 

were installed back then for any source. No controls for CO have been installed since 1993 for any source; 

therefore, control efficiency and rule effectiveness also do not apply in the 2008 inventory. 
Appendix 2 – 2015 Medford CO LMP

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3.4 Stationary Nonpoint (Area) Sources

3.4.1 Introduction and Scope

This section describes the development of the emissions inventory for carbon monoxide for stationary area 

sources located in the Medford UGB in 2008. Area sources included in this inventory are stationary and 

collectively represent relatively small and numerous individual sources within the inventory area. Included in 

the area source category are three groups of distinct area source emission contributors: Waste disposal, 

treatment and recovery (including residential, industrial, and commercial open burning); Small stationary fuel 

and wood use (including residential, industrial, and commercial combustion); and Miscellaneous (forest fires, 

structural fires, and slash burning). A fourth group of sources, small permitted point sources, originally 

included in the 1993 attainment year inventory, are included in the permitted point source inventory (Section 

2.3) for this emission inventory.

All tables referred to in this section of the report are shown at the end of the section.

Table 2.4.1 lists the procedures used to develop the emission estimates for the various categories of area 

source CO emissions included in the Medford UGB inventory. Estimated area source emissions represented in 

this inventory occur on an average weekday during the three-month CO season of January 1 through February 

28, and December 1through December 31, 2008.

Stationary area sources are currently referred to as nonpoint sources by EPA, however the term area sources 

is used in this document for consistency with the 1993 attainment year EI.

3.4.2 Methodology and Approach

3.4.2.1 Source Category Identification and General Methodology Overview

Discussion of guidance documents and broad methodology used to calculate stationary area source emissions 

can be found in Part I. The list of stationary area sources included in the inventory was based on the EPA 

Procedures Document3 and the Emissions Inventory Requirements for CO1. These area sources were 

compared to sources evaluated in the 1993 Attainment Year CO SIP Emission Inventory618, and the annual 

inventory of point source categories.

The starting point for emissions estimates for many area source categories was the EPA 2008 National 

Emission Inventory All data from the 2008 NEI was retrieved from the EPA EIS Gateway (See Part 1, Section 

1.4 of this report). The 2008 NEI CO emissions estimates consist of data generated by both DEQ and EPA, 

depending upon source category. The DEQ data for specific categories, such as Residential Wood Combustion, 

were submitted to EPA through the EIS CERS XML process as required by the Air Emissions Reporting Rule 

(AERR). Data and documentation for the 2008 NEI may be found at the following 

website: http://www.epa.gov/ttnchie1/net/2008inventory.html

For DEQ generated emission estimates, emission factors were taken from the EPA Procedures Document2, the 

FIRE Version 5 SCC’s and Emission Factors10, the Compilation of Air Pollution Emission Factors (AP-42)11, 

various EPA Surveys, and local studies conducted by the Oregon Department of Environmental Quality or 

environmental consulting firms. Errors in estimated emissions could occur in the multiplier values used, in the 

accuracy of calculations, or in mistakes in the construction of equations. Therefore, estimated emissions were 

checked for reasonableness by a number of approaches: 1) using alternative multiplier values when possible; 
Appendix 2 – 2015 Medford CO LMP

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2) comparing estimates with the results of earlier area source inventories; and 3) performing independent 

checks on the accuracy of the multiplier values, the methodologies, and the emission calculations.

Seasonal activity factors were taken from the EPA Procedures Document2 or were derived by DEQ and based 

upon season specific activity levels following guidelines in the Procedures Document. All sources were 

considered to be uncontrolled with the exception of open burning; for details on how controls were 

incorporated into the open burning categories, please see Section 2.4.3.1.2 and associated tables.

3.4.2.2 Reconciliation with Point Source Emissions (double count prevention)

Double counted emissions were removed from area source fuel combustion emissions by subtracting 

emissions from point source fuel burning processes, broken down by the specific type of fuel, as shown in 

Appendix A, Table A-2. However, point source emissions to be removed were selected with the following two 

parameters:

• ACDP source emissions only, since the 2008 TV source double-count was resolved by the DEQ for the 

2008 NEI submittal.

• Jackson County sources only, excluding those sources inventoried in the Grants Pass area, since area 

sources inventoried were for the Medford UGB only

3.4.3 Discussion of Area Source Categories

Each of the major area source categories is comprised of area source types. Detailed descriptions of the 

emission estimation methodology for each source type are included in Tables 2.4.3 through 2.4.14 and in 

Appendix B. The applicable appendix table number is included in the annotations, which accompany the 

summary table. Discussion of data sources, emission factors, seasonal adjustment factors, and activity levels 

which affect the area source are included for each area source type. Applicable state regulations affecting a 

specific area source emission category are included in the notes on each category summary table. If specific 

area source type emissions were affected by state regulations during the inventory year, control efficiency, 

rule effectiveness, and rule penetration have been applied1,3. Example calculations for emissions estimates 

are included on individual spreadsheets. The following sections describe these major categories; subsections 

corresponding to individual area source types are included.

Summary charts and tables, along with emissions estimates tables by category, are shown following this 

section.

3.4.3.1 Waste Disposal, Treatment and Recovery

This category includes disposal, treatment, recovery and clean up of solid and liquid wastes by incineration 

and open burning.

3.4.3.1.1 Incineration

This category consists of the disposal of solid waste, infectious waste, or crematory incinerator waste from 

industrial and commercial/institutional sources by combustion. Combustion occurs in a structure or furnace 

for the purpose of reduction in volume or weight of the waste material.

3.4.3.1.1.1 Industrial Incineration

The Medford UGB does not contain any industrial incineration sources and as such this category has not been 

inventoried
Appendix 2 – 2015 Medford CO LMP

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3.4.3.1.1.2 Commercial/Institutional Incineration

The 1993 attainment year emission inventory considered this category (given as “Commercial/Instititional OnSite Incineration) as an Area source. In 2008 this category was treated under point sources; Please see Part 2.3 

of this document for point source methodology.

3.4.3.1.1.3 Residential Incineration

Residential on-site solid waste incineration activity is assumed to be zero. DEQ rules outlining structural 

requirements, source tests, and continuous emission monitoring, as well as associated permit costs, preclude 

individual residential construction of incineration devices. Destruction of solid waste and yard debris at 

residential sites is included in residential open burning calculations.

3.4.3.1.2 Open Burning

This category includes waste material disposal from industrial, commercial / institutional, and residential 

sources in open outdoor fires, burn barrels or incinerators which do not meet DEQ emission limits, or burn in a 

manner in which combustion air is not effectively controlled and combustion products do not vent through a 

stack or chimney.

3.4.3.1.2.1 Industrial Open Burning

Industrial open burning is prohibited in the Medford UGB except by special letter permit issued by DEQ’s 

Western Region Office. No industrial open burning was permitted within the Medford UGB in 2008 945, 946. 

Industrial Open Burning emissions estimates are detailed in Table 2.4.11.

3.4.3.1.2.2 Commercial/Institutional Open Burning

This category is specific to the clearing of land for new construction and the burning of organic material (i.e. 

trees, shrubs and other vegetation). Jackson County Commercial and Institutional Open Burning emissions are 

from the EPA 2008 National Emissions Inventory (NEI) database. Using Jackson County land use zoning 

acreage, GIS allocations were created to approximate both the location and magnitude of emissions, see 

Appendix B, Table B-1. Annual CO Medford UGB Emissions were estimated by multiplying the county 

emissions by the GIS allocation (%) for the appropriate land use zoning classification (ID #8: Commercial Lawn 

& Garden: Commercial Zones).

Burn permits and complaints were provided by the DEQ Medford office12,14 and City of Medford Fire 

District13,15, and burn days and type of burn were based on the information.

Latitude and longitude data obtain from the permits were used in Google earth to determine which burn

locations were inside the UGB area. Figure 10 shows all commercial open burning location from permits and 

complaints within Medford UGB area. 
Appendix 2 – 2015 Medford CO LMP

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Figure 10: 2008 Commercial Open Burning Locations

There were no CO emission in the CO season because there were no permitted commercial burns and no 

record of illegal burns.

3.4.3.1.2.3 Residential Open Burning (back yard burning)

Residential open burning includes the outdoor burning of wood, leaves, land clearing debris, and household 

waste. Household waste often referred to as residential municipal solid waste (MSW), is a term for 

nonhazardous refuse produced by households (e.g. paper, plastics, metals, wood, glass, rubber, leather, 

textiles, and food wastes).

Jackson County residential open burning emissions are from the EPA 2008 National Emissions Inventory (NEI) 

database.

Using Jackson County land use zoning acreage, GIS allocations were created to approximate both the location 

and magnitude of emissions, see Appendix B, Table B-1. Annual CO Medford UGB emissions were estimated 

by multiplying the county emissions by the GIS allocation (%) for the appropriate land use zoning classification

(ID #9: Residential Lawn & Garden: Residential Zoning).

Burn permits and complaints were provided by the DEQ Medford office12,14 and City of Medford Fire 

District 13,15, and burn days and type of burn were based on the information.

Latitude and longitude data obtain from the permits were used in Google earth to determine which burn

locations were inside the UGB area. Figure 11 shows all residential open burning location from permits and 

complaints within Medford UGB area.
Appendix 2 – 2015 Medford CO LMP

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Figure 11: 2008 Residential Open Burning Locations

Weekly activity values use based on EPA’s document16. Open burning can be expected to take place seven 

days a week. Typical Season Day emissions were calculated by multiplying the UGB annual emissions tons by 

the Seasonal Adjustment Factor (SAF), which includes burning complaints (violations record) and permitted 

burning during peak Season and total burning days annual activity, divided by activity days per week, 

multiplied by 52 weeks per year using the following formula:

CO Typical Season Day (lbs/day) = (Annual UGB Emissions (tons/year) *2000 (lb/ton)* SAF)/ (Activity (days/wk) 

* 52 (wk/year))

Residential Open Burning emissions estimates are detailed in Table 2.4.10

3.4.3.2 Small Stationary Fossil Fuel and Wood Use

This category includes small furnaces, heaters, heating units, and cooking devices that emit fewer than 100 

tons of CO per year. Four main types of fuel are used within the Medford UGB by industrial, 

commercial/institutional, and residential sources: fuel oils, natural gas, liquefied petroleum gas (LPG), and 

wood. Wood fuel use is evaluated only for residential sources, where wood use is primarily in fireplaces,

wood stoves, furnaces, and for cooking; fossil fuel use by residential sources is evaluated for space heating or

cooking purposes only. Use of these fuels by industrial and commercial sources for other purposes is included 

in the point source inventory. 

3.4.3.2.1 Fuel Oil Combustion

Fuel oil emissions from industrial/commercial/institutional sources are from fuel consumption in large or small 

boilers, furnaces, heaters, and other heating devices. Residential fuel oil emission sources are primarily from 

fuel consumption in furnaces, heaters, and other heating devices. For this inventory, industrial and 
Appendix 2 – 2015 Medford CO LMP

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commercial fuel oil use includes residual oil, distillate oil, and kerosene use; residential fuel oil consumption 

includes distillate and kerosene use only.

Jackson County emissions for fuel oil combustion are from the EPA 2008 NEI database. Since industrial and 

commercial fuel use emissions were not inventoried in the 2008 NEI, the respective 2011 NEI emissions were 

used. EPA county-wide industrial and commercial emissions were allocated to the Medford UGB using the 

2008 employee population data from the US Census Bureau and developing a ratio of UGB employees to 

county employees. The 2008 US Census employee population was downloaded from the following 

location: http://www.census.gov/econ/cbp/index.html. Two zip codes were used to represent the Medford 

UGB: 97501 and 97504. The residential emissions were allocated to the UGB by a ratio of the 2010 Medford 

UGB population to the county-wide population. The Medford UGB population was determined by mapping 

the census blocks with population and housing unit counts to the Medford UGB boundary using the GIS spatial 

analysis tool. The census block data with population and housing unit counts are from the 2010 Tiger/Line 

shapefiles. This type of shapefile is released every 10 years, so the 2010 shapefile was selected as the closest 

to year 2008. The following formula was used for spatial allocation:

Annual UGB emissions, tpy = Annual Jackson County Emissions (tons/year) * (UGB employee or population / 

Jackson County employee or population)

The employee data were used to allocate industrial and commercial fuel use, and the population data were 

used to allocate residential fuel use. Weekly activity and the SAF were taken from the 1993 EI.

3 Typical Season 

Day emissions were calculated by multiplying the UGB annual emissions tons by the SAF, divided by activity 

days per week, multiplied by 52 weeks per year, using the following formula. 

CO Typical Season Day Emission (lbs/day) = (Annual UGB Emissions (tons/year) * 2000 (lb/ton) *SAF)/ (Activity 

(days/wk) *52 (weeks/yr))

Area source fuel combustion emissions were reconciled with permitted point source emissions by subtracting 

emissions from point source fuel burning processes, broken down by the specific type of fuel, as shown in 

Appendix A, Table A-2. However, point source emissions to be removed were selected with the following two 

parameters:

• ACDP source emissions only, since the 2008 TV source double-count was resolved by the DEQ for the 

2008 NEI submittal.

• Jackson County sources only, excluding those sources inventoried in the Grants Pass area, since area 

sources inventoried were for the Medford UGB only

Fuel Oil Combustion emissions estimates are detailed in Table 2.4.3.

3.4.3.2.2 Natural Gas (NG) and Liquified Petroleum Gas (LPG)

Natural Gas (NG) and Liquefied Petroleum Gas (LPG) emissions from industrial and commercial sources are 

from fuel consumption in large or small boilers, furnaces, heaters, and other heating devices. Residential 

NG/LPG emission sources are primarily from fuel consumption in furnaces, heaters, and other heating devices. 

