reg on 

John A. Kitzhaber, MD, Governor 

December 12,2012 

Dennis J. McLerran, Regional Administrator 

U.S. Enviromnenta1 Protection Agency, Region 10 

1200 Sixth Avenue 

Mail Code: RA-140 

Seattle, WA 98101 

-Department of Environmental Quality 

Headquarters 

811 SW Sixth Avenue 

Portland, OR 97204-1390 

(503) 229-5696 

FAX (503) 229-6124 

TTY: 711 

RE: Revision to the Oregon State Implementation Plan- Oakridge-Westfir PM2_s attaimnent plan 

Dear Mr. McLerran: 

The Oregon Department ofEnviromnental Quality (DEQ) requests approval of revisions to the Oregon 

State Implementation Plan (SIP) from the Office of Air, Waste, and Toxics, State and Tribal Air 

Programs Unit 'of the U.S. EPA, Region 10. Enclosed for your review is one hard copy of the 

amendments and one electronic copy of the amendments are saved on the disk included. 

The Enviromnental Quality Commission adopted the revisions to the SIP under OAR 340-200-0040 on 

December 6, 2012. DEQ submits these revisions to EPA as part of the SIP and pursuant to 40 CPR 

51.104. 

I certify that public notices were published in newspapers of general circulation on August 20 and 23, 

2012 and in the Secretary of State's Oregon Bulletin on September 1, 2012. The notices included a 

statement that adoption of the rules would revise the SIP. I further certify a public hearing was held on 

September 18 and 20,2012 in Oakridge, Oregon. 

Thank you for your assistance with these revisions to Oregon's SIP. The staff contact for this submittal 

is Nicole Vick, SIP Coordinator at (503) 229-5946. 

Deputy 

:i~ Director 

Enclosures 

cc Andrew Ginsburg, DEQ AQ Administrator 

Paul Koprowski, EPA Oregon Operations office 

Justin Spenillo, EPA, Region 10 

Claudia Vaupel, EPA, Region 10 

Nicole Vick, DEQ AQ SIP Coordinator 
Included Attachment Title

X 1 Evidence the state has adopted the revision

X

1.1 Staff Report, Agenda Item I of the December 6-7, 2012, EQC meeting 

Also see Certificate and Order for Filing Permanent Administrative Rules in Attachment 4.2

X 1.2a Agenda Item 6, Lane Regional Air Protection Agency (LRAPA) Board of Directors Meeting, October 18, 2012

X 1.2b Agenda Item 8, LRAPA Board of Directors Meeting, November 15, 2012

X 1.3a Minutes, LRAPA Board of Directors Meeting, October 18, 2012

X 1.3b Minutes, LRAPA Board of Directors Meeting, November 15, 2012

X 2 Evidence that the state has the necessary legal authority

X 2.1

See Attachment 1.1 "Commission Authority" (page #3 of Staff Report, Agenda Item I, December 6-7, 2012, EQC 

meeting)

X 3 Provisions submitted for approval

X 3.1 Adopted and amended rules submitted for approval

X 3.1a General Air Pollution Procedures and Definitions: OAR 340-200-: 0040. Filed and effective December 10, 2012

X 3.1b Designation of Air Quality Areas: LRAPA Title 29. LRAPA Board adopted on October 18, 2012

X 3.2 Redline/strikeout version of adopted and amended rules submitted for approval

X 3.2a General Air Pollution Procedures and Definitions: OAR 340-200-: 0040. Filed and effective December 10, 2012

X 3.1b Designation of Air Quality Areas: LRAPA Title 29. LRAPA Board adopted on October 18, 2012

X 3.3 Attainment plan and appendices submitted for approval

X 3.3 Oakridge-Westfir PM2.5 attainment plan

X 3.3a Appendix A - UMAA

X 3.3a1 Appendix A1 - Oakridge PM Saturation Study October 2003

X 3.3b Appendix B - Meterology

X 3.3c1 Appendix C1 - 2010 SF1 Cites M-P (no header attached)

X 3.3c2 Appendix C2 - Household and employment growth projections

X 3.3c3 Appendix C3 - Oakridge VMT Projections 2002-2025 by LCOG

X 3.3d Oakridge emission inventory with attachments

X 3.3e 1 SANDWICH

X 3.3e 2 Oakridge PMF report July 30, 2012

X 3.3f1 Oakridge ordinance

X 3.3f2 Smoke management directive

X 3.3f3 Title 38 New Source Review

X 3.3f4 Woodstove changeout list

X 3.3f5 Recommended strategies December 31, 2011

X 3.3g Design value

X 3.3h Rollback modeling

X 3.3i Transportation analysis of Oakridge by LCOG

X 3.3j RACT - RACM analysis

X 4 Evidence that the state followed the Administrative Procedures Act

X 4.1 Public notice in the Secretary of State's Oregon Bulletin, September 1, 2012, publication

X

4.2 Certificate and Order for Filing Permanent Administrative Rules, filed December 10, 2012 and effective December 10, 

2012

X 4.3 DEQ authorization for LRAPA to conduct a hearing on EQC's behalf and stringency review, dated August 15, 2012

X 5 Evidence of adequate public notice

X 5.1 Affidavit of Publication: Dead Mountain Echo, Notice of August 23, 2012 publication

X 5.2 Affidavit of Publication: Register Guard, Notice of August 20, 2012 publication

X 6 Certification of public hearing

SIP Submittal Checklist
X 6.1 See paragraph #3 of cover letter and Attachment 7.1

X 7 Compilation of public comment and department's response

X 7.1 Presiding Officer's report for rulemaking hearings on September 18 and 20, 2012, dated October 26,2012

X 7.2 Summary of public comment and agency response, dated October 18, 2012
ATTACHMENTS

Attachment 1: Evidence the state has adopted the revision

1.1 Staff Report, Agenda Item I of the December 6-7, 2012, EQC meeting

1.2a Agenda Item 6, Lane Regional Air Protection Agency (LRAPA) Board 

of Directors Meeting, October 18, 2012

1.2b Agenda Item 8, LRAPA Board of Directors Meeting, November 15, 

2012

1.3a Minutes, LRAPA Board of Directors Meeting, October 18, 2012

1.3b Minutes, LRAPA Board of Directors Meeting, November 15, 2012

Also see Certificate and Order for Filing Permanent Administrative Rules in 

Attachment 4.2

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

See Attachment 1.1 “Commission Authority” (page # 3 of Staff Report, 

Agenda Item I, December 6-7, 2012, EQC meeting)

Attachment 3: Provisions submitted for approval

3.1 Adopted and amended rules submitted for approval

3.1a General Air Pollution Procedures and Definitions: OAR 340-

200-: 0040. Filed and effective December 10, 2012

3.1b Designation of Air Quality Areas: LRAPA Title 29. LRAPA 

Board adopted on October 18, 2012

3.2 Redline/strikeout version of adopted and amended rules submitted for 

approval

3.2a General Air Pollution Procedures and Definitions: OAR 340-

200-: 0040. Effective December 10, 2012

3.2b Designation of Air Quality Areas: LRAPA Title 29. LRAPA 

Board adopted on October 18, 2012

3.3 Attainment plan and appendices submitted for approval

3.3 Oakridge-Westfir PM2.5 attainment plan

3.3a Appendix A - UMAA

3.3a1 Appendix A1 - Oakridge PM Saturation Study October 2003

3.3b Appendix B - Meterology

3.3c1 Appendix C1 - 2010 SF1 Cites M-P (no header attached)

3.3c2 Appendix C2 - Household and employment growth projections

3.3c3 Appendix C3 - Oakridge VMT Projections 2002-2025 by 

LCOG

3.3d Oakridge emission inventory with attachments

3.3e1 SANDWICH

3.3e2 Oakridge PMF report July 30, 2012

3.3f1 Oakridge ordinance

3.3f2 Smoke management directive

3.3f3 Title 38 New Source Review
3.3f4 Woodstove changeout list

3.3f5 Recommended strategies December 31, 2011

3.3g Design value

3.3h Rollback modeling

3.3i Transportation analysis of Oakridge by LCOG

3.3j RACT - RACM analysis

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, 

2012 publication

4.2 Certificate and Order for Filing Permanent Administrative Rules, filed 

and effective December 10, 2012

4.3 DEQ authorization for LRAPA to conduct a hearing on EQC’s behalf

and stringency review, dated August 15, 2012

Attachment 5: Evidence of adequate public notice

5.1 Affidavit of Publication: Dead Mountain Echo, Notice of August 23, 

2012 publication

5.2 Affidavit of Publication: The Register Guard, Notice of August 20, 

2012

Attachment 6: Certification of public hearing

See paragraph #3 of cover letter and Attachment 7.1

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

7.1 Presiding Officer’s report for rulemaking hearings on September 18 

and 20, 2012, dated October 26, 2012

7.2 Summary of public comment and agency response, dated October 18, 

2012
Attachment 1

Evidence the state has adopted the revision

1.1 Staff Report, Agenda Item I of the December 6-7, 2012, EQC meeting

1.2a Agenda Item 6, Lane Regional Air Protection Agency (LRAPA) Board of Directors 

Meeting, October 18, 2012

1.2b Agenda Item 8, LRAPA Board of Directors Meeting, November 15, 2012

 

1.3a Minutes, LRAPA Board of Directors Meeting, October 18, 2012

1.3b Minutes, LRAPA Board of Directors Meeting, November 15, 2012

Also see Certificate and Order for Filing Permanent Administrative Rules in Attachment 4.2
Attachment 1.1, page 1

State of Oregon 

Department of Environmental Quality Memorandum 

Date: Nov. 16,2012 

To: 

From: 

Environmental Quality Cor1issiop-UL.--------· 

Dick Pedersen, Director Y~ 

Subject: Agenda item I, Action item, Rule proposal: Oakridge-Westfir PM25 Attainment 

Plan 

Dec. 6-7,2012, EQC meeting 

Why this is 

important 

DEQ 

recommendation 

and EQC motion 

Background and 

need for 

rulemaldng 

This proposed rulemaking adopts an attainment plan that will reduce 

fine particulate matter, or PM2.5, in order to protect the health of the 

residents in the city of Oakridge and neighboring Westfir community. 