Jackson County emissions for NG and LPG were first extracted from the EPA 2008 NEI database. Since 

industrial and commercial NG/LPG use emissions were not inventoried in the 2008 NEI, the respective 2011 

NEI emissions were used. EPA county-wide industrial and commercial emissions were allocated to the 

Medford UGB using the 2008 employee population data from the US Census Bureau and developing a ratio of 
Appendix 2 – 2015 Medford CO LMP

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UGB employees to county employees. The residential emissions were allocated to the UGB by the ratio of the 

2010 Medford UGB population data divided by the county-wide population. The UGB population was 

determined using the same method and data described in section 2.4.3.3.1. The following formula was used 

for spatial allocation:

Annual UGB emissions, tpy = (Annual Jackson County Emissions (tons/year)) * (UGB employee or population / 

Jackson County employee or population)

The employee data were used to allocate industrial and commercial NG/LPG use, and the population data 

were used to allocate residential NG/LPG use. Typical Season Day emissions were calculated by multiplying 

the UGB annual emissions tons by the SAF, divided by activity days per week, and multiplied by 52 weeks per 

year. Weekly activity and SAFs were taken from the 1993 EI.

3

CO Typical Season Day Emission (lbs/day) = (Annual UGB Emissions (tons/year) * 2000 (lb/ton) *SAF)/ (Activity 

(days/wk) *52 (weeks/yr))

Area source fuel combustion emissions were reconciled with permitted point source emissions by subtracting 

emissions from point source fuel burning processes, broken down by the specific type of fuel, as shown in 

Appendix A, Table A-2. However, point source emissions to be removed were selected with the following two 

parameters:

• ACDP source emissions only, since the 2008 TV source double-count was resolved by the DEQ for the 

2008 NEI submittal.

• Jackson County sources only, excluding those sources inventoried in the Grants Pass area, since area 

sources inventoried were for the Medford UGB only

NG and LPG emission estimates are detailed in Table 2.4.4 and Table 2.4.5. 

3.4.3.2.3 Coal and Biomass Combustion

Jackson County emissions for coal and biomass were extracted from the EPA 2011 NEI since they were not 

inventoried in the 2008 NEI. EPA county-wide industrial and commercial emissions were allocated to the 

Medford UGB using the 2008 employee population data from the US Census Bureau and developing a ratio of 

UGB employees to county employees. The following formula was used for spatial allocation:

Annual UGB emissions, tpy = (Annual Jackson County Emissions (tons/year)) * (UGB employee / Jackson 

County employee)

The employee data were used to allocate industrial and commercial coal and biomass use. Typical Season Day 

emissions were calculated by multiplying the UGB annual emissions tons by the SAF, divided by activity days 

per week, and multiplied by 52 weeks per year. Weekly activity and SAFs were not provided in the 1993 EI3, so 

the same values as the fuel oil use were used.

CO Typical Season Day Emission (lbs/day) = (Annual UGB Emissions (tons/year) * 2000 (lb/ton) *SAF)/ (Activity 

(days/wk) *52 (weeks/yr))

Coal and biomass emission estimates are detailed in Table 2.4.14 and Table 2.4.15. 
Appendix 2 – 2015 Medford CO LMP

Page 38

3.4.3.3 Residential Wood Combustion

Wood is an important residential space-heating source in Oregon. As a heating source, wood contributes a 

significant percentage of pollutants to an airshed when compared to fuel oil and NG/LPG. Because the CO 

season in Medford occurs during the winter months when residential wood combustion is at its height, 

emissions from residential wood burning are considered, and have been estimated, to be significant in the 

UGB.

Jackson County emissions for Residential Wood Combustion were extracted from the EPA 2008 NEI database. 

Annual UGB emissions were estimated by multiplying county-wide emissions by the ratio of the UGB 

population to county population. The UGB population was determined using the same method and data 

described in section 2.4.3.3.1. The following formula is used for spatial allocation:

Annual UGB emissions, tpy = Annual Jackson County Emissions (tons/year) * (UGB population / Jackson 

County population)

Typical season day emissions were calculated by multiplying the UGB annual emissions tons by the SAF, 

divided by activity days per week, and multiplied by 52 weeks per year. The SAFs were obtained from the 

1993 EI.

1 Weekly activity is 7 days per week based on the need for heating from this fuel source, which is 

consistent with the 1993 EI.

1

Residential Wood Combustion emissions estimates are detailed in Table 2.4.6.

3.4.3.4 Miscellaneous Area Sources

The area sources described in this section are combustion sources and include forest wildfires, prescribed 

burning, and structural fires.

3.4.3.4.1 Forest Wildfires

DEQ staff analyzed EPA 2008 NEI fire event data17, to determine wildfire emissions for the Medford UGB and a 

10-mile buffer around the UGB. The 10-mile buffer was chosen because it captured most of the northern 

valleys in the area that might drain towards Medford. Since EPA NEI fire event emission data is specific to 

date, direct estimation of annual and seasonal emissions is possible without relying on an SAF from other 

reference sources. Seasonal emissions were determined to be 0 lbs/day. Forest wild fire emissions estimates 

and references are detailed in Table 2.4.7.

3.4.3.4.2 Prescribed Burning

By definition, “prescribed burning” means forest debris or woody vegetation to be burned under the Oregon 

Smoke Management Plan administered by the Oregon Department of Forestry pursuant to OAR 477.515. To 

estimate prescribed burning emissions, DEQ staff analyzed EPA 2008 NEI fire event data17, for the Medford 

UGB and a 10-mile buffer around the UGB. The 10-mile buffer was chosen because it captured most of the 

northern valleys in the area that might drain towards Medford. Since EPA NEI fire event emission data is 

specific to date, direct estimation of annual and seasonal emissions is possible without relying on an SAF from 

other reference sources. 

Use of the EPA data resulted in a significant increase in prescribed burning emissions estimates - two orders of 

magnitude larger than the estimate for the 1993 attainment year plan. However, emission inventory staff for 

the attainment year plan did not have access to the considerably more exact prescribed burning data currently 

available from EPA for 2008. Prescribed burning emission estimates and details are found in Table 2.4.8.
Appendix 2 – 2015 Medford CO LMP

Page 39

3.4.3.4.3 Structure Fires

Josephine County structure fires emissions are from DEQ’s 2008 county-wide emissions submitted to the EPA 

National Emissions Inventory (NEI).

Annual CO Medford UGB emissions are estimated by multiplying county-wide emissions by the ratio of the 

2008 UGB population to county population (population data taken from the US Census Bureau) using the 

following formula:

Annual UGB emissions, tpy = UGB Emissions (tons/year) * (UGB population / Josephine county population)

The Seasonal Adjustment Factors (SAF) was estimated from Oregon Fire Marshal data specific to Medford. 

Weekly activity are taken from the EPA procedures document2. Typical Season Day emissions were calculated 

by multiplying the UGB annual emission tons by the SAF, divided by activity days per week, multiplied by 52 

weeks per year using the following formula:

CO Typical Day Emissions (lb/day) = (Annual UGB Emissions (tons/year) *2000 (lb/ton)* SAF)/ (Activity 

(days/wk) * 52 (wk/year))

Structure Fires emissions estimates are detailed in Table 2.4.9.
Appendix 2 – 2015 Medford CO LMP

Page 40

Area Source Emissions Summaries and Estimates

Figure 12: Area Source Annual Emissions by Percentage

Figure 13: Area Source Season Day Emissions By Percentage

Prescribed 

Burning

46%

RWC: NonCertified 

Devices

29%

RWC: Certified 

Devices

12%

RWC: Fireplaces

6%

All other 

sources

7%

Prescribed 

Burning

47%

RWC: NonCertified 

Devices

29%

RWC: Certified 

Devices

12%

RWC: Fireplaces

7%

All other 

sources

5%
Appendix 2 – 2015 Medford CO LMP

Page 41

Table 2.4. 1: Medford 2008 CO EI Summary of Estimation Procedures for Area Sources

Table 2.4. 2: Medford 2008 CO EI Summary of Emissions Estimates for Area Sources
Appendix 2 – 2015 Medford CO LMP

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Table 2.4. 3: Area Source Emissions From Fuel Oil Use
Appendix 2 – 2015 Medford CO LMP

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Table 2.4. 4: Area Source Emissions From Natural Gas (NG) Use
Appendix 2 – 2015 Medford CO LMP

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(1) (2) (3) (4) (5) (6)

SCC and Category Description

County 

Emissions 

Spatial 

factor

Annual UGB 

Emissions Activity 

Seasonal 

Adjustment 

Factor

CO Typical Season Day 

Emissions

(tons/year (%) (tons/year) (days/week) (SAF) (lbs/day)

SCC 21-02-006-000 69.70 31% 21.6 6 1.0 139

Industrial: NG ------- -------

ACDP Emissions (7) 29.5 219

------- -------

Reconciled Emissions Estimate (8) 0 0

SCC 21-03-006-000 55.10 79% 43.5 6 1.4 391

Comm/Inst. NG ------- -------

ACDP Emissions (7) 18.7 104

------- -------

Reconciled Emissions Estimate (8) 24.8 287

SCC 21-04-006-000 45.56 38% 17.3 7 1.7 162

Residential: NG

-------- --------

Total CO UGB Emissions 42.1 448

(tpy):

Total CO UGB Typical 

Season Day Emissions 

(lbs/day):
Appendix 2 – 2015 Medford CO LMP

Page 45

Table 2.4. 5: Area Source Emissions From Liquified Petroleum Gas (LPG) Use
Appendix 2 – 2015 Medford CO LMP

Page 46
Appendix 2 – 2015 Medford CO LMP

Page 47

Table 2.4. 6: Area Source Emissions From Residential Wood Combustion
Appendix 2 – 2015 Medford CO LMP

Page 48

Table 2.4. 7: Area Source Emissions From Wildfires
Appendix 2 – 2015 Medford CO LMP

Page 49

Table 2.4. 8: Area Source Emissions From Prescribed (RX) Burning
Appendix 2 – 2015 Medford CO LMP

Page 50

Table 2.4. 9: Area Source Emissions From Structure Fires
Appendix 2 – 2015 Medford CO LMP

Page 51

Table 2.4. 10: Area Source Emissions From Residential Open Burning
Appendix 2 – 2015 Medford CO LMP

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Table 2.4. 11: Area Source Emissions From Industrial Open Burning

Table 2.4. 12: Area Source Emissions From Commercial/Institutional Open BUrning

(1) (2) (3) (4) (5) (6)

SCC and Category 

Description

County 

Emission 

Spatial 

factor

Annual UGB 

Emissions Activity 

Seasonal 

Adjustment 

Factor

CO Typical 

Season Day 

Emission

(tons/year) (%) (tons/year) (days/week) (SAF) (lbs/day)

Legal Burning - Permitted

SCC: 26-10-000-500

Commercial / 

Institutional Open 

Burning

166 50.3% 84 5 0 0

Notes:

(1). The MS Access application used to query both databases is located at : 

\\deqhq1\EI_FILES\2008_Medford_Second_LMP_CO\Final_EI\2008_NEI\Final_Data_ForBrian.accdb

(2) Spatial Factor (%), using Josephine County land use zoning acreage GIS Allocation Results were 

created to approximate both the location and magnitude of emissions. County-Wide emission 

estimates were allocated by UGB percentage taken from Appendix X, Table C-X, 

(ID 8 = Commercial Lawn & Garden: Commercial Zones) GIS Allocation Results:

Josephine County Zones, County-Wide and by UGB. Spatial surrogates are typically used to approximate 

emissions inside smaller boundaries from larger boundaries.

(3) Annual UGB Emissions: (tons/year)= County Emissions (tons/year)*Spatial Factor (%)

(4) Activity values used in the 1993 EI : Activity is based on the assumption that an individual commercial 

 employee works 5 days per week even if the commercial source's operation runs 7 days per week.

 This employee activity is important because the emissions are based on employee population numbers.

(5) Seasonal Adjustment Factor (SAF)= (0 peak season activity * 12 months)/(173 annual activity * 3 months) 0

Burn days include complaint(illegal) burn data and permitted burns (DEQ Ref.951, 952 and 946)

(6) CO Typical Season Day Emissions [lb/day] =

((Annual Emissions [tons/year]) * (2000 [lb./ton]) * (SAF))/ ((Activity [days/wk]) * (52 [wk./year]))
Appendix 2 – 2015 Medford CO LMP

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Table 2.4. 13: Area Source Emissions From Coal Use
Appendix 2 – 2015 Medford CO LMP

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Table 2.4. 14: Area Source Emissions From Biomass Burning
Appendix 2 – 2015 Medford CO LMP

Page 55

3.5 Nonroad Vehicles and Equipment

3.5.1 Introduction and Scope

This section describes the development of the emission inventory for carbon monoxide for nonroad mobile

sources located in the Medford UGB in the 2008 CO Limited Maintenance Plan year. Sources inventoried 

within the nonroad mobile sector include off-road gasoline and diesel-powered vehicles and equipment, 

aircraft, and railroads as well as recreational and commercial waterborne vessels.

As with most of the area source categories, emissions within the Medford UGB were developed by applying 

SCC-specific spatial and temporal scaling factors to county-wide estimates of annual emissions for Jackson 

County from the 2008 NEI pursuant to the methodology outlined in the IPP.

Table 2.5.1 summarizes the nonroad mobile source emission inventory for the major nonroad source 

categories in terms of both annual and daily emissions (adjusted for activity during the CO season). Figures 2-

1 through 2-4 compare emissions of the nonroad emission subcategories.

3.5.2 Nonroad Vehicles and Equipment

This category encompasses 2-stroke gasoline, 4-stroke gasoline, Compressed Natural Gas (CNG) / Liquefied 

Petroleum Gas (LPG), and diesel vehicles and equipment. Each of the sub-categories includes the following 

vehicle categories: Recreational Equipment, Construction Equipment, Industrial Equipment, Lawn/Garden 

Equipment, Agricultural Equipment, Light Commercial Equipment, and Logging Equipment. 

3.5.2.1 Vehicle Categories

The nonroad vehicles and equipment category includes the following gasoline, CNG/LPG, and diesel sources:

SCC: 22-xx-001-xxx: Recreational Equipment

SCC: 22-xx-002-xxx: Construction Equipment

SCC: 22-xx-003-xxx: Industrial Equipment

SCC: 22-xx-004-xxx: Lawn / Garden Equipment

SCC: 22-xx-005-xxx: Agricultural Equipment

SCC: 22-xx-006-xxx: Light Commercial Equipment

SCC: 22-xx-007-xxx: Logging Equipment

3.5.2.2 Methodology

The starting point for emissions estimates for sources in this category was the county-wide, annual CO 

emissions from the EPA 2008 NEI. Using Jackson county land use zoning acreage,

7 GIS-based spatial allocation 

factors were created to estimate the fraction of county-wide emissions from each of the vehicle types 

(Appendix A, Table A-1) occurring within the Medford UGB. Annual Medford UGB emissions were estimated 

by multiplying the county-wide emissions by the spatial factor (%) for the appropriate zoning ID. The following 

formula was used for spatial allocation:

Annual UGB emissions [tpy] = Annual Jackson County Emissions (tons/year) * Spatial Allocation Factor 

Typical CO Season Day emissions were calculated by multiplying the UGB annual emissions tons by the SAF) 

divided by 365 days per year. SAFs were taken from the 1993 EI.