LRAPA, the Lane Regional Air Protection Agency, is the designated 

agency for air quality in Lane County, as delegated by DEQ. The plan 

and associated rules are designed to bring this area into compliance with 

National Ambient Air Quality Standards for PM25 by the federal 

deadline of December 2014. 

DEQ recommends that the Oregon Environmental Quality Commission 

adopt the proposed rule amendments as presented in attachment A, 

approve Oakridge-Westfir PM25 Attaimnent Plan as presented in 

attachment A and direct DEQ to submit the Oakridge-Westfir PM25 

Attainment Plan to the Environmental Protection Agency as a revision 

to the Oregon Clean Air Act State hnplementation Plan. 

History of particulate pollution in Oakridge 

During the winter months, Oakridge air quality is often threatened by 

high concentrations of smoke fi·om wood stoves settling on the valley 

floor. Local climate and topography make the city of Oakridge prone 

to wintertime temperature inversions, low wind speeds and poor 

atmospheric dispersion. 

As a result, Oakridge has struggled to meet air quality standards. 

Oakridge was designated a PM10 nonattainment area Jan. 20, 1994. 

The city has not violated the PM10 standard since this designation. 

Voluntary measures to reduce wood smoke emissions adopted in 1999 

continue to reduce measured particulate levels. 

In 1997, EPA revised the particulate standard to include smaller 

particulate, PM2.5, and established a daily standard of 65 micrograms 

per cubic meter. The original PM10 strategies were so successful that 

Oakridge met the 1997 PM25 standard. However, in 2006, EPA 

Item I 000001 
Attachment 1.1, page 2

Rule proposal: Oakridge-Westfir PM2.5 Attainment Plan 

Dec. 6-7, 2012, EQC meeting 

Page 2 of 5 

Effect of rule 

lowered the daily PM2.s standard based on the latest health effects 

research, from 65 [tg/m3 to 35 [Ig/m3

, causing Oakridge to go back 

into nonattainment. The area designated as nonattainment for Pl\'hs 

was expanded to include the nearby small city of Westfir and the 

surrounding area. The federal Clean Air Act requires OakridgeWestfir to reduce its particulate levels to comply with the PM25 

standard by December 2014. 

The Oakridge PM25 Advisory Committee 

LRAP A and the City of Oakridge convened the Oakridge Advisory 

Committee in 20 II to help develop and recommend strategies to 

bring Oakridge into attainment with the standard. The committee 

included residents fi·om both Oakridge and Westfir. From July to 

December 20 II, the committee met to evaluate pollution reduction 

strategies with the highest chance of success in meeting the PM2.5 

standard and developed recommendations for emission reduction 

measures. These recommendations formed the groundwork for the 

city to adopt emission reduction measures in local ordinances, and for 

LRAPA to develop an attainment plan for the Oakridge-Westfir area. 

State hnplementation Plan 

The attainment plan, developed in accordance with EPA's guidance, 

is a comprehensive document that identifies the emission sources of 

PM25 and estimates the current and future year concentrations based 

on the emission inventory and measurements. The plan contains 

emission reduction strategies consisting of local ordinances, LRAP A 

regulations and non-regulatory elements including incentives and 

education. If the community fails to reduce pmiiculate emissions by 

the 2014 deadline, the plan's contingency measures would take effect 

automatically and are designed to achieve rapid compliance with the 

PM2.s standard. The contingency measures are a backstop until the 

plan can be reevaluated and corrected. The proposed attainment plan 

will help LRAP A and the community control emissions to ensure 

clean air and protect public health in Oakridge-Westfir. 

Since residential woodstove emissions comprise the majority of the 

fine particulate emissions in Oakridge-Westfir, most of the proposed 

pmiiculate reductions will come fi·om enhancements to the 

community's woodstove curtailment program, implemented through 

local ordinances. Other related strategies include continuing the 

program of replacing polluting uncertified woodstoves and a public 

awareness and education program. 

If the attainment plan fails to achieve the federal standard by 

December 2014, additional measures and regulations in the 

contingency plan would increase the number of"red no-bum days" 

Item I 000002 
Attachment 1.1, page 3

Rule proposal: Oakridge-Westfir PM2.5 Attainment Plan 

Dec. 6-7, 2012, EQC meeting 

Page 3 of 5 

Commission 

authority 

Key issues 

under the woodstove program fi·om 20 to 30 days per year, increase 

the percentage of cmtailment effectiveness and decrease the allowed 

opacity for wood stove emissions from 40 percent to 20 percent during 

the winter woodstove season. 

The emission reduction measures in the attainment plan are designed 

to meet the daily PM25 standard by lowering PM2.5 levels on worst 

days during the winter heating season to approximately 28 j.tg/m3

, 

below the 24-hour health standard of35 j.tg/m3

• Since the woodstove 

curtailment program achieves the vast majority of emission 

reductions, the effectiveness of the program is critical to meet the 

PM25 standard in Oakridge-Westfir. 

The commission has authority to take this action under 

ORS 468.020, 468A.025 and 468A.460. 

Economic impacts 

During plan development and the public comment period, LRAP A 

received comments expressing concern that the attainment plan could 

harm the local economy and hinder its recovery. LRAPA, the 

Oakridge Advisory Committee and the City of Oakridge focused on 

strategies with the lowest fiscal impact on local businesses and the 

economy. 

One benefit of the plan meeting the health standards on schedule is 

that it would allow more opportunity for future economic 

development. 

When an area is designated as nonattainment, federal requirements for 

industrial sources require use of the most stringent control equipment 

for new or expanding sources and reasonably available control 

technology for existing sources. While these federal restrictions may 

prevent some industries from expanding or moving into the OakridgeWestfir area, they are designed to reduce pollution and ensure the 

health of all residents. LRAP A expects the attainment plan will 

achieve timely compliance with the standard, which will enable 

LRAP A to begin the steps needed to lift the more stringent industrial 

restrictions. If the area meets the standard by 2014, LRAPA can begin 

development of a maintenance plan that can be submitted to EPA, 

with a request to re-designate the area to attail111lent. The maintenance 

plan can include provisions to ease the restrictions on industrial 

growth, depending on the implementation success of the existing 

attainment plan. This will have a positive economic impact on the 

community. 

Item I 000003 
Attachment 1.1, page 4

Rule proposal: Oakridge-Westfir PM2.5 Attainment Plan 

Dec. 6-7, 2012, EQC meeting 

Page 4 of 5 

Public outreach 

Evaluating compliance with the standard 

Some community members raised questions on the technical accuracy 

of monitoring data showing Oakridge-Westfir is above the PM25 

standard. They stated that the Willamette Activity Center monitor in 

southwest Oakridge should not be used to determine compliance 

because it is located in a pati of town that has the poorest air quality 

and is not representative of the entire city. However, EPA monitoring 

requirements dictate that monitoring take place in the area with the 

highest pollution levels in order to ensure the entire community meets 

health standards and is protected. Over the last 20 years, LRAP A has 

conducted numerous monitoring studies where patticulate samples 

have been taken throughout the Oakridge area, and more recently in 

the Westfir area. These studies show that patticulate levels are 

consistently high at Willamette Activity Center. 

LRAP A also received comments questioning the validity of the PM25 

standard. EPA sets this standard based on the latest scientific and 

health effect research. EPA reviews the standard every five years. 

LRAP A expects that the proposed attainment plan will have a positive 

effect on the health of Oakridge-Westfir residents. There are a number 

of studies linking PM25 exposure with respiratory problems and 

cardiac diseases. U.S. and Canadian studies report statistically 

significant relationships between an increase in PM25 and an increase 

in hospitalizations for all respiratory causes, including chronic 

obstructive pulmonary disease, pneumonia and asthma. ill addition to 

the greatly expanded body of evidence on hospitalization or 

emergency depattment visits for cardiovascular diseases, new 

epidemiologic studies have also reported associations between more 

subtle physiological changes in the cardiovascular system and shortterm exposures to PM2.5 concentrations. These impacts could result in 

days of missed work and have economic impacts that would affect the 

economy. 

Woodstove emissions 

The enforcement of the woodstove cmtailment program is the key 

strategy to help Oakridge-Westfir comply with the standard. This 

includes a focus on habitually violating offenders, increased patrols 

on red days and increased awareness and public outreach regarding 

the curtailment program. Since the curtailment program already 

exists, effective enforcement is essential for success of the plan. 

LRAPA held a public information meeting in Oakridge on Sept. 18, 

2012, with residents fi·om Oakridge and Westfir in attendance, and a 

public hearing was held before the LRAP A Board of Directors in 

Springfield on Sept. 20, 2012. A summary of the public comments is 

provided in attachment C. 

Item I 000004 
Attachment 1.1, page 5

Rule proposal: Oakridge-Westfir PM2.5 Attainment Plan 

Dec. 6-7, 2012, EQC meeting 

Page 5 of 5 

Next steps 

Attachments 

Available upon 

request 

If approved, DEQ must submit this PM2.s attainment plan to EPA as a 

revision to the Oregon Clean Air Act State Implementation Plan. 

LRAPA must continue to provide real-time air monitoring and daily 

woodburning advisories and work closely with the city of Oakridge to 

ensure effective implementation of the curtailment strategies and the 

success of the attainment plan. LRAP A must continue to assist the 

city in designing public education materials. Finally, LRAP A staff 

must continue to collaborate with the city of Oakridge and the public 

to track progress in reducing PM2.s levels to meet the standard. 

A. Proposed rule revisions 

1. Revisions to Division 200 

2. Revisions to LRAPA's Title 29 

3. Oakridge-Westfir PM2.s Attaimnent Plan 

B. Summary of public comments and agency responses 

C. Presiding Officer's Repmt on public hearings 

D. Relationship to Federal Requirements questions 

E. Statement ofNeed and Fiscal and Economic Impact 

F. Land Use Evaluation statement 

I. DEQ proposed rulemaking announcement 

2. Oakridge PlYh.s_Advisory Committee Recommendations 

3. Legal Notice of Hearing 

4. Written comments received 

5. LRAP A minutes fi·om public hearing 

Approved: 

Report prepared by: Brian Finneran 

Item I 000005 
A G E N D A 

LANE REGIONAL AIR PROTECTION AGENCY 

MONTHLY BOARD OF DIRECTORS MEETING 

THURSDAY, OCTOBER 18, 2012 

12:15 P.M. 

LRAPA MEETING ROOM 

1010 MAIN STREET 

SPRINGFIELD, OREGON 

(Note: Start times for agenda items are approximate.)

1. (12:15 p.m.) CALL TO ORDER 

2. (12:15 p.m.) ADJUSTMENTS TO AGENDA 

3. (12:20 p.m.) PUBLIC PARTICIPATION (time limited to three minutes per speaker) 

A. Comments On an Item On Today’s Agenda 

B. Comments On a Topic Not Included On Today’s Agenda (Note: This is an opportunity for the public 

to bring up unscheduled items. The board may not act at this time but may, if it deems necessary, place such items on 

future agendas. Issues brought up under this agenda item are to be limited to three minutes’ speaking time by the person 

raising the issue. If additional time is necessary, the item may be placed on a future agenda.) 

4. (12:30 p.m.) ACTION ITEM: Consent Calendar 

A. Approval of Minutes of September 20, 2012 Board of Directors Meeting View Material

B. Approval of Expense Reports Through September 30, 2012 View Material

5. (12:40 p.m.) Advisory Committee View Material

6. (12:50 p.m.) ACTION ITEM: Proposed Adoption of Oakridge PM2.5 Attainment 

Plan View Material

REPORTS

7. (1:50 p.m.) Director’s Report of Agency Activities in the Month of September, 

2012 View Material

WORK SESSION 

8. (2:00 p.m.) Old Business 

A. Personnel Policy Review Committee–Status Report 

B. Revenue Resources Committee–Status Report 

Review Committee Efforts (joint meeting with Revenue Resources Committee, including updates from Springfield, Lane County, or other IGA partners) View Material

 C. Strategic Priorities 

Updated LRAPA High Priorities (review and discussion of attached July 26, 2012 staff 

report) View Material

D. Handbook for Board Members (as approved on May 17, 2012) View Material 

Attachment 1.2a page 1
A G E N D A October 18, 2012 

LRAPA BOARD OF DIRECTORS MEETING -2- 

9. (2:30 p.m.) New Business 

 

10. (3:10 p.m.) Adjournment 

If you have questions regarding items on this agenda, would like to request a copy of backup material for 

an agenda item, or would like to be added to the mailing list to receive the agendas for the monthly 

LRAPA Board of Directors meetings, please contact Debby Wineinger at (541) 736-1056 Ext. 219 –

email – debby@lrapa.org

Location is wheelchair accessible (WCS). American Sign Language (ASL) interpretation is available 

with 48 hours notice. Please call contact Debby Wineinger at (541) 736-1056 Ext. 219 – email –

debby@lrapa.org

Attachment 1.2a page 2
A G E N D A 

LANE REGIONAL AIR PROTECTION AGENCY 

MONTHLY BOARD OF DIRECTORS MEETING 

THURSDAY, NOVEMBER 15, 2012 

12:15 P.M. 

LRAPA MEETING ROOM 

1010 MAIN STREET 

SPRINGFIELD, OREGON 

(Note: Start times for agenda items are approximate.)

1. (12:15 p.m.) CALL TO ORDER 

2. (12:15 p.m.) ADJUSTMENTS TO AGENDA 

3. (12:20 p.m.) PUBLIC PARTICIPATION (time limited to three minutes per speaker) 

A. Comments On an Item On Today’s Agenda 

B. Comments On a Topic Not Included On Today’s Agenda (Note: This is an opportunity for the public 

to bring up unscheduled items. The board may not act at this time but may, if it deems necessary, place such items on 

future agendas. Issues brought up under this agenda item are to be limited to three minutes’ speaking time by the person 

raising the issue. If additional time is necessary, the item may be placed on a future agenda.) 

4. (12:30 p.m.) ACTION ITEM: Consent Calendar 

A. Approval of Minutes of October 18, 2012 Board of Directors Meeting view material

B. Approval of Expense Reports Through October 31, 2012 view material

5. (12:40 p.m.) Advisory Committee view material

REPORTS

6. (1:00 p.m.) FY’12 (July 1, 2011 – June 30, 2012) Audit of Financial Statement 

Presentation (Isler, CPA) view material

 

7. (1:20 p.m.) Director’s Report of Agency Activities in the Month of October, 2012 view material

8. (1:30 p.m.) Oakridge PM2.5 Attainment Plan Follow-up view material

WORK SESSION 

9. (2:00 p.m.) Old Business 

A. Revenue Resources-Ongoing Discussion 

 B. Preparation for Work Session with Lane County Board of Commissioners 

C. Personnel Policy Review Committee–Status Report 

Attachment 1.2b, page 1
A G E N D A November 15, 2012 

LRAPA BOARD OF DIRECTORS MEETING -2- 

10. (2:50 p.m.) New Business 

 

11. (3:00 p.m.) Adjournment 

If you have questions regarding items on this agenda, would like to request a copy of backup material for 

an agenda item, or would like to be added to the mailing list to receive the agendas for the monthly 

LRAPA Board of Directors meetings, please contact Debby Wineinger at (541) 736-1056 Ext. 219 –

email – debby@lrapa.org

Location is wheelchair accessible (WCS). American Sign Language (ASL) interpretation is available 

with 48 hours notice. Please call contact Debby Wineinger at (541) 736-1056 Ext. 219 – email –

debby@lrapa.org

Attachment 1.2b, page 2
M I N U T E S

LANE REGIONAL AIR PROTECTION AGENCY 

BOARD OF DIRECTORS MEETING 

THURSDAY–OCTOBER 18, 2012 

LRAPA MEETING ROOM 

1010 MAIN STREET 

SPRINGFIELD, OREGON 

 

ATTENDANCE 

Board: Bill Brommelsiek, Chair–At-Large (Springfield Area); Mike Fleck, Vice-Chair–

Cottage Grove/Oakridge; Joseph Gonzales–Eugene; Jeannine Parisi–Eugene; Jay Bozievich–

Lane County; Scott Lucas–Eugene; Brian Forge–At-Large General; Dave Ralston–

Springfield 

 

ABSENT: Andrea Ortiz–Eugene 

Staff: Merlyn Hough–Director; Robbye Lanier; Debby Wineinger; Nasser Mirhosseyni 

Others: LRAPA Advisory Committee Members Jim Daniels; John Tamulonis; and Chuck Gottfried; 

Ben P. Sappington- Eugene Area Chamber of Commerce 

1. OPENING: Brommelsiek called the meeting to order at 12:15 p.m. 

2. ADJUSTMENTS TO AGENDA: No adjustments were made to the agenda. 

 

3. PUBLIC PARTICIPATION: No public participation. 

4. CONSENT CALENDAR: 

 

Approval of Minutes of September 20, 2012 Board of Directors Meeting 

MOTION: Lucas MOVED to approve Minutes as presented. Ralston SECONDED 

THE MOTION. VOTE ON MOTION: 8-0

Approval of Expense Reports Through September 30, 2012 

Fleck commented that the general fund balance was down about $100,000.00, and the cash flow 

chart shows a higher amount. He asked if that was reflecting the loss of dues. Mirhosseyni

explained that on the federal side we are up. And we receive federal payments monthly and the 

states payments are quarterly. 

Brommelsiek asked if LRAPA had received anything from the partners in dollars or in-kind

services. Mirhosseyni said we have not and we are still waiting for the signed MOU from the 

county. 

Attachment 1.3a, page 1
M I N U T E S SEPTEMBER 20, 2012 

LRAPA Board of Directors Meeting -2- 

MOTION: Ralston MOVED to approve the Expense Reports as presented. Gonzales 

SECONDED THE MOTION. VOTE ON MOTION: 8-0

5. ADVISORY COMMITTEE: 

Maurie Denner and Earl Koenig were not present at today’s meeting. Merlyn gave updates from 

the last meeting. Chuck Gottfried, who was present today, gave an overview on a field burning 

report from last summer. He had recapped the changes since the phase-out of field burning. 

Gottfried said if anyone is hearing discussions about field burning; it is probably not related to 

field burning. It is other sources of smoke. Burning in the south valley is history, and burning in 

the north valley is not likely to impact us. There may be misunderstandings on sources of smoke. 

Lucas asked about the economic impacts on the grass growers. Gottfried said there has been a 

shift in techniques with the increased use of pesticides and herbicides. The end results are always 

up and down. There is always a new bug or fungus but then there are also new chemicals. 

Ralston added that there are tradeoffs; they may use a different technique such as pesticides 

which shifts the burden to other environmental impacts. 

Bozievich mentioned two recent burns but they were not field burning. They were for wildlife 

management. One completely smoked out the city of Veneta during the harvest festival. He 

wanted to know if LRAPA received calls or complaints about it. Hough said there is an annual 

joint permit application submitted by The Nature Conservancy, BLM, Corps of Engineers, and 

the City of Eugene. It outlines their plan for ecological burning in the wetlands area. There was 

also some burning in Southern Benton County on the Wildlife Refuge. And that did impact the 

Elmira area. Bozievich said the fire danger level was high on the day of the burn. And he was 

shocked that they were burning on that day. Hough said there were fire districts directly involved 

with them, and they have fire suppression equipment on site. Brommelsiek said he would hope 

they would check with the local communities about events prior to burning. Hough agreed, and 

said they do have a prescription that they follow; it requires certain wind vectors, and wind speed 

ranges to try and minimize impact on populated areas. He said LRAPA staff also has its own 

criticisms that the burning hasn’t been ideally handled. 

Hough said the CAC welcomed the request to look into the Coal Train issue. There has been a 

lot of information complied on both sides of the issue. They formed a subcommittee and that 

group will be meeting within the next week. 

Brommelsiek asked Jay Bozievich about information he received from over at the coast, and did 

it make sense to continue to work on the coal train issue at this time or put in on hold. Bozievich

said he did think it made sense to continue to work on it. They put off taking any action on the 

resolution but the issue will still be around. With the forty some people that testified he heard a 

lot of repeated information received off the internet that he had verified was inaccurate. He didn’t 

think it would hurt to be prepared, also he didn’t think the issue was going away. 