3 The activity is assumed to be 7 days per 

week across all vehicle types to be consistent with the 1993 EI.

3

CO Typical Season Day Emission [lbs/day] = (Annual UGB Emissions (t/yr) * 2000(lb/ton) *SAF)/ (365 days/yr))
Appendix 2 – 2015 Medford CO LMP

Page 56

Nonroad vehicle and equipment emissions are detailed in Tables 2.5.2 through 2.5.5.

3.5.3 Aircraft and Airport Operations Emissions

The aircraft and airport operation emission source categories inventoried include commercial and military 

aircraft, general aviation, air taxi, airport auxiliary power unit, and airport ground service equipment (GSE). 

Annual Jackson County CO emissions from aircraft and airport operation were obtained from the 2008 NEI.

*

 

Annual Medford UGB CO emissions were estimated by multiplying the county-wide emissions by appropriate

spatial allocation factors. Spatial factors for general aviation and air taxi were calculated by dividing the total 

aircraft-related emissions by those of the Jackson County. The military and commercial aircraft, auxiliary 

power unit, and GSE were assigned a 100% spatial allocation factor since all these sources occur at the Rouge 

Valley International Medford Airport located within the UGB, which is the sole commercial airport operating in 

Jackson County. The details of these calculations and a summary of aircraft and airport emissions are given in 

Table 2.5.6.

3.5.4 Waterborne Vessels

Waterborne vessels fall under two categories: commercial/military marine vessels and recreational pleasure 

craft. Although pleasure craft emissions occur in other areas of Jackson County, neither category of 

waterborne vessel has any activity within the Medford UGB due to lack of sufficient water bodies and inland 

location to support such activity. As such, waterborne vessel emissions within the Medford UGB were set to 

zero.

3.5.5 Rail

Railroad emissions encompass both locomotive operation and railway maintenance as shown by individual 

SCC category below.

SCC: 22-85-002-007: Locomotives: Line-Haul

SCC: 22-85-002-010: Locomotives: Yard

County-wide annual emissions for railroads were taken from the EPA 2008 NEI database.

†

 Jackson County 

annual emission estimates for locomotive emissions were allocated using only active track miles within the 

Medford UGB and locating railroad yard activity within the Medford UGB using the railway GIS shapefiles in 

the 2008 NEI supporting data. 

The 2008 NEI had no railway maintenance emissions for Jackson County; therefore, emissions for these SCC 

categories were set to zero for the Medford UGB.

Typical Season Day emissions were calculated by multiplying the UGB annual emissions tons by the SAF, 

divided by 365 days per year. To be consistent with the 1993 EI,

3 seasonal activity is assumed to be uniform 

and the SAF is equal to 1.0. 

 * Aircraft and airport operations have traditionally been classified within the Nonroad Mobile Source sector. Although their SCC 

classifications have not changed, EPA grouped them within the Point Source sector beginning with the 2008 NEI. To maintain 

consistency with previous Medford air quality plans and emission inventories, these emissions continue to be reported within the

Nonroad sector.

† Railroad have traditionally been classified within the Nonroad Mobile Source sector. Although their SCC classifications have not 

changed, EPA grouped them within the Non-Point (Area) Source sector beginning with the 2008 NEI. To maintain consistency with 

previous Medford air quality plans and emission inventories, these emissions continue to be reported within the Nonroad sector.
Appendix 2 – 2015 Medford CO LMP

Page 57

CO Typical Season Day Emission [lbs/day] = (Annual UGB Emissions (t/yr) * 2000(lb/ton) *SAF)/ (365 days/yr))

Railroad emission estimates are detailed in Table 2.5.7.
Appendix 2 – 2015 Medford CO LMP

Page 58

Figure 14: Distribution of Medford UGB Annual Nonroad Source CO Emissions, 2008

Figure 15: Percentage of Medford Annual Nonroad CO Source Emissions, 2008
Appendix 2 – 2015 Medford CO LMP

Page 59

Figure 16: Distribution of Medford CO Season Day Nonroad Source Emissions, 2008

Figure 17: Percentage of Medford UGB CO Season Day Nonroad Source Emission, 2008
Appendix 2 – 2015 Medford CO LMP

Page 60

Table 2.5. 1: Medford UGB 2008 CO Summary of Emissions from Nonroad Sources

CO Annual UGB 

Emissions 

(tons/yr)

CO Typical 

Season Day 

Emissions 

(lbs/day)

GAS, 2-Cycle

 Recreational Equipment 2.5.2 22-60-001-xxx 0.0 0.0

 Construction Equipment 2.5.2 22-60-002-xxx 12.2 36.2

 Industrial Equipment 2.5.2 22-60-003-xxx 0.1 0.3

 Lawn / Garden Equipment 2.5.2 22-60-004-xxx 225 12

 Agricultural Equipment 2.5.2 22-60-005-035 0 0

 Light Commercial Equipment 2.5.2 22-60-006-xxx 17 93

 Logging Equipment 2.5.2 22-60-007-005 0 0

Category Subtotal 254 142

GAS, 4-Cycle

 Recreational Equipment 2.5.3 22-65-001-xxx 0 0

 Construction Equipment 2.5.3 22-65-002-xxx 63 138

 Industrial Equipment 2.5.3 22-65-003-xxx 32 172

 Lawn / Garden Equipment 2.5.3 22-65-004-xxx 2,322 127

 Agricultural Equipment 2.5.3 22-65-005-xxx 0 0

 Light Commercial Equipment 2.5.3 22-65-006-xxx 1,378 7,476

 Logging Equipment 2.5.3 22-65-007-xxx 0 0

Category Subtotal 3,795 7,914

CNG/LPG

 Recreational Equipment 2.5.4 22-67,68-xxx-xxx 0 0

 Construction Equipment 2.5.4 22-67,68-xxx-xxx 2 4

 Industrial Equipment 2.5.4 22-67,68-xxx-xxx 190 1,031

 Lawn / Garden Equipment 2.5.4 22-67,68-xxx-xxx 2 0

 Agricultural Equipment 2.5.4 22-67,68-xxx-xxx 0 0

 Light Commercial Equipment 2.5.4 22-67,68-xxx-xxx 0 0

 Logging Equipment 2.5.4 22-67,68-xxx-xxx 0 0

Category Subtotal 194 1,036

Diesel

 Recreational Equipment 2.5.5 22-70-001-xxx 0 0

 Construction Equipment 2.5.5 22-70-002-xxx 65 146

 Industrial Equipment 2.5.5 22-70-003-xxx 12 60

 Lawn / Garden Equipment 2.5.5 22-70-004-xxx 4 0

 Agricultural Equipment 2.5.5 22-70-005-xxx 0 0

 Light Commercial Equipment 2.5.5 22-70-006-xxx 20 123

 Logging Equipment 2.5.5 22-70-007-xxx 2 0

Category Subtotal 104 329

VEHICLE SUBTOTAL Category Subtotal 4,348 9,421

AIRCRAFT

Military Aircraft 2.5.6 22-75-001-000 2 4

Aircraft: Commercial Aircraft 2.5.6 22-75-020-000 17 86

Aircraft: General Aviation 2.5.6 22-75-050-xxx 48 155

Aircraft: Air Taxi 2.5.6 22-75-060-xxx 7 37

Aircraft Auxillary Power Unit 2.5.6 22-75-070-000 2 12

Airport GSE 2.5.6 22-xx-008-005 61 330

Category Subtotal 138 624

RAILROADS

Locomotives: Line-Haul 2.5.7 22-85-002-007 0 1

Locomotives: Yard 2.5.7 22-85-002-010 3 15

Category Subtotal 3 16

MARINE VESSELS

Commercial Marine Vessels 2.5.8 22-80-004-000 0 0

Pleasure Craft-Diesel-Inboard/Stern 2.5.8 22-82-020-005 0 0

Pleasure Craft-Diesel-Outboard 2.5.8 22-82-020-010 0 0

Pleasure Craft-Gasoline 2-Stroke-Ou 2.5.8 22-82-005-010 0 0

Pleasure Craft-Gasoline 2-Stroke-Per 2.5.8 22-82-005-015 0 0

Pleasure Craft-Gasoline 4-Stroke-Inb 2.5.8 22-82-010-005 0 0

Category Subtotal 0 0

(tons/yr) (lbs/day)

TOTAL NON-ROAD 4,488 10,061

2008 EI

Source Description Table # SCC Code
Appendix 2 – 2015 Medford CO LMP

Page 61

Table 2.5. 2: Medford UGB 2008 CO, Summary of Emissions from Nonroad Gasoline Vehicles * Equipment, 2-

Cycle
Appendix 2 – 2015 Medford CO LMP

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Appendix 2 – 2015 Medford CO LMP

Page 63

Table 2. 5. 3. 2008 Medford UGB CO: Summary of Emissions from Nonroad Gasoline Vehicles and 

Equipment, 4-Cycle
Appendix 2 – 2015 Medford CO LMP

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Appendix 2 – 2015 Medford CO LMP

Page 65

Table 2. 5. 4. 2008 Medford UGB CO: Summary of Emissions from Nonroad CNG/LPG Vehicles and 

Equipment
Appendix 2 – 2015 Medford CO LMP

Page 66
Appendix 2 – 2015 Medford CO LMP

Page 67

Table 2. 5. 5. 2008 Medford UGB CO: Summary of Emissions from Nonroad Diesel Vehicles and Equipment
Appendix 2 – 2015 Medford CO LMP

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Appendix 2 – 2015 Medford CO LMP

Page 69

Table 2.5. 6. 2008 Medford UGB CO: Summary of Emissions from Aircraft and Airport GSE
Appendix 2 – 2015 Medford CO LMP

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Appendix 2 – 2015 Medford CO LMP

Page 71

Table 2.5. 7. 2008 Medford UGB CO: Summary of Emissions from Railroads

(1) (2) (3) (5)

SCC and Category Description

County 

Emission 

Spatial 

factor

Annual UGB 

Emissions

CO Typical Season Day 

Emissions

(tons/year) (%) (tons/year) (lbs/day)

SCC 22-85-002-007 6.66 3% 0.22 1.21

Locomotives: Line-Haul

SCC 22-85-002-010 8.01 33% 2.67 14.63

Locomotives: Yard

-------- --------

 Total CO UGB Emissions (tpy) : 3 16

Notes for Table 2.5.7

(1) The data are from the 2008 NEI, summarized in the file "MedfordCOLMP_2008NEI_Jackson_County.xlsx." (References 5 and 18)

 https://gis.odot.state.or.us/transGIS/

Jackson 

County

Medford UGB Spatial Factor

Line-haul 138.3 4.6 3.33%

Yard 3 1 33.33%

(3) Annual UGB CO Emissions (tons/year) = County Emissions (tons/year)*Spatial Factor (%).

(4) Seasonal Adjustment Factor (SAF) is obtained from Table 2.5.6 of Oregon 1993 Medford UGB Carbon Monoxide Attainment year SIP Emission Inventory

(5) CO Typical Season Day Emissions [lbs/day] = ((Annual Emissions [tons/yr] * 2000 [lbs/ton]) * SAF) / (365 [days])

Total CO UGB Season Typical 

Day Emissions (lbs/day):

(2) Spatial factor (%) allocates county-wide emissions to UGB. The spatial surrogates for line-haul and yard emissions are track miles and yard locations, 

respectively. Track miles were obtained from 2008 NEI railway shapfile, and yard locations were identified by using ODET TransGIS: 

(4)

Seasonal Adjustment Factor

(SAF)

1

1
Appendix 2 – 2015 Medford CO LMP

Page 72

3.6 On-Road Mobile Sources

3.6.1 Introduction and Scope

This section describes the development of the emission inventory for CO from on-road mobile 

sources in the Medford UGB for the 2008 CO LMP analysis year. On-road emission estimates 

from Version 3 of the 2008 NEI database were used to represent countywide emissions. (The 

on-road emission estimates in Version 3 of the 2008 NEI were developed using EPA’s 

MOVES2010b vehicle emissions model.) On-road sources included in this inventory were 

grouped by both vehicle type and road type. Separate sets of on-road CO emissions 

categorized by vehicle type and by road type were estimated and reported.

3.6.2 Spatial and Temporal Allocation of 2008 NEI Data

3.6.2.1 Spatial Allocation

County-wide 2008 on-road exhaust emissions from the 2008 NEI were allocated to the Medford 

UGB using spatial surrogates based on vehicle miles traveled (VMT). The spatial factor was 

calculated by dividing the Medford UGB annual VMT by the Jackson County annual VMT in 

2008. Medford UGB annual VMT was calculated from the model output of the RVMPO “Models 

Version 3.0” travel demand model.8 Jackson County annual VMT was calculated from the 

monthly VMT provided in the 2008 NEI supporting “4c” archive file3 database for transportation 

activity. Table 2.6.1 and Table 2.6.2 detail spatial allocation of data for on-road mobile sources. 

The following formula was used for spatial allocation:

Annual UGB emissions, tpy = Annual Jackson County Emissions (tons/year) * (UGB Annual VMT 

/ Jackson County Annual VMT)

3.6.2.2 Temporal Allocation

Typical Season Day CO emissions were calculated by multiplying the UGB annual emissions tons 

by the SAF, divided by 365 days per year. The SAFs for on-road emissions grouped by vehicle 

type were calculated using the values in Table 2.6.5 in the 1993 EI.