Gonzales asked if LRAPA was going to make a statement, he asked what the board’s directive 

was. Brommelsiek said the board has asked the CAC to look into the issue and get back to the 

board with some technical information, on both the diesel engines and the coal dust issues. And 

depending on what we learn from the CAC we may take further action. 

Attachment 1.3a, page 2
M I N U T E S SEPTEMBER 20, 2012 

LRAPA Board of Directors Meeting -3- 

6. ACTION ITEM: HEARING ON PROPOSED ADOPTION OF OAKRIDGE PM2.5 

ATTAINMENT PLAN 

Brommelsiek reminded everyone that the public hearing was held at the last meeting. We 

received several comments, and many were received at the last minute. We postponed final 

decision at the meeting to give staff time to summarize the comments. Hough told everyone that 

in the packet today were the revised attainment plan, comments/responses, and rule changes. He 

gave a brief overview of the comments and responses. 

Discussion during the overview: 

Brommelsiek said in California they were able to argue successfully there was no contribution 

from one area to another. And suspected that the same argument could be made here, that 

Westfir couldn’t contribute to Oakridge’s problems. Parisi said it sounded like EPA Region 10 

was supportive of the change but it was hung-up in Washington DC. Hough said they were not in 

a position to override; they were understanding and supportive of our arguments. 

Brommelsiek noted that LRAPA’s response on comment two, page three, first sentence, we say 

the tightening is more than 50%; it is actually about 46%. Lucas suggested alternate language 

“almost 50%” regarding the tightened standard. 

Hough wanted to point out on comment 8A Transportation, we thought it was straightforward 

that motor vehicle emissions should be considered insignificant, but we have had some pushback 

on it. And we may need to add a sentence to the plan that says “there is a motor vehicle budget 

of this number of pounds per day which would be based on the 2014 emission inventory that 

Lane Council of Government prepared for us”. Or we may just want to make it conditional “if 

EPA does not concur with this finding of insignificance than the budget for evaluating 

regional conformity in the future is this number of pounds per day based on the 2014 

numbers.” The future motor vehicle emission projection is that the numbers will continue to 

decrease because of cleaner vehicles and fuels. We shouldn’t have a problem if there is a project 

that triggers the regional review. The regional review would be ODOT’s responsibility.

RACT/RACM is reasonably available control technology (RACT) and reasonably available 

control measures (RACM). Brommelsiek asked about industrial sources in the community. 

Hough explained that RACT on industries isn’t so much the issue, the RACM part has to do with 

residential wood burning. 

Parisi asked if there was going to be any feedback about households not conforming to the rules. 

Are police going to engage with folks who are burning on a no-burn day, will staff be informed 

what the circumstances were, such as copies of police reports. Hough said currently we are 

receiving the police logs. Parisi added that it would be helpful to know if they are owneroccupied or rental units. And do you target your energy to change the behavior in those 

households. 

Fleck wanted to know how a police officer determines the opacity of the smoke coming from the 

chimney. Hough said excessive smoke is banned by city ordinance all the time, if someone is 

exceeding 40% opacity that is enforceable. It does require a calibrated eyeball. There is a 

Attachment 1.3a, page 3
M I N U T E S SEPTEMBER 20, 2012 

LRAPA Board of Directors Meeting -4- 

certification program for determining the opacity in stacks. Some of the LRAPA staff is

recertified every year. For industrial sources the limit is typically 20% opacity. When you see 

any visible smoke it is about 5-10% opacity. At 100% you wouldn’t be able to see through it at 

all. So 40% is relatively heavy smoke. One of the contingency measures is if we don’t meet 

standards by the deadline it would go from 40% opacity to 20%. Both would require city staff to 

be trained. And they have not yet had the training or certification. On the curtailment days there 

cannot be any visible smoke, so opacity certification would not be required for the police officers, 

and warnings or citations could be issued even before opacity training and certification. 

Lucas asked if it was a person being recertified every year or a piece of equipment. Hough said it 

was a person. Lucas asked if that was a federal law, and why a person would need to be 

recertified every year. Hough explained that the opacity training/certification is essentially 

calibration of the person's ability to determine the density of the observed smoke. The opacity 

certification involves a calibrated smoke generator; the operator of the smoke generator will put 

out 15% opacity smoke, a horn will sound, and people being certified will fill-in the reading on a 

scorecard. For example, the reader has to be within 5% on average, and not off by more than 10-

15% or so on any individual reading. 

Gonzales said it didn’t sound like the City Council is taking ownership with this issue in terms of 

training. Hough said the Mayor, City Councilor Glenn Fortune, and the former City 

Administrator have all been very supportive. And Hough said he was attending a City Council 

work session tonight to reinforce the importance with all of them. 

Brommelsiek commented that on page 6, comment 2 didn’t read correctly. He asked if someone 

could check and be sure the comment was stated correctly. Hough read the comment: Why have 

existing strategies that have been in place since 2008 - the continuation of which are the primary strategy for attainment - have not yielded greater progress toward the projected 2014 

design value in the last three years? Parisi commented that maybe it was verbatim. Hough said 

they would check on the wording in the comment. 

Hough noted that under “other comments” there were several minor corrections and clarifications made in response. And regarding comment 2 on the last page, we need to add a sentence 

and we are still waiting to hear if EPA concurs with it. And lastly, EPA had some minor suggested changes. 

Fleck said he heard at least one item that may need clarification. He was referring to ODOT and 

insignificant vs. significant. He asked about direction for adopting this, do we include the 

changes now, or do we have to amend if those arise? Hough and Lanier outlined alternative 

ways to adopt or amend the plan. Hough deferred to Robbye Lanier’s recommendations. 

Parisi asked if you should come back to it at the end of the meeting, she would hate to postpone 

it if we don’t need to. She also asked if you could adopt the plan in content. So we are 

substantially adopting it today. If there are minor editorial changes. We know those might 

happen, and we don’t have to go back and look at them again. Lucas asked if the new suggestion 

was to incorporate the changes and then vote on a final plan at the November meeting. Hough

said he was thinking about Jeannine’s suggestion that the board take action today; substantially 

approve the plan with the recognition that additional details will be addressed at the November 

meeting. We could move it forward for EQC adoption. Lucas asked then there will be things you 

do with other agencies between now and November when things are amended. Hough said we 

Attachment 1.3a, page 4
M I N U T E S SEPTEMBER 20, 2012 

LRAPA Board of Directors Meeting -5- 

would finalize where EPA is going to come out, we are pretty sure that they are not going to 

concur with the insignificance finding. We will need to put a sentence in with a specific number in 

the plan. 

Brommelsiek said we could have a motion to approve as presented with modifications as 

identified by you today. Fleck agreed. Brommelsiek continued to say so we can move forward 

and revisit in November if there are any concerns. Brommelsiek suggested a motion to approve 

with modifications as outlined by Merlyn at this meeting. Parisi commented that it was in 

everyone’s best interest that Oakridge is able to hit attainment in 2014; even if they are in 

attainment there are still a lot years required to get the restrictions off the books. Forge added 

that he thought it was also important that it had the board’s approval with Merlyn attending the 

work session in Oakridge this evening. Bozievich wanted to clarify the changes that Merlyn 

outlined today include the change to the transportation component as being significant, and a 

budget based on the LCOG 2014 number. Parisi added as deemed necessary by EPA. 

Ralston wanted to get a comment on the record, he still hates all or nothing propositions. And 

he still has a problem including Westfir in the nonattainment area and monitoring in the worst 

areas. Bozievich also wanted to say for the record, that he takes issue with EPA’s nonattainment 

area that they have prescribed for this plan. He thinks it is overly large and in general the 

standard has become really constricted, but those are battles we can’t win at this time. It is more 

important to pass this plan and get them in attainment so they can move forward with economic 

development. He agrees with Dave Ralston’s objections, and it really is all or nothing, we either 

approve the plan or we don’t. And if they don’t have a plan they actually will have more 

problems, even with the wrong attainment area. 

MOTION: Lucas MOVED to approve with modifications as outlined by Merlyn 

Hough at this meeting. Fleck SECONDED THE MOTION. VOTE ON MOTION: 7-1 

in favor. 

7. DIRECTOR’S REPORT OF AGENCY ACTIVITIES FOR SEPTEMBER 2012: 

 Hough said regarding air quality in September, there were some local smoke concerns, but the 

bigger impact was wildfire smoke entering the area. 

Gonzales had a question regarding the total number of complaints. He wanted to know the 

about the 17 listed for open burning, what areas they were in? Hough said more detail was given 

in the enforcement section. Brommelsiek commented that prior to October 1st burning wasn’t

allowed. And it was also postponed for two weeks. Brommelsiek asked Merlyn if the report 

could be broken down into the geographic areas where the complaints were coming from on 

future reports. Hough said that can be provided. 

 

8. OLD BUSINESS 

A. Personnel Policy Review Committee 

Attachment 1.3a, page 5
M I N U T E S SEPTEMBER 20, 2012 

LRAPA Board of Directors Meeting -6- 

Hough said he thought we were getting closer with the County MOU. We will be asking 

their Human Resources (HR) Director to review. Mirhosseyni added that they have a 

meeting with the HR Director on the 23rd of October. 

B. Revenue Resources Committee 

Brommelsiek said there was to be joint meeting of the Revenue Resources Committee with 

the full LRAPA Board. With the exception of Chuck Gottfried, there weren't any other nonBoard committee members present. He asked if the elected officials, Merlyn, and Nasser had 

any updates. Bozievich said there is a November 27th work session scheduled with the 

Board of County Commissioners. He has also requested that elected officials be invited to 

attend along with their city managers if possible, so everybody can hear the same information 

all at the same time. Discussion will cover what happens if LRAPA were gone, what 

activities DEQ would take over, what they couldn’t take over, and who would run the 

Oakridge attainment plan. And if the County no longer participates, what would happen with 

the various jurisdictions. He thinks it is going to be a good and important meeting. 

Lucas asked if we knew if Klamath County chose to do an attainment plan or if DEQ said 

they had to do it. Bozievich said he knows they are doing it, but didn’t know if that was 

acquired or forced upon. Lucas thought it would be good to know that prior to the 

meeting, especially if it was forced on them. Bozievich said he was hoping Merlyn would be 

able to bring that information to the meeting. 

Ralston said Springfield has its first mid-year budget committee meeting on Tuesday, 

December 4th. But they won’t have anything new to report at this time. Brommelsiek asked 

Dave Ralston if anyone had spoke to him about possibly using the Springfield refueling 

center. Ralston said yes he had heard about it, and there might be other opportunities such 

as available space. But that is something that should be brought to the Springfield City 

Manager and let him bring it to the Council. Mirhosseyni said Marcie Parker with the City 

of Springfield told him the refueling issue would have to go thought the fire department to 

add additional users. And she said she would check on it and get back to him. 

Brommelsiek asked if anyone knew what was going on with the City of Eugene. Hough

said they have finalized the MOU and they are prepared to work with us on some legal issues. Mirhosseyni added that there was an amendment to the MOU regarding legal support. 

We were informed it has to be specific because of client-attorney relationships. And the City 

Manager will have to approve each case. The City Manager has signed the amendment. 

Questions the committee asked him to follow-up on were, if LRAPA could become part of 

another agency, and also if LRAPA could get some clerical support. Mirhosseyni will be 

following up with Glenn Klein. 

Mirhosseyni also reported that the equity line of credit has been approved by LRAPA's 

bank. It is an unsecured line of credit, and they do not need the building as collateral. But 

we will not be utilizing the line of credit this year. Lucas asked what is required before the 

line of credit is accessed, what is the process, does it require the Board of Directors approval 

before it accessed? Mirhosseyni said he was pretty sure it would require some legal directive, so the City Attorney’s office will be assisting. 

Attachment 1.3a, page 6
M I N U T E S SEPTEMBER 20, 2012 

LRAPA Board of Directors Meeting -7- 

Parisi wanted to know if LRAPA per the current state ordinance can be absorbed as a 

division of another organization. Mirhosseyni said that question has also been asked and 

will be explored with legal counsel. 

Fleck wanted to know if the loan is unsecured will it impact the interest rate. Mirhosseyni

explained because of LRAPA’s cash flow position with the bank they are going to extend it 

to us. But we haven’t discussed the fees and interest rate. Fleck said typically they are 

higher rates if unsecured. 

Parisi asked Jay Bozievich at the County’s public hearing was there time to hear public 

comment. Bozievich explained that it was a work session and not a public hearing. Parisi

asked if folks wanted to come and comment when they could do that. Bozievich said this 

meeting in not really set-up for that, this is informational only. Parisi said this could be 

taken up at future meeting and that would be the time where people could weigh in. But that 

would also be the time the Board of County Commissioners was making a decision. 

Bozievich said anytime someone wants to come for public comment, we take comments 

until people are done. Parisi wanted to know if there was a secondary meeting being set-up. 

Bozievich said not at this point. We may hear everything and look at each other and get 

three head nods, and just let sleeping dogs lay. 

There was discussion on when to schedule the next Revenue Resources Committee meeting. 

It was agreed that it would be after the County’s November 27th meeting. 

Hough said he and Nasser had talked about pulling some examples from the documents that 

were prepared during the budget process for the informational packet the County requested 

for the meeting. He didn’t envision creating something new, but just taking “the best of”

materials. Brommelsiek believed as important as this is to the County, it was also important 

for the county representatives to know what the cost impacts are for the cities. If LRAPA is 

not around what the costs will be to implement their ordinances. So he recommended we 

make sure all the information included what the cities responsibilities were and what would 

fall to the County. Bozievich said Faye Stewart represents two those cities, we all represent 

portions of cities involved in this. We need to think about the impact we are creating for the 

cities within our districts. Also it would be good information for the elective officials that are 

not familiar with LRAPA. And the legal background, what part of the ORS you are created 

under, and how the County links the two cities together. What happens if LRAPA is not 

here, who takes over what portions of it? Obviously all major industry permitting would fall 

back on DEQ. Brommelsiek added that other permitting would also go to DEQ. 

C. Strategic Priorities 

Hough said one of the key attachments is looking back at the successes in recent years, 

organized by the four strategic goals. And the other key attachment is looking ahead at the 

strategic priorities in future years. 

Brommelsiek asked if at a future board meeting someone could give an overview of the 

complaint process. Last year LRAPA responded to some 800 complaints. And on the 

“unable to do list” is has lower or medium priority complaints. If there is a matrix or 

Attachment 1.3a, page 7
M I N U T E S SEPTEMBER 20, 2012 

LRAPA Board of Directors Meeting -8- 

something that outlines the process with the lower and medium priorities. So if someone 

comes to them and says they didn’t get a follow-up, they would know how to respond to 

them. Parisi said she thought she had brought this up about two meetings ago. What gets a 

physical response, what just gets a call back, and what might just get logged? And she 

remembers hearing is that it is a case-by-case basis. She thought there was a way to 

prioritize, and decide where you were going to focus your resources. Lucas recalled the 

conversation also, and he was a little skeptical about being able to develop a workable 

matrix. But he would also like more information on the complaint process. Hough said 

complaint intake and response involves most of the agency. Lucas said he would like a few 

staff to sit with the board and go over the process. But he didn’t want staff to spend hours 

working on this as a project. Hough said we are revising our complaint policy/training with 

our shrinking staff. This would be added to a future agenda after the November 27th meeting 

with the County. 

Brommelsiek suggested to have a standing/ongoing agenda item on the revenue issues. 

Everyone agree that it should be a standing agenda item under “old business.” 

Bozievich wanted to know if the sequestration goes through with the federal government, is

it basically 8 1⁄2 percent reduction to all agencies? He also wanted to know if it would impact 

the matching grant. Hough said it would affect the federal grants to state and lcoal air 

agencies (State and Territorial Air Grants, or STAG grants), and we could expect about an 8 

1⁄2 percent reduction in our grant. But from what he was hearing, it would be very surprising

if Congress lets that happen. Lucas wanted to know within the STAG grant what percent of 

it is in the overall budget. Mirhosseyni it is about 21%. Lucas said so about 8 1⁄2 percent 

of 21%. Hough said the federal grant is in about the $250,000.00 - $300,000.00 range so it 

is a significant part of our budget. 

D. Handbook for Board Members 

Bill Brommelsiek and Mike Fleck signed the final document. It will be reviewed with the 

LRAPA Board of Directors annually. 

 

 9. NEW BUSINESS 

Parisi asked if anyone knew about Councilor Ortiz’s status on the board. Ben Sappington 

said it was in the Register Guard that she was going to resign early. Parisi stressed that she 

wanted to recognize her service on the LRAPA Board. Hough explained that normally when 

board members complete their terms, the LRAPA Board presents them with a plaque and a 

letter thanking them for their service. Parisi said she would be happy to read the letter into a 

City Council meeting so she may be acknowledged in front of her peers. And maybe Scott 

Lucas would in interested in participating since he also represents Eugene. Hough added 

that Joe Gonzales may also be interested as he, too, represents Eugene. Lucas said he would 

be happy to participate in any way he could. And he would also contact the Mayor to see if 

he could get an update on the status of Councilor Ortiz or her replacement. 

12. ADJOURNMENT: 

Attachment 1.3a, page 8
M I N U T E S SEPTEMBER 20, 2012 

LRAPA Board of Directors Meeting -9- 

 The meeting adjourned at 2:05 p.m. The next regular meeting of the LRAPA Board of 

Directors is scheduled for Thursday, November 15, 2012, 12:15 p.m. in the meeting room at 

LRAPA’s office, 1010 Main Street, in Springfield, Oregon. 

 Respectfully submitted, 

 Debby Wineinger 

 Recording Secretary 

 

 

 

Attachment 1.3a, page 9
M I N U T E S

LANE REGIONAL AIR PROTECTION AGENCY

BOARD OF DIRECTORS MEETING

THURSDAY–NOVEMBER 15, 2012 

LRAPA MEETING ROOM

1010 MAIN STREET 

SPRINGFIELD, OREGON

 

ATTENDANCE 

Board: Bill Brommelsiek, Chair–At-Large (Springfield Area); Mike Fleck, Vice-Chair–

Cottage Grove/Oakridge; Joseph Gonzales–Eugene; Jay Bozievich–Lane County; Scott 

Lucas–Eugene; Brian Forge–At-Large General

 

ABSENT: Jeannine Parisi–Eugene; Andrea Ortiz–Eugene; Dave Ralston–Springfield

Staff: Merlyn Hough–Director; Robbye Lanier; Debby Wineinger; Sally Markos; Max Hueftle; 

Nasser Mirhosseyni 

Others: LRAPA Advisory Committee Chair Maurie Denner; Member Jim Daniels; Member Earl 

Koenig: Ben P. Sappington- Eugene Area Chamber of Commerce; Paul Nielson, Isler CPA 

• Excerpts from Minutes:

REPORTS

8. Oakridge PM2.5 Attainment Plan Follow-up

 Hough reported back to the Board that there was a change made on page 33. We didn’t have the 

specific numbers but it was something that EPA asked to be included in the plan. 

 Another issue that came up was we went through a few iterations with EPA on their comments. 

There was a paragraph that was important to them to be in the plan demonstrating that we were 

following their 2007 implementation rule. We acknowledged that and looked at potential secondary sources of particulate that form nitrates or sulfates in Oakridge. EPA agrees that in Oakridge 

(and in Oregon in general) there are minimal amounts of nitrates and sulfates that show up on the 

filters. It is primarily organic carbon and very heavily affected by woodstove and fireplace emissions. It’s not the typical situation addressed by the EPA national guidance; but, in order to be 

clear that we were complying they asked that we put this paragraph in. We consider this just 

clarification as we have this in other words in the plan itself or in the appendix where we talk 

about RACT/RACM analysis in particular. First, we checked with DEQ to make sure this 

wouldn’t disrupt the EQC adoption plan for the early December meeting and we checked if someAttachment 1.3b, page 1
M I N U T E S NOVEMBER 15, 2012 

LRAPA Board of Directors Meeting -2- 

thing like this would require re-noticing. We were assured on both counts we were fine. It 

wouldn’t require re-noticing for us or EQC and as long as we let DEQ know immediately what 

action the Board takes today it can still be on the December 6th EQC agenda. They are sending 

their packet out sometime between this last Wednesday and early next week, but they said if we 

got something to them by tomorrow they could incorporate it. What Hough requested from the 

Board today was for them to take formal action to adopt the two clarification changes as part of 

the attainment plan. 