1 The SAFs for on-road 

emissions grouped by road type were taken from Table 2.6.3 in the 1993 EI,

1 and the weekly 

adjustment factors were taken from Table 2.6.4 in the 1993 EI1. The following formula was 

used for temporal allocation:

CO Typical Season Day Emission (lbs/day) = (Annual UGB Emissions (tons/year) * 2000 (lb/ton) 

*SAF)/ (365 days/year)

3.6.3 Summary of On-Road Mobile Source Emissions

On-road mobile emissions have been summarized by vehicle type and roadway type for annual 

and season day emissions in Figures 19 through 21, and Tables 2.6.1 and 2.6.2 respectively.

The CO Season daily emissions are nominally different in Tables 2.6.1 and 2.6.2 because of the 

SAFs, which were taken from the 1993 Attainment Year EI1. Although these SAFs gave the same 

 3 ftp://ftp.epa.gov/EmisInventory/2008v3/doc. 
Appendix 2 – 2015 Medford CO LMP

Page 73

CO Season daily emissions in respective tables in the 1993 EI, they result in slightly different CO 

season daily emissions when applied to the 2008 NEI.

Figure 18: Percentage of 2008 Medford Annual Onroad CO Source Emissions, by Vehicle Type

Figure 19: Percentage of 2008 Medford Season Day Onroad CO Source Emissions, by Vehicle 

Type

LDGV

32%

LDGT2

36%

LDGT4

19%

HDDV

3%

ALL OTHER 

TYPES

10%

LDGV

32%

LDGT2

36%

LDGT4

19%

HDDV

3%

ALL OTHER 

TYPES

10%
Appendix 2 – 2015 Medford CO LMP

Page 74

Figure 20: Percentage of 2008 Medford Annual Onroad CO Source Emissions, by Roadway 

Type

Figure 21: Percentage of 2008 Medford Season Day Onroad CO Source Emissions, by Roadway 

Type

Interstate

14%

Arterial

Collector 17%

7%

Local

Parking Area 5%

57%

Interstate

16%

Arterial

Collector 17%

6%

Local

5%

Parking Area

56%
Appendix 2 – 2015 Medford CO LMP

Page 75

Table 2.6. 1. 2008 Medford UGB CO: Summary of On-Road Mobile Emissions by Vehicle Type
Appendix 2 – 2015 Medford CO LMP

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Appendix 2 – 2015 Medford CO LMP

Page 77

Table 2.6. 2. 2008 Medford UGB CO: Summary of On-Road Mobile Emissions by Road Type
Appendix 2 – 2015 Medford CO LMP

Page 78

4 Quality Assurance and Quality Control

4.1 Introduction

The Oregon DEQ is responsible for overall quality and accuracy of this inventory of Carbon 

Monoxide (CO) sources and emissions for the Medford urban growth boundary (UGB) for the 2008 

Limited Maintenance Plan. As presented in the IPP delivered to EPA in November 2014, DEQ used

existing data that has already been quality checked. DEQ staff performed quality assurance for 

accuracy, completeness, and representativeness on the spatial and temporal allocation of 

emissions from the existing inventory. DEQ and Sierra Research used EPA county database 

estimates from the 2008 NEI v.3 generated using MOVES2010b modeled emissions rates.

5,18

4.2 Organization and Personnel

Wesley Risher, an emission inventory analyst at the DEQ, was appointed Quality Assurance 

Coordinator. DEQ staff Brandy Albertson, Christopher Swab, and Miyoung Park, along with 

Wenxian Zhang at Sierra Research, performed the bulk of the required source calculations. The 

abbreviated organizational hierarchy for carrying out the Quality Assurance Program is shown 

below.

Oregon Department of Environmental Quality

Air Quality Division

Wendy Wiles, Administrator – Environmental Solutions Division 

Jeffrey Stocum, Manager – Air Quality Technical Services Section

Emission Inventory

Christopher Swab, Senior Emission Inventory Analyst

Brandy Albertson, Emission Inventory Analyst

Miyoung Park, Emission Inventory Specialist

Quality Assurance

Wesley Risher, Emission Inventory Analyst

David Collier,

Air Quality Planning Manager

Dave Nordberg, Air Quality Planner

Sierra Research

Tom Carlson, Principal Scientist

Wenxian Zhang, Associate Engineer
Appendix 2 – 2015 Medford CO LMP

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4.3 Data Collection and Analysis

4.3.1 Data Collection and Analysis

To ensure the comprehensive nature of the emission inventory, a source listing from the 1993 

attainment year inventory was used as a starting point1

. The listing of sources in the 1993 

inventory was generated using EPA's Quality Assurance Plan guidance document1 and EPA’s 

Procedures for the Preparation of Emissions for Carbon Monoxide And Precursors Of Ozone2 were 

used. The inventoried sources are marked under the appropriate pollutant category. Only those 

sources that had been determined to operate in the inventory areas were included

Inventory source categories were divided into Stationary Point Sources, Stationary Area Sources, 

Non-Road Mobile and On-Road Mobile Sources, the details of which are discussed in Parts 2.3 

through 2.6 of this report. Permitted stationary point source information is maintained by DEQ for 

sources with annual emissions of at least 5 tons per year, so a questionnaire/survey was not 

necessary to identify stationary area and point sources. Emissions from permitted point sources 

were calculated on the basis of 2008 production levels and the best available emission factors 

(from TV source tests or from the permits). Point sources considered in this inventory are listed in 

Appendix A, Table A-1. 

The majority of the area and nonroad source emissions data at annual, county-wide levels were

taken from previously compiled EPA and DEQ estimates that were subjected to QA/QC protocols5. 

Many of the stationary area sources and non-road mobile sources were allocated to UGB by 

applying a spatial surrogate developed using ArcGIS and zoning shapefiles. Zoning and railway line 

GIS work was reviewed for completeness and accuracy by DEQ staff familiar with the Medford 

UGB region and activity. Population, fuel use, and employee data was reviewed by DEQ staff as 

part of the QA/QC protocols outlined here. Additionally, in all cases, the source of the information 

and validation for its use was documented in the calculation spreadsheets and checked at the time 

of QC for reliability and appropriateness. 

4.4 DATA HANDLING

Data handling by DEQ staff included: 1) data tracking, and 2) QA/QC (which included data 

checking, data correcting, and handling corrected data). Specific additional procedures included 

checking data after conversion to the inventory format, checking for missing data, and reviewing 

the estimates.

4.5 Data Coding and Recording

No air dispersion modeling was performed for this SIP so coding the source emissions for entry 

into the model was not necessary.

4.6 Data Tracking

Information obtained from source files, other divisions of the DEQ, other State, Federal, and 

local agencies, and private companies used in compiling the emission inventories were 

recorded in reference files, in appendices, and documented on the calculation spreadsheets. 

The appendices and calculation spreadsheets were also stored electronically. All emission 
Appendix 2 – 2015 Medford CO LMP

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factors, throughputs, seasonal adjustment factors, and activities were documented on the 

calculation spreadsheets in both hard copy and electronic copy. All of the above mentioned 

information is kept at DEQ Headquarters.

4.7 QA/QC Procedures - Checking and Correcting

The QC of all source category emissions included: 

1. Checking input data for inventory completeness, missing data, incorrect calculations, 

incorrect information, and reasonableness, and

2. Correcting the calculation sheets, summary sheets, and Appendices where needed.

The QA of the emission estimates include:

1. Reviewing the emission summary for reasonableness, and

2. Ensuring that the data transferred between agencies and consultants was intact.

4.7.1 Checking Data

4.7.1.1 Inventory Completeness 

Completeness of the inventory was determined by checking against the EPA QA Plan guidance 

source listings and the 1993 attainment year inventory. Double counting of sources was 

reviewed to ensure that source categories included in stationary point source category were 

not also included in area or non-road mobile categories. Double-count removal is detailed in 

Tables 2.4.3 and 2.4.4 of this document.

4.7.1.2 Missing Data

In order to ensure that all the necessary data was submitted for each stationary point source, 

forms were created to identify all the data elements required by EPA to be reported for each 

stationary point source. Any parameter left blank during the initial completion of the form was 

considered a missing data element. Further review of the source files and, as necessary, 

contact with facility personnel were procedures used to obtain the missing information. If 

these steps did not result in supplying a missing data element, estimates were made based on 

similar point sources or from information contained in EPA publications. Written 

documentation of the source of the data were recorded in the Emission Inventory notebook on 

the Data Error Report and Correction form as well as in the Audit Trail notebook.

Missing data for stationary area sources and non-road mobile sources can usually be identified 

by the inability to calculate emissions. If the appropriate data was missing, a reasonable effort 

was made to acquire it. If this was unsuccessful, estimates were made based on data of recent 

years or on information contained in EPA documents. Missing data were recorded on the QC 

area and non-road mobile correction forms.

4.7.1.3 Incorrect Calculations

In order to ensure that all the calculations were done correctly, the calculations were first 

reviewed to ensure that they were used correctly, followed by review of electronic equations in 
Appendix 2 – 2015 Medford CO LMP

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order to make sure that they were entered correctly. Any improperly used or incorrect 

calculations were noted on the calculation sheet.

4.7.1.4 Incorrect Information

In order to ensure that the information on summary sheets, calculations sheets, and

Appendices for this report are correct, all the explanations, titles, and reference were checked 

for accuracy and clarity. Any changes were documented either directly on the sheet.

4.7.1.5 Reasonableness

A reasonableness check was performed on the estimated emissions, activity levels, and 

emission factors using the 1993 Medford Attainment Year CO SIP emission inventory1 as a 

background comparison.

Stationary point source estimated emissions associated with the Air Contaminant Discharge 

Permit, Title V Permit, or Title V draft for each identified point source were reviewed in relation 

to similar sources. In addition, the stationary point source production levels source tests, and 

permitted emission factors were rechecked. The source’s current operational status was also 

reviewed using notices of construction, permit addendums, and DEQ source inspector 

information. Stationary area source and non-road mobile estimated emissions were compared, 

when possible to the 1993 Medford Attainment Year CO SIP emission inventory1. The 

references from which the emission factors and activity levels were taken were confirmed for 

the appropriateness of their use. Any reasonableness errors were documented in the correction 

forms.

4.7.1.6 Emissions Summary Reasonableness

Emissions summaries were reviewed against the 1993 attainment year, as shown in Executive 

Summary Figures 3 and 4 of this document. 

4.8 Data Reporting

An electronic copy of this report will be provided to EPA Region X in June 2015. Electronic 

copies of the summary and calculations spreadsheets will be made available to EPA upon 

request.
Appendix 2 – 2015 Medford CO LMP

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5 References

1. State of Oregon 1993 Attainment Year SIP Emission Inventory: Medford UGB Carbon 

Monoxide, Appendix D3-4. Air Quality Division, Oregon Department of Environmental 

Quality, Portland, OR, March 9, 2001. (DEQ AQ-TS Ref. 618)

2. Procedures Document for National Emission Inventory, Criteria Air Pollutants 1985-1999, 

EPA-454/R-01-006, U.S. EPA, Research Triangle Park, NC. March 2001. (DEQ AQ-TS Ref. 

2)

3. Emission Inventory Requirements for Carbon Monoxide State Implementation Plans, EPA450/4-91-011, U.S. EPA, Research Triangle Park, NC. March 1991. (DEQ AQ-TS Ref. 1a)

4. Inventory Preparation Plan/Quality Assurance Plan for the Medford Urban Growth 

Boundary 2008 Carbon Monoxide (CO) Limited Maintenance Plan, Oregon Department of 

Environmental Quality, February 2015: Please see Appendix C.

5. http://www.epa.gov/ttnchie1/net/2008inventory.html.

6. 2008 National Emissions Inventory, Version 3, Technical Support Document, Draft, U.S. 

EPA, Research Triangle Park, Sep 2013.

7. The Jackson County zoning data were downloaded 

from http://gis.jacksoncounty.org/Portal/gis-data.aspx. 

8. Technical Memorandum: Modeling to Support the RVMPO 2015-2018 TIP Air Quality 

Conformity Determination (AQCD), prepared by Jin Ren with ODOT/TPAU, June 2014.

9. Grants Pass SIP Appendices for Carbon Monoxide. Appendix D4-4: Grants Pass UGB and 

CO NAA: 1993 Base Year and 2015 Forecast Year Emission Inventory and Forecast. Oregon 

DEQ. September 13, 2002. (DEQ AQ-TS Ref. 933)

10. Internet: http://www.epa.gov/ttnchie1/software/fire/index.html

11. Compilation of Air Pollutant Emission Factors, Fifth Edition and Supplements, AP-42, U.S. 

EPA, Research Triangle Park, NC. January 1995. (DEQ AQ-TS Ref. 8).

12. Email from Wayne Kauzlarich, DEQ WR Medford, AQ Permit Writer/Inspector to Miyoung 

Park. City of Medford burn information (2008year). November 28, 2014 (DEQ AQ-TS Ref. 

945).
Appendix 2 – 2015 Medford CO LMP

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13. Email from Greg G. Kleinberg, City of Medford , Deputy Chief - Fire Marshal, Medford FireRescue to Miyoung Park. City of Medford burn Information (2008 year). November 25, 

2014 (DEQ AQ-TS Ref. 946).

14. Email from Meghan Fagundes, DEQ WR Medford, AQ Permit Writer/Inspector to Miyoung 

Park. Complaint open burning locations for Jackson County in 2008. March 12, 2015 (DEQ 

AQ-TS Ref. 951).

15. Email from Greg G. Kleinberg, City of Medford , Deputy Chief - Fire Marshal, Medford FireRescue to Miyoung Park. City of Medford, illegal burn information (2008 year). March 

12, 2015 (DEQ AQ-TS Ref. 952).