 Hough also spoke about the follow-up Letters from Westfir. They made comments during the 

public process. Their concerns were about the standards and boundary, Hough said those were 

both battles for a different place. They included DEQ in the loop on it, and DEQ responded to the 

comments and indicated that they would be willing to take a look at the information we had provided back when EPA was setting the boundary as well as the additional information that is part 

of the plan. If they agreed with Westfir's concerns which were the same as our concerns back in 

2008, they would raise that to the next level. We are not sure what that process would be. There 

are copies of the Westfir letter and DEQ’s response letters in the packet. EPA also responded 

and said that had been set as part of normal open process back in 2008. They weren’t convinced to 

do anything different. Westfir has since responded that they understand the PM2.5 standards, but 

they don’t agree with it and regarding the boundary they took up DEQ’s offer to take a look at 

that. So, we will be providing any additional information DEQ would like to see in that process. 

Brommelsiek made a suggestion that at some point it might be worth talking to our elected 

officials in Washington DC, so they are aware beforehand of any significant changes proposed by 

EPA that would affect Lane County or Oregon. 

 Hough said he will be doing a “dry run” of the EQC presentation with DEQ staff on November 

28th and the following week he will be presenting it jointly with Andy Ginsburg from DEQ asking 

the EQC to adopt the Oakridge attainment plan. It looks like we are on schedule at this point for 

submitting in December 2012. 

Forge asked Merlyn what his take was on the Oakridge meeting last month with the City and 

police regarding enforcement on this. Hough said he was encouraged that there was support by the 

Mayor and they have had some counselor changes with the election. We are going to be working 

closely with the City to be sure they implement their ordinances. 

MOTION: Fleck moved to adopt the two proposed amendments. Lucas SECONDED 

THE MOTION. VOTE ON MOTION: 6-0 

Attachment 1.3b, page 2
Attachment 2

Evidence that the state has the necessary legal authority

See Attachment 1.1 “Commission Authority” (page #3 of Staff Report, Agenda Item I of the 

December 6-7, 2012, EQC meeting)
Attachment 3

Provisions submitted for approval

3.1 Adopted and amended rules submitted for approval

3.1a General Air Pollution Procedures and Definitions: OAR 340-200-: 0040. 

Effective December 10, 2012

3.1b Designation of Air Quality Areas: LRAPA Title 29. LRAPA Board adopted on

October 18, 2012

3.2 Redline/strikeout version of adopted and amended rules submitted for approval

3.2a General Air Pollution Procedures and Definitions: OAR 340-200-: 0040. 

Effective December 10, 2012

3.2b Designation of Air Quality Areas: LRAPA Title 29. LRAPA Board adopted on

October 18, 2012

3.3 Attainment plan and appendices submitted for approval

3.3 Oakridge-Westfir PM2.5 Attainment Plan

3.3a Appendix A – UMAA

3.3a1 Appendix A1 - Oakridge PM Saturation Study October 2003

3.3b Appendix B - Meterology

3.3c1 Appendix C1 - 2010 SF1 Cites M-P (no header attached)

3.3c2 Appendix C2 - Household and employment growth projections

3.3c3 Appendix C3 - Oakridge VMT Projections 2002-2025 by LCOG

3.3d Oakridge emission inventory with attachments

3.3e1 SANDWICH

3.3e2 Oakridge PMF report July 30, 2012

3.3f1 Oakridge ordinance

3.3f2 Smoke management directive

3.3f3 Title 38 New Source Review

3.3f4 Woodstove changeout list

3.3f5 Recommended strategies December 31, 2011

3.3g Design value

3.3h Rollback modeling

3.3i Transportation analysis of Oakridge by LCOG

3.3j RACT - RACM analysis
DEPARTMENT OF ENVIRONMENTAL QUALITY

DIVISION 200 

GENERAL AIR POLLUTION PROCEDURES AND DEFINITIONS

General

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 the Department of Environmental 

Quality and is adopted as the state implementation plan (SIP) of the State of Oregon pursuant to the 

federal Clean Air Act, 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 Commission’s 

rulemaking procedures in division 11 of this chapter and any other requirements contained in the SIP and 

will be submitted to the United States Environmental Protection Agency for approval. The State 

Implementation Plan was last modified by the Commission on December 6, 2012. 

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

(a) Submit to the Environmental Protection Agency any permit condition implementing a rule that is part of 

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

public hearings provisions of 40 CFR 51.102 (July 1, 2002); and

(b) Approve the standards submitted by a regional authority if the regional authority adopts verbatim any 

standard that the Commission has adopted, and submit the standards to EPA for approval as a SIP 

revision.

NOTE: Revisions to the State of Oregon Clean Air Act Implementation Plan become federally enforceable 

upon approval by the United States Environmental Protection Agency. If any provision of the federally 

approved Implementation Plan conflicts with any provision adopted by the Commission, the Department 

shall enforce the more stringent provision.

Stat. Auth.: ORS 468.020, 468A.035 & 468A.070 

Stats. Implemented: ORS 468A.035 

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-

Attachment 3.1a, page 1
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

Attachment 3.1a, page 2
Amended 10-18-2012 29.1 

LANE REGIONAL AIR PROTECTION AGENCY 

TITLE 29

DESIGNATION OF AIR QUALITY AREAS

 

Section 29-0010 Definitions 

The definitions in Title 12 and this rule apply to this division. If the same term is defined 

in this rule and Title 12, the definition in this rule applies to this division. Definitions of 

boundaries in this rule also apply to LRAPA Rules and Regulations. 

(1) "AQCR" means Air Quality Control Region. 

(2) "AQMA" means Air Quality Maintenance Area. 

(3) "CO" means Carbon Monoxide. 

(4) "CBD" means Central Business District. 

(5) "Criteria Pollutant" means any of the six pollutants set out by the Clean Air Act 

(sulfur oxides, particulate matter, ozone, carbon monoxide, nitrogen dioxide, and lead) 

for which the EPA has promulgated standards in 40 CFR 50.4 through 50.12 (July, 1993). 

(6) "Eugene-Springfield UGB" means the area within the bounds beginning at the 

Willamette River at a point due east from the intersection of East Beacon Road and River 

Loop No.1; thence southerly along the Willamette River to the intersection with Belt Line 

Road; thence easterly along Belt Line Road approximately one-half mile to the 

intersection with Delta Highway; thence northwesterly and then northerly along Delta 

Highway and on a line north from the Delta Highway to the intersection with the 

McKenzie River; thence generally southerly and easterly along the McKenzie River 

approximately eleven miles to the intersection with Marcola Road; thence southwesterly 

along Marcola Road to the intersection with 42nd Street; thence southerly along 42nd 

Street to the intersection with the northern branch of US Highway 126; thence easterly 

along US Highway 126 to the intersection with 52nd Street; thence north along 52nd 

Street to the intersection with High Banks Road; thence easterly along High Banks Road 

to the intersection with 58th Street; thence south along 58th Street to the intersection with 

Thurston Road; thence easterly along Thurston Road to the intersection with the western 

boundary of Section 36, T17S, R2W; thence south to the southwest corner of Section 36, 

T17S, R2W; thence west to the Springfield City Limits; thence following the Springfield 

City Limits southwesterly to the intersection with the western boundary of Section 2, 

T18S, R2W; thence on a line southwest to the Private Logging Road approximately onehalf mile away; thence southeasterly along the Private Logging Road to the intersection 

with Wallace Creek; thence southwesterly along Wallace Creek to the confluence with 

Attachment 3.1b, page 1
Amended 10-18-2012 29.2 

the Middle Fork of the Willamette River; thence generally northwesterly along the 

Middle Fork of the Willamette River approximately seven and one-half miles to the 

intersection with the northern boundary of Section 11, T18S, R3W; thence west to the 

northwest corner of Section 10, T18S, R3W; thence south to the intersection with 30th 

Avenue; thence westerly along 30th Avenue to the intersection with the Eugene City 

Limits; thence following the Eugene City Limits first southerly then westerly then 

northerly and finally westerly to the intersection with the northern boundary of Section 5, 

T18S, R4W; thence west to the intersection with Greenhill Road; thence north along 

Greenhill Road to the intersection with Barger Drive; thence east along Barger Drive to 

the intersection with the Eugene City Limits (Ohio Street); thence following the Eugene 

City Limits first north then east then north then east then south then east to the 

intersection with Jansen Drive; thence east along Jansen Drive to the intersection with 

Belt Line Road; thence northeasterly along Belt Line Road to the intersection with 

Highway 99; thence northwesterly along Highway 99 to the intersection with Clear Lake 

Road; thence west along Clear Lake Road to the intersection with the western boundary 

of Section 9, T17S, R4W; thence north to the intersection with Airport Road; thence east 

along Airport Road to the intersection with Highway 99; thence northwesterly along 

Highway 99 to the intersection East Enid Road; thence east along East Enid Road to the 

intersection with Prairie Road; thence southerly along Prairie Road to the intersection 

with Irvington Road; thence east along Irvington Road to the intersection with the 

Southern Pacific Railroad Line; thence southeasterly along the Southern Pacific Railroad 

Line to the intersection with Irving Road; thence east along Irving Road to the 

intersection with Kalmia Road; thence northerly along Kalmia Road to the intersection 

with Hyacinth Road; thence northerly along Hyancinth Road to the intersection with 

Irvington Road; thence east along Irvington Road to the intersection with Spring Creek; 

thence northerly along Spring Creek to the intersection with River Road; thence northerly 

along River Road to the intersection with East Beacon Drive; thence following East 

Beacon Drive first east then south then east to the intersection with River Loop No.1; 

thence on a line due east to the Willamette River and the point of beginning. 

 (7) "Maintenance Area" means any area that was formerly nonattainment for a criteria 

pollutant but has since met EPA promulgated standards and has had a maintenance plan 

to stay within the standards approved by the EPA pursuant to 40 CFR 51.110 (July, 

1993). 

(8) "Nonattainment Area" means any area that has been designated as not meeting the 

standards established by the U.S. Environmental Protection Agency (EPA) pursuant to 40 

CFR 51.52 (July, 1993) for any criteria pollutant. 

(9) "O3" means Ozone. 

(10) “Oakridge PM2.5 Nonattainment Area” means the area enclosed by the following: 

T21S, R2E, Sect 11 (NW Corner) east to T21S, R3E, Sect 11 (NE corner), south to T21S, 

R3E, Sect 23(SE Corner), west to T21S, R2E, Sect 23(SW corner) correctly back to 

T21S, R2E, Sect 11(NW corner). 

Attachment 3.1b, page 2
Amended 10-18-2012 29.3 

(11) "Oakridge UGB" means the area enclosed by the following: Beginning at the 

northwest corner of Section 17, T21S, R3E and the city limits; thence south along the 

western boundary of Section 17, T21S, R3E along the city limits approximately 800 feet; 

thence southwesterly following the city limits approximately 750 feet; thence west along 

the city limits approximately 450 feet; thence northwesterly along the city limits 

approximately 450 feet; thence on a line south along the city limits approximately 250 

feet; thence on a line east along the city limits approximately 100 feet; thence 

southwesterly along the city limits approximately 200 feet; thence on a line east along the 

city limits approximately 400 feet; thence on a line south along the city limits to the 

channel of the Willamette River Middle Fork; thence south-easterly up the Willamette 

River Middle Fork along the city limits approximately 7200 feet; thence exiting the 

Willamette River Middle Fork with the city limits in a northerly manner and forming a 

rough semicircle with a diameter of approximately one-half mile before rejoining the 

Willamette River Middle Fork; thence diverging from the city limits upon rejoining the 

Willamette River Middle Fork and moving southeasterly approximately 5600 feet up the 

Willamette River Middle Fork to a point on the river even with the point where Salmon 

Creek Road intersects with U.S. Highway 58; thence on a line east from the channel of 

the Willamette River Middle Fork across the intersection of Salmon Creek Road and U.S. 

Highway 58 to the intersection with the Southern Pacific Railroad Line; thence northerly 

along the Southern Pacific Railroad Line to the intersection with the northern boundary 

of Section 22, T21S, R3E; thence west along the northern boundary of Section 22, T21S, 

R3E to the intersection with Salmon Creek Road; thence on a line north to the 

intersection with the Southern Pacific Railroad Line; thence east along the Southern 

Pacific Railroad Line approximately 600 feet; thence on a line north to the intersection 

with High Prairie Road; thence on a line west approximately 400 feet; thence on a line 

north to the intersection with the northern boundary of Section 15, T21S, R3E; thence 

west along the northern boundary of Section 15, T21S, R3E to the intersection with the 

southeastern corner of Section 9, T21S, R3E; thence north along the eastern boundary of 

Section 9, T21S, R3E approximately 1300 feet; thence on a line west approximately 1100 

feet; thence on a line south to the intersection with West Oak Road; thence northwesterly 

along West Oak Road approximately 2000 feet; thence on a line south to the intersection 

with the northern boundary line of the city limits; thence westerly and northwesterly 

approximately 8000 feet along the city limits to the point of beginning. 

(12) "Particulate Matter" means all finely divided solid or liquid material, other than 

uncombined water, emitted to the ambient air as measured by an applicable reference 

method with the Department's Source Sampling Manual, (January, 1992). 

(13) PM10: 

(a) When used in the context of emissions, means finely divided solid or liquid material, 

including condensible water, other than combined water, with an aerodynamic diameter 

less than or equal to a nominal 10 microns, emitted to the ambient air as measured by as 

applicable reference method in accordance with the Department's Source Sampling 

Manual (January, 1992); 

Attachment 3.1b, page 3
Amended 10-18-2012 29.4 

(b) When used in the context of ambient concentration, means airborne finely divided 

solid or liquid material with an aerodynamic diameter less than or equal to a nominal 10 

microns as measured in accordance with 40 CFR Part 50, Appendix J (July, 1993). 

 (14) "UGA" means Urban Growth Area. (synonymous with “UGB”)

(15) "UGB" means Urban Growth Boundary. 

Section 29-0020 Designation of Air Quality Control Regions

Oregon's thirty-six counties are divided into five AQCRs. The AQCR boundaries follow 

county lines, and there are no counties that belong to more than one AQCR. The five 

AQCRs are as follows: 

(1) Portland Interstate AQCR, containing ten counties: 

(a) Benton County; 

(b) Clackamas County; 

(c) Columbia County; 

(d) Lane County; 

(e) Linn County; 

(f) Marion County; 

(g) Multnomah County; 

(h) Polk County; 

(i) Washington County; 

(j) Yamhill County. 

(2) Northwest Oregon AQCR, containing three counties: 

(a) Clatsop County; 

(b) Lincoln County; 

(c) Tillamook County. 

(3) Southwest Oregon AQCR, containing five counties: 

Attachment 3.1b, page 4
Amended 10-18-2012 29.5 

(a) Coos County; 

(b) Curry County; 

(c) Douglas County; 

(d) Jackson County; 

(e) Josephine County. 

(4) Central Oregon AQCR, containing eight counties: 

(a) Crook County; 

(b) Deschutes County; 

(c) Hood River County; 

(d) Jefferson County; 

(e) Klamath County; 

(f) Lake County; 

(g) Sherman County; 

(h) Wasco County. 

(5) Eastern Oregon AQCR, containing ten counties: 

(a) Baker County; 

(b) Gilliam County; 

(c) Grant County; 

(d) Harney County; 

(e) Malheur County; 

(f) Morrow County; 

(g) Umatilla County; 

(h) Union County; 

Attachment 3.1b, page 5
Amended 10-18-2012 29.6 

(i) Wallowa County; 

(j) Wheel County. 

Section 29-0030 Designation of Nonattainment Areas 

The following areas are designated as Nonattainment Areas: 

 (1) PM10 Nonattainment Areas: 

 (a) The Oakridge Nonattainment Area for PM10 is the Oakridge UGB as defined in 

Section 29-0010. 

(2) PM2.5 Nonattainment Areas: 

(a) The Oakridge Nonattainment Area for PM2.5 is defined in Section 29-0010. 

Section 29-0040 Designation of Maintenance Areas 

The following areas are designated as Maintenance Areas: 

(1) Carbon Monoxide Maintenance Areas: 

(a) The Eugene Maintenance Area for Carbon Monoxide is the Eugene-Springfield UGB 

as defined in Section 29-0010. 

(2) PM10 Maintenance Areas: 

(a) The Eugene-Springfield Maintenance Area for PM10 is the Eugene-Springfield UGB 

as defined in Section 29-0010. 

Section 29-0050 Designation of Prevention of Significant Deterioration Areas

(1) All of the following areas which were in existence on August 7, 1977, shall be Class I 

Areas and may not be redesignated: 

(a) Mt. Hood Wilderness, as established by Public Law 88-577; 

(b) Eagle Cap Wilderness, as established by Public Law 88-577; 

(c) Hells Canyon Wilderness, as established by Public Law 94-199; 

(d) Mt. Jefferson Wilderness, as established by Public Law 90-548; 

(e) Mt. Washington Wilderness, as established by Public Law 88-577; 

Attachment 3.1b, page 6
Amended 10-18-2012 29.7 

(f) Three Sisters Wilderness, as established by Public Law 88-577; 

(g) Strawberry Mountain Wilderness, as established by Public Law 88-577; 

(h) Diamond Peak Wilderness, as established by Public Law 88-577; 

(i) Crater Lake National Park, as established by Public Law 88-577 and expanded in the 

1990 Clean Air Act Amendments; 

(j) Kalmiopsis Wilderness, as established by Public Law 88-577; 

(k) Mountain Lake Wilderness, as established by Public Law 88-577; 

(l) Gearhart Mountain Wilderness, as established by Public Law 88-577. 

(2) All other areas, in Oregon are initially designated Class II, but may be redesignated as 

provided in Section 29-0060. 

(3) The following areas may be redesignated only as Class I or II: 

(a) An area which as of August 7, 1977, exceeded 10,000 acres in size and was a national 

monument, a national primitive area, a national preserve, a national recreational area, a 

national wild and scenic river, a national wildlife refuge, a national lakeshore or seashore; 

and 

(b) A national park or national wilderness area established after August 7, 1977, which 

exceeds 10,000 acres in size. 

(4) The extent of the areas referred to in section (1) and (3) of this rule shall conform to 

any changes in the boundaries of such areas which occurred between August 7, 1977, and 

November 15, 1990. 

Section 29-0060 Redesignation of Prevention of Significant Deterioration Areas

(1)(a) All areas in Oregon, except as otherwise provided under Section 29-0050, are 

designated Class II as of December 5, 1974; 

(b) Redesignation, except as otherwise precluded by Section 29-0050, may be proposed 

by LRAPA, as provided below, subject to approval by the EPA Administrator as a 

revision to the State Implementation Plan. 

(2) LRAPA may submit to the EPA Administrator a proposal to redesignate areas of the 

state Class I or II provided that: 

(a) At least one public hearing has been held in accordance with procedures established in 

the Plan; 

Attachment 3.1b, page 7
Amended 10-18-2012 29.8 

(b) Other States, Indian Governing Bodies, and Federal Land Managers whose lands may 

be affected by the proposed redesignation were notified at least 30 days prior to the 

public hearing; 

(c) A discussion of the reasons for the proposed redesignation, including a satisfactory 

description and analysis of the health, environmental, economic, social and energy effects 

of the proposed redesignation, was prepared and made available for public inspection at 

least 30 days prior to the hearing and the notice announcing the hearing contained 

appropriate notification of the availability of such discussion; 

(d) Prior to the issuance of notice respecting the redesignation of an area that includes 

any Federal lands, LRAPA has provided written notice to the appropriate Federal Land 

Manager and afforded adequate opportunity, not in excess of 60 days to confer with 

LRAPA respecting the redesignation and to submit written comments and 

recommendations. In redesignating any area with respect to which any Federal Land 

Manager had submitted written comments and recommendations, LRAPA shall have 

published a list of any inconsistency between such redesignation and such comments and 

recommendations together with the reasons for making such redesignation against the 

recommendation of the Federal Land Manager; and 

(e) LRAPA has proposed the redesignation after consultation with the elected leadership 

of local general purpose governments in the area covered by the proposed redesignation. 