16. Open Burning Emission factor: Emission Inventory Improvement Program (EIIP), EPA, 

Office of Air Quality Planning and Standards, Emission Factor and Inventory Group, 

Research Triangle Park, NC. Volume III: Chapter 16 (DEQ AQ-TS Ref. 947)

17. E-mail from Venkatesh Rao (EPA) to C. Swab. EPA 2008 Oregon/California prescribed 

burning and wildfire emissions estimates, EIS event format. August 3, 2011. (DEQ AQTS Ref. 762)

18. E-mail from Wenxian Zhang to C. Swab. Medford UGB 2008 CO LMP - Draft Emission 

Inventory. April 27, 2015. (DEQ AQ-TS Ref. 961).
Appendix 2 – 2015 Medford CO LMP

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6 Appendices to the Emission Inventory
Appendix 2 – 2015 Medford CO LMP

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APPENDIX A: STATIONARY PERMITTED POINT SOURCES

• Figure A-1: Point Source Locations

• Table A-1: Stationary Point Source Determination for 2008 CO Inventory Determination

• Table A-2: Exclusion of 1993 and some 2008 Facilities from CO Emission Inventory

• Table A-3: Stationary Point Source Emission Estimation Details
Appendix 2 – 2015 Medford CO LMP

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Appendix A, Figure A- 1: 2008 Medford CO LMP Permitted Point Source Locations
Appendix 2 – 2015 Medford CO LMP

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Appendix A, Table A- 1: Stationary Point Source Determination for 2008 CO Inventory

Appendix A, Table A- 2: Exclusion of 1993 and some 2008 Facilities from CO Emission Inventory
Appendix 2 – 2015 Medford CO LMP

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Appendix 2 – 2015 Medford CO LMP

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Appendix A, Table A- 3: Stationary Point Source Emission Estimation Details

(cont’d on next page)
Appendix 2 – 2015 Medford CO LMP

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Appendix A, Table A-3 Continued
Appendix 2 – 2015 Medford CO LMP

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APPENDIX B: STATIONARY AREA SOURCES

• Figure B-1: Wildfire and Prescribed Burning Locations

• Table B-1: GIS Allocation Results: Josephine County Zones, County-Wide and by UGB
Appendix 2 – 2015 Medford CO LMP

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Appendix B, Figure B- 1: Wildfire and Prescribed Burn Location and Date
Appendix 2 – 2015 Medford CO LMP

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Appendix B, Table B- 1: GIS Allocation Results: Josephine County Zones, County-Wide and by UGB
Appendix 2 – 2015 Medford CO LMP

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Notes for Table B-1
Appendix 3 - EPA Approval Letter

Justification for Discontinuation of Monitoring in Carbon 

Monoxide and PM10 Maintenance Areas

Submitted to: Keith Rose, EPA Region 10 

By: Anthony Barnack, Oregon DEQ 

October, 2011 

Last Updated: 12/01/11

By: Anthony Barnack

Report
This report prepared by: 

Oregon Department of Environmental Quality 

811 SW 6th Avenue

Portland, OR 97204 

1-800-452-4011 

www.oregon.gov/deq 

Contact: 

Anthony Barnack 

(503) 229-5713 
Monitoring Discontinuation Justification 3 3

Table of Contents

1. Executive Summary .....................................................................................................................1

2. Introduction..................................................................................................................................2

3. Pollutant Trends and Source of Emissions ..................................................................................2

3.1 Carbon Monoxide Trends for Eugene/Springfield and Medford ........................................................................2

3.2 Carbon Monoxide Emission Sources in Eugene/Springfield and Medford ........................................................4

3.3 PM10 Trends........................................................................................................................................................4

3.4 PM10 Emission Sources in Eugene/Springfield and Medford.............................................................................5

4. Fraction of PM10 that is PM2.5......................................................................................................5

4.1 Klamath Falls PM10 vs. PM2.5 ............................................................................................................................6

4.2 Grants Pass PM10 vs. PM2.5:...............................................................................................................................7

4.3 PM10 vs. PM2.5 Summary: ..................................................................................................................................9

5. Emission Estimate Methods: .......................................................................................................9

5.1 The Central Lane MPO Regional Emissions Analysis .......................................................................................9

5.2 The Rogue Valley Regional Emissions Analysis..............................................................................................10

6. An alternate approach for tracking the pollutant .......................................................................10

6.1 Tracking Carbon Monoxide:............................................................................................................................10

6.2 Tracking PM10: ................................................................................................................................................11

7. Alternate contingency measure trigger......................................................................................11

7.1 Alternative trigger for CO for Medford UGB:.................................................................................................11

7.2 Alternative trigger for CO for Eugene/Springfield AQMA: ............................................................................12

7.3 Alternative trigger for Klamath Falls PM10 Urban Growth Boundary.............................................................13

7.4 Alternative trigger for Grants Pass PM10 Urban Growth Boundary.................................................................14

8. Conclusion .................................................................................................................................14

9. Reference ...................................................................................................................................15

Table of Figures

Figure 1. Medford and Eugene/Springfield CO trends.................................................................. 3

Figure 2. Grants Pass and Klamath Falls PM10 trends................................................................... 4

Figure 3. Klamath Falls, Peterson School PM10/PM2.5 Correlation............................................... 6

Figure 4. Klamath Falls winter time PM10 distribution of PMcoarse and PM2.5. .......................... 7

Figure 5. Grants Pass, Parkside School PM10/PM2.5 Correlation................................................ 8

Figure 6. Grants Pass, winter time PM10 distribution of PMcoarse and PM2.5.............................. 8

Table of Tables

Table 1. Medford and Eugene/Springfield CO design values. ...................................................... 3

Table 2. Medford and Eugene/Springfield PM10 design values. ................................................... 5

Table 3. PM2.5 fraction of PM10 Average and 95% confidence level. ........................................... 9

Table 4. 2010 CO emission estimates within the Eugene/Springfield boundary. ....................... 10

Table 5. 2010 CO emission estimates within the Medford urban growth boundary. .................. 10

Table 6. Linear regression equations and ratios used to estimate PM10 using PM2.5................... 14
Glossary of Terms:

NAAQS – National Ambient Air Quality Standards (EPA criteria pollutant standards)

CO – Carbon monoxide

PM10 – Particulate matter, 10 microns in diameter or smaller

PM2.5 - Particulate matter, 10 microns in diameter or smaller

ODEQ – Oregon Department of Environmental Quality

LRAPA – Lane Regional Air Protection Authority (Lane County, Oregon)

SIP – State Implementation Plan 

ppm – Parts per million (concentration)

μg/m3– micrograms per meter cubed (concentration)

FRM – Federal Reference Method

MPO – Metropolitan Planning Organization

AQCD - The Air Quality Conformity Determination
1 1

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Monitoring Discontinuation Justification

1. Executive Summary

Due to budget cuts, Oregon DEQ and the Lane Regional Air Protection Authority needed to 

discontinue carbon monoxide and PM10 monitoring in maintenance areas which are now far 

below the National Ambient Air Quality Standard (NAAQS). The monitoring funds have 

either been lost or reinvested in higher priority monitoring such as PM2.5 or ozone. These 

pollutants are much closer to the NAAQS and require sustained monitoring. 

The CO and PM10 maintenance plans require continued monitoring for compliance 

determination and as triggers for contingency plans. To remove this requirement from the 

plans would require resources and time that ODEQ and LRAPA cannot afford at this time. 

EPA Region 10 has proposed a compromise which would require the use of alternative 

methods to track these pollutants in maintenance areas. The alternative methods will be 

included in the next maintenance plan revisions. 

The method for tracking CO would use the regional emissions analysis performed in the Air 

Quality Transportation Conformity Determination. This is conducted every four years by the 

Metropolitan Planning Organizations. These analyses will show the emission trends and will 

provide a trigger for the contingency plans written into the maintenance plans. As a real time 

measure, the Portland CO monitor will be used to track trends in general CO levels.

For PM10, PM2.5 will be used as a surrogate. The percent of PM10 that is PM2.5 is very high in 

Oregon and the control strategies are the same for both pollutants. 

Maintenance Plans are located at: http://www.deq.state.or.us/aq/planning/maintenance.htm
2 2

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Monitoring Discontinuation Justification

2. Introduction

Beginning in the 1970s, and continuing through the early part of the 1990s, Oregon had 

several communities that violated the carbon monoxide and PM10 NAAQS and were 

consequently declared out of attainment for these pollutants. Oregon DEQ and local stake 

holders implemented State Implementation Plans (SIPs) to bring these areas under the 

NAAQS. After many years of levels below the standards, maintenance plans were installed 

to keep the air quality below the NAAQS. The maintenance plans included requirements to 

continue monitoring to determine long-term trends and compliance. Monitoring was also 

required for contingency measure triggers for additional regulatory actions.

Over the last twenty years, the CO and PM10 concentrations have dropped far below the 

NAAQS. Monitoring continued only to meet the maintenance requirements, but had no real 

benefit for public health. The maintenance plans require monitoring until 2014 for 

Eugene/Springfield CO, and 2022 for Medford CO, and 2023 for Grants Pass PM10 and 

Klamath Falls PM10. Public health benefits most from PM2.5, ozone, and air toxic 

monitoring. 

In the last ten years ODEQ and LRAPA have experienced repeated budget cuts as a result of 

diminished revenue and expanded costs. In 2010 and 2011, budget cuts were especially deep 

and resulted in the elimination or reprioritization of many monitoring activities. ODEQ and 

LRAPA had already cut discretionary monitoring and had to now consider shutting down 

required, but low priority monitoring. CO and PM10 sites were considered expendable as 

long as alternative methods were available to track general concentrations and act as 

contingency measure triggers.

This report shows the how alternative methods can be used to adequately track CO and PM10

and trigger contingency measures.

3. Pollutant Trends and Source of Emissions

3.1 Carbon Monoxide Trends for Eugene/Springfield and Medford

The carbon monoxide levels have continuously dropped over the past 20 years and are now

routinely one quarter of the NAAQS. Figure 1 shows the CO trends for Medford and 

Eugene/Springfield and Table 1 provides the design values from 2000 to 2010. Medford has 

been below the NAAQS since 1993 and Eugene/Springfield has been below the NAAQS 

since 1983. With ever more cleaner cars on the road, the design values are not expected to 

increase.
3 3

3

Monitoring Discontinuation Justification

Figure 1. Medford and Eugene/Springfield CO trends.

Second highest 8 hour average.

Table 1. Medford and Eugene/Springfield CO design values.

Eugene Medford

(ppm)

% of 

NAAQS (ppm)

% of 

NAAQS

2000 4.3 45% 4.7 49%

2001 4.1 43% 4.6 48%

2002 4.2 44% 5.5 58%

2003 3.4 36% 4.7 49%

2004 3.4 36% 4 42%

2005 2.6 27% 3.8 40%

2006 2 21% 2.8 29%

2007 2.1 22% 2.7 28%

2008 1.7 18% 2.4 25%

2009 1.7 18% 2.4 25%

2010 1.3 14% ND ND

Based on annual 2nd highest, daily maximum eight hour average.

0

2

4

6

8

10

12

14

16

18

20

1972 1974 1976 1978 1980 1982 1984 1986 1988 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010

CO (ppm)

Medford and Eugene/Springfield Carbon Monoxide Trends

Medford

Eugene

NAAQS 8hr Average

Second highest 8hr average
4 4

4

Monitoring Discontinuation Justification

3.2 Carbon Monoxide Emission Sources in Eugene/Springfield and Medford

In the past, CO emissions in Medford and Eugene/Springfield were primarily from mobile 

source. In newer vehicles, catalytic converters, fuel injections, and electronic timing have 

greatly reduced tailpipe CO levels. As the vehicle fleet becomes newer the CO levels are 

expected to continue dropping. 

Non-mobile CO sources include industrial and area sources. Both areas have EPA Title V 

sources with Plant Site Emission Limits over 100 tons per year. These sources have been 

operating for years and are regulated. They would have to go through Prevention of 

Significant Deterioration review if they wanted to raise their CO emissions. 

Both areas also have a significant population using residential wood heating. Both were 

PM10 non-attainment areas and have had programs in place for years that encourages the use 

of certified woodstoves. All of Oregon now has the Heat Smart Program which requires the 

removal of non-certified woodstove upon sale of a home. Certified wood stoves emit far less 

CO than non-certified stoves. 

 

3.3 PM10 Trends 

Over the last 20 years PM10 levels have dropped statewide because of permitting programs 

and other reduction strategies. Figure 2 shows the PM10 trends for Grants Pass and Klamath 

Falls from 1987 to 2010. Table 2 provides the design values from 2000 to 2010. Grants Pass 

has been below the NAAQS since 1988 and Klamath Falls has been below the NAAQS since 

1991. 

Figure 2. Grants Pass and Klamath Falls PM10 trends.

0

50

100

150

200

250

300

350

400

450

500

550

600

650

700

750

1987 1989 1991 1993 1995 1997 1999 2001 2003 2005 2007 2009 μg/m3

PM10 for Klamath Falls and Grants Pass 

1987 to 2010

Grants Pass

Klamath Falls

NAAQS

2nd highest 24hr average PM10 value
5 5

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Monitoring Discontinuation Justification

Second highest 24 hour average PM10 values.

Table 2. Grants Pass and Klamath Falls PM10 design values.

Grants Pass Klamath Falls 

(μg/m3)

% of 

NAAQS (μg/m3)

% of 

NAAQS

2000 40.0 27% 93.0 62%

2001 50.0 33% 62.0 41%

2002 41.0 27% 121.0* 81%

2003 49.0 33% 63.2 42%

2004 32.3 22% 70.4 47%

2005 37.5 25% 75.5 50%

2006 37.7 25% 56.3 38%

2007 39.3 26% 71.8 48%

2008 42.3 28% 71.7 48%

2009 ND ND 61.8 41%

2010 ND ND 40.8 27%

Based on annual 2nd highest, 24 hour average.

* The 2002 Klamath Falls PM10 value was from a forest fire but was not considered an 

exceptional event because it was below the NAAQS.

3.4 PM10 Emission Sources in Eugene/Springfield and Medford

In the past, PM10 emissions in Medford and Eugene/Springfield were primarily from 

industrial and area sources. Both areas have EPA Title V sources with Plant Site Emission 

Limits over 100 tons per year. Industrial sources were regulated and now have cyclones , 

bag houses, and more efficient boilers to control emissions. Other methods such as Wigwam 

burners were outlawed. If these sources wanted to emit more PM10 they would have to go 

through Prevention of Significant Deteriation review. 

The primary source of PM10 is now smoke from residential wood heating. Medford and 

Eugene/Springfield were PM10 non-attainment areas and have had programs in place for 

years that encourage the use of certified woodstoves. All of Oregon now has the Heat Smart 

Program which requires the removal of non-certified woodstove upon sale of a home. 

Certified wood stoves emit far less PM10 than non-certified stoves. 

4. Fraction of PM10 that is PM2.5

In Oregon, PM10 is mostly made up of PM2.5. This section will show the results of years of 

wintertime collocated PM10 and PM2.5 sampling in Klamath Falls and Grants Pass to 

ascertain the PM coarse (PMc) fraction of PM10. In Oregon, winter weather occurs from 

November through February. This is when most winter inversions occur and the highest 

concentrations are measured.
6 6

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Monitoring Discontinuation Justification

4.1 Klamath Falls PM10 vs. PM2.5

Comparable PM10 and PM2.5 FRM samplers were operated in Klamath Falls from 2007 

through 2010. Comparison of the winter PM2.5 and PM10 data shows a correlation with an R 

Squared of 0.87 (Figure 3). During this period there were 17 samples greater than 1⁄4 of the 

NAAQS, three of which were greater than 1⁄2 the NAAQS. The highest value in the past 

three winters was 57% of the PM10 NAAQS. On average, winter PM10 is 70% PM2.5 by 

weight with a 95% confidence level of 66% to 74% (summarized in Table 3). Figure 4 

shows the PM2.5 and PMcoarse fractions for the highest winter values for 2007-2009.

Figure 3. Klamath Falls, Peterson School PM10/PM2.5 Correlation.

y = 1.4x + 1.0

R2 = 0.87

0

10

20

30

40

50

60

70

80

90

100

0 10 20 30 40 50 60 70 80 90 100 PM10 ug/m3

PM2.5 ug/m3

Klamath Falls Winter PM2.5 and PM10 Comparison
7 7

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Monitoring Discontinuation Justification

Figure 4. Klamath Falls winter time PM10 distribution of PMcoarse and PM2.5. 

Note: In Figure 4, PMc(red)+PM2.5 (blue) = PM10

Over the past ten years there were two years with elevated days outside of winter. In 2002, 

massive forest fires caused elevated levels during August; the PM10 was mostly PM2.5. In 

2009, a dust event caused an elevated level in early October. The dust event had a low PM2.5

quotient but the PM10 concentration (87μg/m3) was well below the NAAQS. If that single 

dust event was included in the linear regression done in Figure 2, the RSquared would 

change from 0.87 to 0.76 and the equation would change from y =1.4x+1.0 to y =1.4x+3.2. 

This is only a 2.2μg/m3higher PM10 derived value if the dust event is included. 

4.2 Grants Pass PM10 vs. PM2.5:

Comparable PM10 and PM2.5 samplers were co-located in Grants Pass from 2006 through 

2008. The PM2.5 and PM10 correlation has an R Squared of 0.94 (Figure 5).

From 2006 to 2008 there were only four samples over 1⁄4 of the NAAQS, and none over 1⁄2 the 

NAAQS. On average, winter PM10 is 73% PM2.5 by weight with a 95% confidence level of 

70% to 76% (summarized in Table 3). The highest value in the past three winters was only 

29% of the PM10 NAAQS. Figure 6 shows the PM2.5 and PM coarse fractions for the winter 

values for 2006-2008. 

-100%

-80%

-60%

-40%

-20%

0%

20%

40%

60%

80%

100%

0

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190

200

1 5 5 μg/m3

Klamath Falls Winter PM10, PM2.5, & PMc

Note: PM2.5 + PMc = PM10

PM10 = PM2.5 + PMc

% of PM10 that made up of PM2.5

y = 0.002x+0.6

Winter PM1 0 (PM2.5 + PMc) values from highest to lowest concentrations.
8 8

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Monitoring Discontinuation Justification

Figure 5. Grants Pass, Parkside School PM10/PM2.5 Correlation.

Figure 6. Grants Pass, winter time PM10 distribution of PMcoarse and PM2.5. 

Note: In Figure 6, PMc(red)+PM2.5 (blue) = PM10

y = 1.2x + 2.6

R2 = 0.94

0

5

10

15

20

25

30

35

40

45

50

0 10 20 30 40 50 PM10 μg/m3

PM2.5 μg/m3

Grants Pass winter PM2.5 and PM10 Comparison

-100%

-80%

-60%

-40%

-20%

0%

20%

40%

60%

80%

100%

0

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1 ug/m3

Grants Pass Winter PM10, PM2.5, & PMc

Note: PM2.5 + PMc = PM10

PM10 = PM2.5 + PMc

% of PM10 that made up of PM2.5

y = -0.002x+0.8

Winter PM1 0 (PM2.5 + PMc) values from highest to lowest concentrations.
9 9

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Monitoring Discontinuation Justification

4.3 PM10 vs. PM2.5 Summary:

Table 3 shows the summary of the winter co-located PM10 and PM2.5 samples. This 

percentage shows the percentage (by weight) of PM10 that is PM2.5. 

Table 3. PM2.5 fraction of PM10 Average and 95% confidence level.

Average 95% Confidence Level

Klamath Falls 70% 66% - 74%

Grants Pass 73% 70% - 76%

5. Emission Estimate Methods:

Modeled CO emission estimates are developed by the Metropolitan Planning Organizations 

(MPOs) for Eugene/Springfield and Medford as part of the transportation conformity 

requirements in the maintenance plans in accordance with Clean Air Act section 176(c).

Transportation conformity ensures that federal funding and approval are given to highway 

and transit projects that are consistent with ("conform to") the air quality goals established by 

a SIP. Conformity, to the purpose of the SIP, means that transportation activities will not 

cause new air quality violations, worsen existing violations, or delay timely attainment of the 

NAAQS.

A regional emissions analysis is a major component of demonstrating transportation 

conformity. The regional emissions analysis includes emissions from all current and planned 

regionally significant projects in the entire transportation system in the maintenance area for 

the duration of the transportation plan or TIP. The regional emissions analysis must use the

latest planning assumptions and latest emissions model.

This following section discusses the regional emissions analyses conducted in 

Eugene/Springfield and Medford for transportation conformity determinations.

5.1 The Central Lane MPO Regional Emissions Analysis

The Central Lane MPO is the agency responsible for performing the regional emissions 

analysis in the Eugene/Springfield maintenance area. The most recent regional emissions 

analysis was completed in 2010 for the “FY10-13 Metropolitan Transportation Improvement 

Program.”

The 2010 CO emissions projections from the regional emissions analyses are shown in Table 

4 (in tons per year). The first year listed, 2004, is the regional land use/transportation model

base year. 
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Monitoring Discontinuation Justification

Table 4. 2010 CO emission estimates within the Eugene/Springfield boundary.

Analysis Year

Estimated CO Emissions 

(tons/yr)

2004 2,198

2008 1,634

2018 1,160

2028 1,056

2031 1,059

5.2 The Rogue Valley Regional Emissions Analysis

The Rogue Valley MPO is the agency responsible for performing the regional emissions 

analysis in the Medford maintenance area. The most recent regional emissions analysis was 

completed in 2010 “2010-2013 Metropolitan Transportation Improvement Program 2009-

2034 Regional Transportation Plan”. 

The 2010 AQCD’s CO emissions from the regional emissions analysis are shown in Table 5

(in pounds per day). The first year listed, 2005, is the regional land use/transportation 

model base year used in the “2001-2023 Regional Transportation Plan and 2002-2005 

Transportation Improvement Program”.

Table 5. 2010 CO emission estimates within the Medford urban growth boundary.

Analysis Year

Estimated CO Emissions 

(lbs/day)

2005 33,910 

2015 19,359

2020 20,280

2026 19,770

2034 32,640

6. An alternate approach for tracking the pollutant

CO and PM10 maintenance plans required continued monitoring to determine NAAQS 

compliance. If the monitoring agency discontinues monitoring, CO and PM10 must be 

tracked using alternative methods. This section outlines the specific tracking methods 

ODEQ and LRAPA will use for CO in Medford and Eugene/Springfield, and PM10 in 

Klamath Falls and Grants Pass.

6.1 Tracking Carbon Monoxide:

Carbon monoxide has traditionally been tracked by monitoring and modeling. Once

monitoring is discontinued in the Eugene/Springfield and Medford maintenance areas, 

regional emissions modeling will be the primary method of tracking CO. 
11 11

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Monitoring Discontinuation Justification

Because on-road motor vehicle emissions are the primary source of CO in the 

Eugene/Springfield and Medford maintenance areas, ODEQ believes the regional emissions 

analysis conducted for the CO maintenance areas provides an effective surrogate method for 

tracking CO emissions. The regional emissions analysis must use the latest planning 

assumptions (e.g., population, vehicle miles traveled, employment estimates) and the latest 

emissions model. The regional emissions modeling is done at least every four years and 

produces CO estimates based on current and planned transportation activities throughout the 

CO maintenance areas. If these estimates exceed the base year estimates (shown in italics in 

Tables 4 and 5), then the current CO concentrations may be higher than the design values for 

those years (3.4 ppm in Eugene in 2004 and 3.8 ppm in Medford in 2005, see Table 1). If 

this occurs, EPA and ODEQ or LRAPA will decide whether to conduct CO survey 

monitoring. If the CO survey monitoring shows levels > 1⁄2 of the NAAQS, then CO 

monitoring will be restarted. Survey monitoring is done with an inexpensive non-FRM 

monitor. 

ODEQ will also continue to monitor CO in Portland. This monitoring will track general CO 

concentrations, because if the CO levels increase in Portland, they may also be going up in 

the other cities. If the Portland CO design value exceeds 1⁄2 the NAAQS, survey monitoring 

may be performed at the former Medford and Eugene/Springfield CO sites to determine 

current conditions. If the surveyed CO levels are 1⁄2 the NAAQS, CO monitoring will be 

restarted. 

The CO estimates will be included in the annual network review. 

6.2 Tracking PM10: 

PM10 in Klamath Falls and Grants Pass will be tracked using PM2.5 monitoring. The major 

source of PM10 in these communities is smoke from wood heating. The percentage of PM10

which is PM2.5 is known in both of these communities and PM10 estimates can be made using 

PM2.5 monitored levels. PM2.5 is monitored with both continuous and FRM samplers. Table 

6 contains the linear regression equations used to estimate PM10 from PM2.5 at these sampling 

locations. 

The PM10 estimates will be included in the annual network review. 

7. Alternate contingency measure trigger

CO and PM10 maintenance plans contain contingency triggers which are tied to monitored 

levels. If the trigger concentration is reached, ODEQ or LRAPA must institute the 

contingency measures outlined in the maintenance plan. If the monitoring agency wants to 

discontinue monitoring, they need to offer an alternative method to measure air quality for 

comparison to the trigger level. This section outlines the specific alternative trigger methods 

for CO in Medford and Eugene/Springfield, and PM10 in Klamath Falls and Grants Pass. 

7.1 Alternative trigger for CO for Medford UGB: 

Contingency trigger requirements:

On March 9th, 2001, the Environmental Quality Commission adopted the State

implementation plan revision for carbon monoxide in the Medford urban growth boundary (a 
12 12

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Monitoring Discontinuation Justification

plan for maintaining the national ambient air quality standards for carbon monoxide). 

Section 4.52.3.3 of the plan requires a “Contingency Plan” to take effect if the second highest 

daily 8 hour average monitored values were 1) above 90% of the NAAQS (phase 1), or 2) 

above the NAAQS (phase 2). The “Plan” makes an exception for the Medford Old Car 

Rally. 

The problem:

ODEQ had to discontinue CO monitoring due to budget cuts and very low concentrations. 

The contingency plan relies on continued monitoring to compare to the trigger points. 

ODEQ needs to adopt a trigger point based on an alternative pollutant measure. 

The Solution: 

For Medford, two alternative contingency trigger methods will be used. Method 1 relies on 

estimates produced every four years. Method 2 relies on hourly, real time data. 

Method 1:

The first method will be to use the modeled CO emissions in the regional emissions analysis 

conducted every four years by the Rogue Valley MPO for the transportation conformity 

determination. If the modeled emissions are above the modeled baseline year emissions, CO 

survey monitoring will be started to determine whether the contingency requirements are 

triggered. Survey monitoring is done with an inexpensive non-FRM monitor. 

Method 2:

The Portland, SE Lafayette CO monitor will be used as a surrogate. This provides real time 

monitoring data. If the Portland monitor reaches 1⁄2 the NAAQS, survey sampling will be 

started in Medford to determine whether the contingency requirements are triggered. Survey 

monitoring is done with an inexpensive non-FRM monitor. 

7.2 Alternative trigger for CO for Eugene/Springfield AQMA: 

Contingency trigger requirements:

On February 27th, 1992, Lane Regional Air Pollution (now Protection) Authority sent an

addendum to their carbon monoxide maintenance plan title “Contingency Commitment for 

Amendment of Oregon’s SIP, Eugene-Springfield carbon monoxide Attainment 

Redesignation & Adoption of Maintenance Plan”. The letter committed LRAPA to a carbon 

monoxide contingency plan as part of their carbon monoxide maintenance plan. The letter 

stated that “Within 60 days of reporting on AIRS that a violation of the carbon monoxide 

NAAQS has occurred within the Eugene-Springfield AQMA, LRAPA and LCOG will 

submit to the EPA a contingency plan for attaining the standard, which will be implemented 

as expeditiously as practicable”. Since the carbon monoxide NAAQS was never violated 

following this letter, the contingency plan for attaining the standard was never required. 

The problem:

LRAPA had to discontinue CO monitoring due to budget cuts and low CO concentrations. 

The contingency plan relies on continued monitoring to compare to the trigger points. 

LRAPA needs to adopt a trigger point based on an alternative pollutant measure. 
13 13

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Monitoring Discontinuation Justification

The Solution:

For Eugene/Springfield, one of two alternative contingency trigger methods will be used. 

Method 1 relies on estimates produced every four years. Method 2 relies on hourly, real time 

data. 

Method 1:

The first method will be to use the modeled CO emissions in the regional emissions analysis 

conducted every four years by the Central Lane MPO. If the modeled emissions are above 

the modeled baseline year emissions, CO survey monitoring will be started to determine 

whether the contingency requirements are triggered. Survey monitoring is done with an 

inexpensive non-FRM monitor.

Method 2:

The Portland, SE Lafayette CO monitor will be used as a surrogate. This provides real time 

monitoring data. If the Portland monitor reaches 1⁄2 the NAAQS, survey sampling will be 

started in Eugene to determine whether the contingency requirements are triggered. Survey 

monitoring is done with an inexpensive non-FRM monitor.

7.3 Alternative trigger for Klamath Falls PM10 Urban Growth Boundary

Contingency trigger requirements:

In October 2002, the Klamath Falls PM10 maintenance plan was finalized, installing a 

contingency plan that said:

Phase 1: Risk of Violation

The County and DEQ will reconvene a planning group to develop an action plan if 

ambient concentrations (actual or estimated) equal or exceed 90% of the NAAQS 

concentration of PM10 (135μg/m3 for the 24 hour average or 45μg/m3 for an annual 

average) at Peterson School. The planning group will prepare an action plan that 

includes a schedule for implementation of additional strategies as necessary to prevent an 

exceedance or violation of PM10 standards. If the high PM10 concentration was 

determined to be a natural event based on EPA's policy or an exceptional event, no 

further action may be needed.

Phase 2: Actual Violation 

If a violation of the PM10 standard occurs and is validated by DEQ, the following 

contingency measures will automatically be implemented:

The problem:

DEQ had to discontinue PM10 monitoring due to budget cuts and low PM10 levels. The 

contingency plan relies on continued PM10 monitoring to compare to the trigger points. 

ODEQ needs to adopt a trigger point based on an alternative pollutant measure.

The Solution:

The PM10 alternative pollutant measure will be to use PM2.5 monitoring as a surrogate. The 

PM2.5 relationship to PM10 has been established in recent years with collocated PM10 and 

PM2.5 monitors. Linear regression analysis was performed on the PM10 and PM2.5 data 
14 14

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Monitoring Discontinuation Justification

(Figure 3) and a linear regression equation was established (Table 6). Using this linear 

regression equation, ODEQ has determined the PM2.5 concentration needed to trigger the 

PM10 “Risk of Violation” and “Actual Violation” levels discussed above, also shown in 

Table 6. 

7.4 Alternative trigger for Grants Pass PM10 Urban Growth Boundary 

Contingency trigger requirements:

In October 2002, the Grants Pass PM10 maintenance plan was finalized, installing a 

contingency plan that said: 

“DEQ will convene a planning group if the 24-hour PM10 concentration as measured at 

the Grants Pass PM10 monitor equals or exceeds 120μg/m3. The planning group will

assess the probable emissions event resulting in the elevated PM10 level and consider a 

range of measures with the potential to reduce emissions. However, if a violation of the 

24-hour PM10 standard occurs, Lowest Achievable Emission Rate requirements, plus 

offsets, for major new industrial sources in the UGB will be restored and the exemption 

for offsets eliminated.”

The problem:

ODEQ discontinued PM10 monitoring due to budget cuts and low PM10 levels. The 

contingency plan relies on continued PM10 monitoring to compare to the trigger points. 

ODEQ needs to adopt a trigger point based on an alternative pollutant measure. 

The Solution: 

The PM10 alternative pollutant measure will be to use PM2.5 monitoring as a surrogate. The 

PM2.5 relationship to PM10 has been established in recent years with collocated PM10 and 

PM2.5 monitors. Linear regression analysis was performed on the PM10 and PM2.5 data 

(Figure 3) and a linear regression equation was established (Table 6). Using this linear 

regression equation, DEQ has determined the PM2.5 concentration needed to trigger the PM10

trigger of 120μg/m3. This is shown in Table 6.

Table 6. Linear regression equations and ratios used to estimate PM10 using PM2.5. 

Klamath Falls Grants Pass

Linear Regression Equation y = 1.4x + 3.2 y = 1.2x + 2.6

PM2.5 trigger for “Risk of Violation” 94 μg/m3

PM2.5 trigger for “Actual Violation” 105 μg/m3

PM2.5 trigger for 120 μg/m3 PM10 101 μg/m3

Y = PM10, X = PM2.5 

8. Conclusion

Budget cuts have forced ODEQ and LRAPA to cut CO and PM10 monitoring where they are 

required by the maintenance plans for compliance determination and contingency measure 

triggers. Fortunately, the CO and PM10 levels are so far below the NAAQS that there is very 

little probability that the monitors would trigger the contingency plans. Regardless, the 

maintenance plans need ambient levels for comparison, so alternative methods are needed to 

estimate concentrations. The alternative contingency plans described in this document will 
15 15

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Monitoring Discontinuation Justification

allow ODEQ and LRAPA to track CO and PM10 levels into the future. If levels start trending 

back up near the NAAQS, funding from other monitoring can be shifted and CO and PM10

monitors restarted. This is very unlikely however. 

Finally, monitoring is only required during the first 20 years of the maintenance plan. The 

monitoring requirement for Eugene/Springfield CO expires in 2014. The monitoring 

requirements for Medford CO will expire in 2023 and for Grants Pass PM10 and Klamath 

Falls PM10, the monitoring requirements will expire in 2023.

9. Reference

1. Air Quality Conformity Determination, Central Lane MPO FFY10-13 Metropolitan 

Transportation Improvement Program and 2007-2031 Regional Transportation Plan, 

October, 2010.

2. Air Quality Conformity Determination for 2010-2013. Metropolitan Transportation 

Improvement Program & 2009-2034 Regional Transportation Plan – Amended, Rogue 

Valley MPO, April, 2010.
Appendix 4 – 2015 Medford CO LMP

Appendix 4

Inventory Preparation and

Quality Assurance Plan

for the

Medford Urban Growth Boundary

2008

Carbon Monoxide (CO)

Limited Maintenance Plan

OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY

Air Quality Division – Technical Services Section
Appendix 4 - 2015 Medford CO LMP

February 2015

Oregon Department of the Environmental Quality

Inventory Preparation Plan/Quality Assurance Plan 

for the 

Medford Urban Growth Boundary

2008

Carbon Monoxide (CO)

Limited Maintenance Plan

 Oregon Department of the Environmental Quality

Environmental Solutions Division, Technical Services Section

811 SW Sixth Avenue

Portland, Oregon 97204

Phone 503-229-5359 • Fax 503-229-5675
Appendix 4 – 2015 Medford CO LMP

Page i

TABLE OF CONTENTS

1 INTRODUCTION....................................................................................................................1

Geographic Area........................................................................................................................................1

Temporal Resolution .................................................................................................................................3

2 INVENTORY DEVELOPMENT ............................................................................................3

2.1 Data Categories.............................................................................................................................4

Emission Sectors........................................................................................................................................4

3 SPATIAL ALLOCATION METHODS...................................................................................5

4 TEMPORAL ALLOCATION METHODS..............................................................................7

4.1 Permitted Point.............................................................................................................................7

4.2 Aircraft and Locomotives...............................................................................................................7

4.3 Nonpoint (area) and Nonroad Vehicles & Equipment...................................................................7

4.3.1 Open Burning ........................................................................................................................ 7

4.3.2 Small Stationary Fossil Fuel Combustion .............................................................................. 7

4.3.3 Residential Wood Combustion ............................................................................................. 7

4.3.4 Wildfires and Prescribed Burning ......................................................................................... 8

4.3.5 Structure Fires....................................................................................................................... 8

4.3.6 Nonroad Vehicles & Equipment Excluding Aircraft and Locomotives.................................. 8

4.4 On-Road Mobile: Vehicle Exhaust .................................................................................................8

5 QUALITY ASSURANCE AND QUALITY CONTROL .......................................................8

6 EXTERNAL AUDITS .............................................................................................................8

7 PERSONNEL...........................................................................................................................8

8 SCHEDULE .............................................................................................................................9
Appendix 4 – 2015 Medford CO LMP

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TABLE OF FIGURES

Figure 1-1. Medford UGB and CO Maintenance Area ........................................................................................... 2

Figure 1-2. Medford 25 Mile Buffer for CO Sources >100 tons/year ..................................................................... 3

TABLE OF TABLES

Table 2.1. 1993 CO Season Day Emissions by Category ........................................................................................ 4

Table 2.2. 1993 CO Season Day Emissions by Source Category ............................................................................ 4

Table 3.1. Data Sources, Spatial Surrogates and Boundaries................................................................................ 6
Appendix 4 – 2015 Medford CO LMP

Page 1

1 INTRODUCTION

Medford Oregon was designated a nonattainment area for carbon monoxide (CO) in 1978 and classified 

as moderate upon enactment of the 1990 Clean Air Act Amendments (CAAA). The highest 8-hour carbon 

monoxide concentration recorded in Medford occurred in 1977 at level of 21.8 ppm. Due to hot spot 

problems within the downtown region of Medford in 1982 the nonattainment area was revised to include 

only the central business district. Following the CAAA, the nonattainment area was modified to the 

Medford Urban Growth Boundary (UGB) as recommended by Governor Roberts’s March 15, 1991 letter 

to the EPA (57 FR 56762, November 30, 1992). By the late 1980’s, maximum levels were closer to the 

standard level, and the last exceedances of the standard were in 1990. 

The area was redesignated to attainment for the 8-hour CO standard in September 23, 2002, when EPA 

approved Oregon’s redesignation request and the first maintenance plan designed to maintain 

compliance with the 8-hour CO standard through the year 2015 (67 FR 48388, July 24, 2002). This plan 

addresses the second 10-year maintenance period required under section 175A(b) of Act. Once approved 

by EPA, the second maintenance plan will fulfill the 20-year maintenance planning requirements of Clean 

Air Act section 175A. This Inventory Preparation Plan is in support of the development of the required 

second CO maintenance plan. 

The maintenance area is the Medford UGB (Figure 1.1). Similar approach is recommended for the second 

maintenance plan. One of two CO monitors was located at the Brophy building location in downtown 

Medford. Measured CO levels were so low that the monitor was removed with EPA approval at the end 

of 2009. Because on-road mobile vehicle emissions are the primary source of CO in Medford (about 50%), 

Oregon DEQ has been tracking any increase in emissions for CO in Medford. 

The Medford second maintenance plan qualifies for the Limited Maintenance Plan (LMP) approach 

because it satisfies all the requirements outlined in the Limited Maintenance Plan Option for 

Nonclassifiable CO Nonattainment Areas (Paisie memo, 1995). For the 8-hour CO, in the most recent two 

years of data, the maximum value of 2.6 ppm was recorded on January 18, 2008 and the second 

maximum value of 2.4 ppm was recorded on December 6, 2008. The risk to the community of exceeding 

the CO standard is low. 

Oregon DEQ proposes using existing information from the EPA 2008 National Emission Inventory (NEl) to 

create the emissions inventory for CO sources in Medford. This document describes the planned approach 

to the Medford CO LMP EI and the basis for selecting that approach.

Geographic Area

The geographic area of the Medford UGB is shown in Figure 1-1. The 25-mile extension to the UGB area is 

shown in Figure 1-2; includes incorporated and unincorporated Jackson County and a part of Josephine 

County. Populated areas within the 25 mile buffer with large point sources included in this inventory are 

Medford, Rogue River and White City. The city is approximately 28 sq. miles in area, and the US Census 

2008 population was 77,667. The elevation of the city is approximately 422 meters (1384 ft).
Appendix 4 – 2015 Medford CO LMP

Page 2

Figure 1-1. Medford UGB and CO Maintenance Area
Appendix 4 – 2015 Medford CO LMP

Page 3

Figure 1-2. Medford 25 Mile Buffer for CO Sources >100 tons/year

Temporal Resolution

The CO season is defined as three consecutive months, December 1st through the end of February. As 

such, winter season day emissions will be included in the inventory. The unit of measure for winter 

season day emissions will be pounds per day (lb/day).

2 INVENTORY DEVELOPMENT

The DEQ will develop an emission inventory using EPA 2008 National Emissions Inventory (NEI) data for 

Jackson County. We will temporally allocate the EI data to CO season, and spatially allocate the countywide NEI data to the Medford UGB, or to buffers around the UGB, depending on emissions category. All 

data sources and allocation methods will be documented. The emission inventory will be consistent with 

the 1993 inventory.
Appendix 4 – 2015 Medford CO LMP

Page 4

2.1 Data Categories

From the base year (1993) emission inventory for the maintenance plan, the most significant categories of 

CO emissions in the Medford UGB are on-road mobile vehicle exhaust, stationary area sources, permitted 

point sources, and nonroad vehicles and equipment. Table 2.1 shows the breakdown by category for CO 

Season day emissions in 1993.

Table 2.1. 1993 CO Season Day Emissions by Category

Emission Inventory Category Emissions per Day 

(lb/day)

Percent of Daily 

Emissions

On-Road Mobile Sources 57,342 51%

Stationary Point Sources 28,516 25%

Stationary Area Sources 19,748 18%

Non-Road Mobile Sources 6,536 6%

------- -------

Total 112,143 100%

Emission Sectors

We propose 11 emission inventory source sectors be included in this LMP for the Medford UGB 

maintenance area. The sectors are based on a review of emission sectors listed in the 1993 maintenance 

plan, and an analysis of 2008 NEI data. Table 2.2 shows the breakdown by source category of average 

daily COemissions in 1993 inventory; DEQ will use the same source categories as in the 1993 inventory 

with the exception of the small point sources which will be combined with the Permitted Point Sources 

category.

Table 2.2. 1993 CO Season Day Emissions by Source Category

Emission Source Category Emissions per Day 

(lb/day)

Percent of WorstCase Day Emissions

Permitted Point Sources 28,516 25.43%

Small Point Sources 13 0.01%

Open Burning 495 0.44%

Small Stationary Fossil Fuel Combustion(a) 390 0.35%

Residential Wood Combustion 18,648 16.63%
Appendix 4 – 2015 Medford CO LMP

Page 5

Emission Source Category Emissions per Day 

(lb/day)

Percent of WorstCase Day Emissions

Wildfires & Prescribed Burning 183 0.16%

Structure Fires 19 0.02%

Aircraft & Airport Related 2,773 2.47%

Locomotives 17 0.01%

Recreational Marine 0 0.00%

Nonroad Vehicles & Equipment 3,747 3.34%

Onroad Mobile: Exhaust 57,342 51.13%

------- --------

Total 112,143 100%

(a) Non-permitted stationary residential, industrial, commercial, and institutional fuel use

3 SPATIAL ALLOCATION METHODS

For emissions sources with specific coordinates, emissions will be mapped to either the UGB or other 

boundary, depending on emissions source category. For sources without specific coordinates, spatial 

surrogates will be used to approximate both the location and magnitude of emissions. Spatial surrogates are 

typically used to approximate emissions inside smaller boundaries from larger boundaries. For sources 

without specific coordinates, county-wide emissions will be spatially allocated to UGB using the formula:

EUGB = ECOUNTY * SurrogateUGB / SurrogateCOUNTY

Where EUGB = emissions in UGB, 

ECOUNTY = county-wide emissions

SurrogateUGB = surrogate activity in UGB

SurrogateCOUNTY = surrogate activity in county

Data sources, spatial surrogates or boundaries used for each category of emissions are detailed in Table 3-

1.
Appendix 4 – 2015 Medford CO LMP

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Table 3.1. Data Sources, Spatial Surrogates and Boundaries
Appendix 4 – 2015 Medford CO LMP

Page 7

4 TEMPORAL ALLOCATION METHODS

Annual emissions will be adjusted from tons per year to lbs per season day for each source category. 

Methods for each category are described below, and all methods are consistent with the 1993 EI. 

4.1 Permitted Point

Typical day emissions estimates will be calculated from annual emissions utilizing facility operating 

schedules taken from source permits. Seasonal adjustment may also be estimated from source annual 

reports, and DEQ point source emissions estimation reports.

4.2 Aircraft and Locomotives

Aircraft and locomotive activity will be considered uniform throughout the year. Annual emissions will be 

divided by 365 days to estimate season day emissions.

4.3 Nonpoint (area) and Nonroad Vehicles & Equipment

For nonpoint (area) and nonroad vehicles and equipment (excluding aircraft and locomotive), temporal 

allocation to season will follow the formula:

Annual to Typical Season Day = (Annual Emissions * SAF) / (weekly activity * 52 weeks/yr)

Where SAF = Seasonal Adjustment Factor =

 = (Season Activity * 12 months) / (Annual Activity * Season Months)

(Reference: EPA-450/4-91-016, p. 5-22)

4.3.1 Open Burning

Open burning will be temporally allocated using SAF values and activity in days per week; DEQ may either 

verify the SAF values used in the 1993 EI or develop new SAF values based on the 2008 permitting and 

complaint data. Regardless, the method will be consistent with the 1993 EI.

4.3.2 Small Stationary Fossil Fuel Combustion

Annual emissions from small stationary fossil fuel combustion will be temporally allocated using SAF values 

and activity in days per week taken from the 1993 EI. SAF values for these sources in the 1993 EI were 

taken directly from EPA-450/4-91-016, Table 5.8-1, p. 5-18.

4.3.3 Residential Wood Combustion

Annual emissions from residential wood combustion will be temporally allocated using SAF values and 

activity in days per week taken from the 1993 EI. SAF values for these sources in the 1993 EI were taken 

directly from EPA-450/4-91-016, Table 5.8-1, p. 5-18.
Appendix 4 – 2015 Medford CO LMP

Page 8

4.3.4 Wildfires and Prescribed Burning

As wildfires and prescribed burning are date-specific events, DEQ will temporally allocate emissions from 

these sources using fire date data, available from the EPA National Emission Inventory (NEI). SAF values 

will be calculated using annual and seasonal fire dates.

4.3.5 Structure Fires

As structure fires are date-specific events, DEQ will temporally allocate emissions from these sources using 

fire date data. Fire data used by DEQ to estimate structure fire emissions for the NEI is supplied by the 

state fire marshal. A seasonal adjustment factor (SAF) will be estimated using annual and seasonal fire 

dates.

4.3.6 Nonroad Vehicles & Equipment Excluding Aircraft and Locomotives

Sources of emissions covered by the Nonroad model include the following categories:

 Recreational marine • Railway maintenance

 Agricultural • Lawn & garden

 Construction • Industrial

 Light commercial • Logging

 Airport Ground Support Equipment (GSE)

Emissions from these categories will be temporally allocated to season using SAFs and weekly activity 

taken from the 1993 emission inventory.

4.4 On-Road Mobile: Vehicle Exhaust

EPA provides 2008 on-road NEI data by month, allowing for calculation of an on-road seasonal adjustment 

factor for typical season day estimation. 

5 QUALITY ASSURANCE AND QUALITY CONTROL

DEQ will be using existing data that has already been quality checked. DEQ staff will perform quality 

assurance for accuracy, completeness, and representativeness on the spatial and temporal allocation of 

emissions from the existing inventory. DEQ will be using EPA county database estimates from the 2008 NEI 

v.3 generated using MOVES2010b modeled emissions rates.

6 EXTERNAL AUDITS

DEQ is willing to be audited by the EPA, and make changes to this inventory preparation and quality 

assurance plan if warranted.

7 PERSONNEL

DEQ personnel responsible for the Medford CO Limited Maintenance Plan inventory include:
Appendix 4 – 2015 Medford CO LMP

Page 9

Wendy Wiles, DEQ Environmental Solutions Division Administrator

Jeffrey Stocum, Air Quality Technical Services Section Manager, 503-229-5506

Emission Inventory and Air Quality Information Systems

Christopher Swab, Senior Emission Inventory Analyst, 503-229-5661

Brandy Albertson, Emission Inventory Analyst, 503-229-6459

Wesley Risher, Emission Inventory Analyst, 503-229-5092

Miyoung Park, Emission Inventory Specialist, 503-229-5178

Quality Assurance

Anthony Barnack, Air Monitoring Coordinator, 503-229-5713

David Collier, Air Quality Planning & Development Manager, 503-229-5177

Dave Nordberg, Air Quality Planner, 503-229-5519

8 SCHEDULE

Medford CO 2008 Limited Maintenance Plan

Draft Inventory Preparation Plan to EPA Oct. 2014

Fast Track Checklist to EPA Feb. 20, 2015

Final IPP with Schedule to EPA Feb. 20, 2015

Draft Emissions Inventory to ODEQ May 1, 2015

Draft Maint. Plan w/o E.I. to EPA May 20, 2015

Final E.I. to ODEQ June 16, 2015

EPA Comments on Draft Maint. Plan to ODEQ June 22, 2015

Maintenance Plan with E.I. to EPA July 1, 2015
Appendix 4 – 2015 Medford CO LMP

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EPA Comments on Plan & E.I. to ODEQ (if possible) July 22, 2015

Public Comment Period Begins (email notice) Aug. 17, 2015

Public Hearing (in Medford) Sept. 17, 2015

Close of Comment Period Sept. 21, 2015

Rule Adoption Staff Report to Director’s Office Oct. 29, 2015

Environmental Quality Commission Meeting Dec. 9, 2015

ODEQ Submits SIP Rule Update to SOS Dec. 14, 2015

Submit SIP Revision to EPA Dec. 22, 2015

EPA Approves Adequacy Determination Mar. 30, 2016
Attachment 4

Evidence that the state followed the Administrative Procedures Act

4.1 Public notice in the Secretary of State's Oregon Bulletin, September 1, 2015, 

publication

4.2 Certificate and Order for Filing Permanent Administrative Rules, filed and 

effective December 10, 2015
OREGON

BULLETIN

Supplements the 2015 Oregon Administrative Rules Compilation

Volume 54, No. 9

September 1, 2015

For July 16, 2015–August 15, 2015

Published by

JEANNE P. ATKINS

Secretary of State

Copyright 2015 Oregon Secretary of State
Department of Energy on the aggregate amount of funds that have

been deferred for green energy technology.

The rules will become effective upon filing. Text of the proposed

rules and hearing details can be found on the department website:

http://www.oregon.gov/energy/Pages/Rulemaking-Green-EnergyTechnology.aspx.

Rules Coordinator: Elizabeth Ross

Address: Department of Energy, 625 Marion St. NE, Salem, OR

97301

Telephone: (503) 373-8534

Department of Energy, 

Energy Facility Siting Council

Chapter 345

Rule Caption: Amendments to update the dates of publications,

rules, codes, standards, and laws incorporated by reference.

Date: Time: Location:

9-18-15 9 a.m. 2 Marine Dr. Port of Morrow 

Well Spring Rm.

Boardman, OR 97818

Hearing Officer: Jason Sierman 

Stat. Auth.: ORS 469.470 & 469.501 

Stats. Implemented: ORS 469.300–469.570 & 469.619.

Proposed Amendments: 345-001-0005, 345-001-0010, 345-021-

0010, 345-023-0030, 345-024-0720, 345-027-0023

Last Date for Comment: 9-18-15, Close of Hearing

Summary: The purpose of this rulemaking is to update identified

Chapter 345 rule provisions that incorporate non-EFSC publications,

rules, codes, standards and laws by reference. The proposed amendments will ensure that a more current publication, rule, code, standard or law is referenced in each identified EFSC rule.

In addition to effective dates, some of the identified Chapter 345

rule provisions that incorporate non-EFSC publications, rules, codes,

standards and laws also include instructional language that fully

implements the provision. Accordingly, to ensure the identified rules

continue to function appropriately, some proposed amendments also

include updates to the implementing language. 

The Council requests public comment on these draft rules. The

Council also requests public comment on whether other options

should be considered for achieving the rule’s substantive goals while

reducing the negative economic impact of the rule on business. A

call-in number is available for the public hearing. Please see the Oregon Department of Energy website for hearing details and other

materials: http://www.oregon.gov/energy/Siting/Pages/councilrulemaking.aspx

Rules Coordinator: Jason Sierman

Address: Department of Energy, Energy Facility Siting Council, 625

Marion St. NE , Salem, OR 97301

Telephone: (503) 373-2127

Department of Environmental Quality

Chapter 340

Rule Caption: Medford Limited Maintenance Plan for Carbon

Monoxide

Date: Time: Location:

9-21-15 7 p.m. DEQ Medford Office

221 Stewart Ave., Suite 201

Medford OR 97501

Hearing Officer: Wayne Kauzlarich 

Stat. Auth.: ORS 468.020 & 468A.035 

Stats. Implemented: ORS 468A.025 & 468A.035

Proposed Amendments: 340-200-0040

Last Date for Comment: 9-24-15, 4 p.m.

Summary: DEQ proposes this Medford Limited Maintenance Plan

for carbon monoxide and associated Emissions Inventory for adoption by the Oregon Environmental Quality Commission. If adopted,

DEQ will submit this Plan and Emissions Inventory to the U.S. Environmental Protection Agency (EPA) for approval as a revision to the

Oregon Clean Air Act State Implementation Plan.

In the 1970s and 1980s the Medford area violated the national air

quality standard for carbon monoxide (CO). State and federal regulations applied measures that reduced CO concentrations and in 2002

EPA redesignated Medford as meeting the CO standard. The redesignation included approval of the first Medford CO Maintenance

Plan, which demonstrated how the area would continue to meet the

standard in the coming decade. EPA required the plan to include a

budget for the amount of CO that vehicles operating on the future

highway system could emit in coming decades. Each time a new

transportation plan is adopted, planners must show that estimated CO

emissions from the new highway system will remain within the budgeted amount. 

DEQ recently discovered the instructions for calculating the emissions budget were incorrect and set too low. When future vehicle

emissions are estimated and compared to the emissions budget, they

exceed the budgeted amount. This error prevents Medford from

adopting a new transportation plan. The situation can be corrected

by revising the budget in the original plan or by adopting a new CO

maintenance plan. Since Medford is due to adopt a second CO maintenance plan, a new plan is the preferred way of correcting the error. 

The measured concentration of CO in Medford is currently 27 percent of the federal CO limit. This low level of CO allows Medford

to use the streamlined requirements of a “limited maintenance plan.”

Under these streamlined requirements, a vehicle emissions budget

is no longer required when preparing future transportation plans. 

DEQ, in consultation with EPA and the Rogue Valley Metropolitan Planning Organization (RVMPO), proposes a new limited maintenance plan as the most efficient way to support Medford’s transportation planning process and schedule. Medford will continue to

meet the federal CO standard, while eliminating administrative

requirements that are no longer needed to protect air quality. The limited maintenance plan updates Medford’s existing air quality plan,

imposes no new control measures and saves the cost of emissions

analyses that are no longer useful.

Rules Coordinator: Meyer Goldstein

Address: Department of Environmental Quality, 811 SW Sixth Ave.,

Portland, OR 97204

Telephone: (503) 229-6478

Rule Caption: Water Quality Credit Trading

Date: Time: Location:

9-21-15 6 p.m. DEQ Headquarters

811 SW 6th Ave., 

10th Floor, Rm. EQC A

Portland, OR

Hearing Officer: Evan Haas 

Stat. Auth.: ORS 468.020, 468B.020, 468B.030, 468B.035,

468B.550 

Stats. Implemented: ORS 468B.555

Proposed Adoptions: 340-039-0001, 340-039-0003, 340-039-

0005, 340-039-0015, 340-039-0017, 340-039-0020, 340-039-0025,

340-039-0030, 340-039-0035, 340-039-0040, 340-039-0043

Last Date for Comment: 9-25-15, 4 p.m.

Summary: DEQ proposes the Oregon Environmental Quality Commission adopt new rules establishing a water quality trading program.

The proposed rules clarify DEQ’s authority to allow water quality

trading as a voluntary compliance option in water quality permits and

water quality certifications issued under the Clean Water Act (CWA).

In addition, the rules establish the mechanisms and criteria through

which DEQ will evaluate and approve water quality trades and oversee implementation of water quality trades. The rules will provide

consistency and regulatory certainty for water quality permittees,

other stakeholders and the public. 

Water quality trading is one compliance option among several

available to meet regulatory requirements under the CWA. Through

an approved water quality trading plan, permit holders and other regNOTICES OF PROPOSED RULEMAKING

Oregon Bulletin September 2015: Volume 54, No. 9

16



Attachment 5

Evidence of adequate public notice

5.1 Affidavits of Publication August 14, 2015:

The Oregonian

Medford Mail Tribune


Attachment 6

Certification of public hearing

For certification of the public hearing, see the cover letter and page 10 of 

Attachment 1.1
Attachment 7

Compilation of public comment and department's response

For the Presiding Officer's record for rulemaking hearings, see page 10 of 

Attachment 1.1

For the Summary of comments and DEQ responses, see page 12 of Attachment 1.1