(3) Any area other than an area to which Section 29-0050 refers may be redesignated as 

Class III if: 

(a) The redesignation would meet the requirements of section (2) of this rule; 

(b) The redesignation, except any established by an Indian Governing Body, has been 

specifically approved by the Governor, after consultation with the appropriate 

committees of the legislature, if it is in session, or with the leadership of the legislature, if 

it is not in session, unless state law provides that the redesignation must be specifically 

approved by state legislation, and if general purpose units of local government 

representing a majority of the residents of the area to be redesignated enact legislation or 

pass resolutions concurring in the redesignation; 

(c) The redesignation would not cause, or contribute to, a concentration of any air 

pollutant which would exceed any maximum allowable increase permitted under the 

classification of any other area or any national ambient air quality standard; and 

(d) Any permit application for any major stationary source or major modification, subject 

to review under section (1) of this rule, which could receive a permit under this section 

only if the area in question were redesignated as Class III, and any material submitted as 

part of that application, were available insofar as was practicable for public inspection 

prior to any public hearing on redesignation of the area as Class III. 

Attachment 3.1b, page 8
Amended 10-18-2012 29.9 

(4) Lands within the exterior boundaries of Indian Reservations may be redesignated only 

by the appropriate Indian Governing Body. The appropriate Indian Governing Body may 

submit to the EPA Administrator a proposal to redesignate areas Class I, II, or III; 

provided that: 

(a) The Indian Governing Body has followed procedures equivalent to those required of 

LRAPA under section (2) and subsections (3)(c) and (d) of this rule; and 

(b) Such redesignation is proposed after consultation with the state(s) in which the Indian 

Reservation is located and which border the Indian Reservation. 

(5) The EPA Administrator shall disapprove, within 90 days of submission, a proposed 

redesignation of any area only if he finds, after notice and opportunity for public hearing, 

that such redesignation does not meet the procedural requirements of this paragraph or is 

inconsistent with Section 29-0050. If any such disapproval occurs, the classification of 

the area shall be that which was in effect prior to the redesignation which was 

disapproved. 

(6) If the EPA Administrator disapproves any proposed redesignation, LRAPA or Indian 

Governing Body, as appropriate, may resubmit the proposal after correcting the 

deficiencies noted by the EPA Administrator. 

Section 29-0070 Special Control Areas

The following areas are designated as Special Control Areas: 

(1) Lane County; 

 (2) Within incorporated cities having a population of 4,000 or more, and within three 

miles of the corporate limits of any such city. 

Section 29-0080 Motor Vehicle Inspection Boundary Designations

In addition to the area specified in ORS 815.300, pursuant to ORS 468A.390, the 

following geographical areas are designated as areas within which motor vehicles are 

subject to the requirement under ORS 815.300 to have a Certificate of Compliance issued 

pursuant to ORS 468A.380 to be registered or have the registration of the vehicle 

renewed. 

(1) There are currently no geographic areas in Lane County subject to motor vehicle 

inspection programs. 

Section 29-0090 Oxygenated Gasoline Control Areas 

There currently are no oxygenated gasoline control areas in Lane County. 

Attachment 3.1b, page 9
DEPARTMENT OF ENVIRONMENTAL QUALITY

DIVISION 200 

GENERAL AIR POLLUTION PROCEDURES AND DEFINITIONS

General

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 the Department of Environmental 

Quality and is adopted as the state implementation plan (SIP) of the State of Oregon pursuant to the 

federal Clean Air Act, 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 Commission’s 

rulemaking procedures in division 11 of this chapter and any other requirements contained in the SIP and 

will be submitted to the United States Environmental Protection Agency for approval. The State 

Implementation Plan was last modified by the Commission on December 6, 2012.

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

(a) Submit to the Environmental Protection Agency any permit condition implementing a rule that is part of 

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

public hearings provisions of 40 CFR 51.102 (July 1, 2002); and

(b) Approve the standards submitted by a regional authority if the regional authority adopts verbatim any 

standard that the Commission has adopted, and submit the standards to EPA for approval as a SIP 

revision.

NOTE: Revisions to the State of Oregon Clean Air Act Implementation Plan become federally enforceable 

upon approval by the United States Environmental Protection Agency. If any provision of the federally 

approved Implementation Plan conflicts with any provision adopted by the Commission, the Department 

shall enforce the more stringent provision.

Stat. Auth.: ORS 468.020, 468A.035 & 468A.070

Stats. Implemented: ORS 468A.035

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-

Attachment 3.2a, page 1
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

Attachment 3.2a, page 2
Draft July 19, 2012 29.1 

LANE REGIONAL AIR PROTECTION AGENCY 

TITLE 29

DESIGNATION OF AIR QUALITY AREAS

 

Section 29-0010 Definitions 

The definitions in Title 12 and this rule apply to this division. If the same term is defined 

in this rule and Title 12, the definition in this rule applies to this division. Definitions of 

boundaries in this rule also apply to LRAPA Rules and Regulations. 

(1) "AQCR" means Air Quality Control Region. 

(2) "AQMA" means Air Quality Maintenance Area. 

(3) "CO" means Carbon Monoxide. 

(4) "CBD" means Central Business District. 

(5) "Criteria Pollutant" means any of the six pollutants set out by the Clean Air Act 

(sulfur oxides, particulate matter, ozone, carbon monoxide, nitrogen dioxide, and lead) 

for which the EPA has promulgated standards in 40 CFR 50.4 through 50.12 (July, 1993). 

(6) "Eugene-Springfield UGB" means the area within the bounds beginning at the 

Willamette River at a point due east from the intersection of East Beacon Road and River 

Loop No.1; thence southerly along the Willamette River to the intersection with Belt Line 

Road; thence easterly along Belt Line Road approximately one-half mile to the 

intersection with Delta Highway; thence northwesterly and then northerly along Delta 

Highway and on a line north from the Delta Highway to the intersection with the 

McKenzie River; thence generally southerly and easterly along the McKenzie River 

approximately eleven miles to the intersection with Marcola Road; thence southwesterly 

along Marcola Road to the intersection with 42nd Street; thence southerly along 42nd 

Street to the intersection with the northern branch of US Highway 126; thence easterly 

along US Highway 126 to the intersection with 52nd Street; thence north along 52nd 

Street to the intersection with High Banks Road; thence easterly along High Banks Road 

to the intersection with 58th Street; thence south along 58th Street to the intersection with 

Thurston Road; thence easterly along Thurston Road to the intersection with the western 

boundary of Section 36, T17S, R2W; thence south to the southwest corner of Section 36, 

T17S, R2W; thence west to the Springfield City Limits; thence following the Springfield 

City Limits southwesterly to the intersection with the western boundary of Section 2, 

T18S, R2W; thence on a line southwest to the Private Logging Road approximately onehalf mile away; thence southeasterly along the Private Logging Road to the intersection 

with Wallace Creek; thence southwesterly along Wallace Creek to the confluence with 

Attachment 3.2b, page 1
Draft July 19, 2012 29.2 

the Middle Fork of the Willamette River; thence generally northwesterly along the 

Middle Fork of the Willamette River approximately seven and one-half miles to the 

intersection with the northern boundary of Section 11, T18S, R3W; thence west to the 

northwest corner of Section 10, T18S, R3W; thence south to the intersection with 30th 

Avenue; thence westerly along 30th Avenue to the intersection with the Eugene City 

Limits; thence following the Eugene City Limits first southerly then westerly then 

northerly and finally westerly to the intersection with the northern boundary of Section 5, 

T18S, R4W; thence west to the intersection with Greenhill Road; thence north along 

Greenhill Road to the intersection with Barger Drive; thence east along Barger Drive to 

the intersection with the Eugene City Limits (Ohio Street); thence following the Eugene 

City Limits first north then east then north then east then south then east to the 

intersection with Jansen Drive; thence east along Jansen Drive to the intersection with 

Belt Line Road; thence northeasterly along Belt Line Road to the intersection with 

Highway 99; thence northwesterly along Highway 99 to the intersection with Clear Lake 

Road; thence west along Clear Lake Road to the intersection with the western boundary 

of Section 9, T17S, R4W; thence north to the intersection with Airport Road; thence east 

along Airport Road to the intersection with Highway 99; thence northwesterly along 

Highway 99 to the intersection East Enid Road; thence east along East Enid Road to the 

intersection with Prairie Road; thence southerly along Prairie Road to the intersection 

with Irvington Road; thence east along Irvington Road to the intersection with the 

Southern Pacific Railroad Line; thence southeasterly along the Southern Pacific Railroad 

Line to the intersection with Irving Road; thence east along Irving Road to the 

intersection with Kalmia Road; thence northerly along Kalmia Road to the intersection 

with Hyacinth Road; thence northerly along Hyancinth Road to the intersection with 

Irvington Road; thence east along Irvington Road to the intersection with Spring Creek; 

thence northerly along Spring Creek to the intersection with River Road; thence northerly 

along River Road to the intersection with East Beacon Drive; thence following East 

Beacon Drive first east then south then east to the intersection with River Loop No.1; 

thence on a line due east to the Willamette River and the point of beginning. 

 (7) "Maintenance Area" means any area that was formerly nonattainment for a criteria 

pollutant but has since met EPA promulgated standards and has had a maintenance plan 

to stay within the standards approved by the EPA pursuant to 40 CFR 51.110 (July, 

1993). 

(8) "Nonattainment Area" means any area that has been designated as not meeting the 

standards established by the U.S. Environmental Protection Agency (EPA) pursuant to 40 

CFR 51.52 (July, 1993) for any criteria pollutant. 

(9) "O3" means Ozone. 

(10(10) “Oakridge PM2.5 Nonattainment Area” means the area enclosed by the 

following: T21S, R2E, Sect 11 (NW Corner) east to T21S, R3E, Sect 11 (NE corner), 

Attachment 3.2b, page 2
Draft July 19, 2012 29.3 

south to T21S, R3E, Sect 23(SE Corner), west to T21S, R2E, Sect 23(SW corner) 

correctly back to T21S, R2E, Sect 11(NW corner).

(11) "Oakridge UGB" means the area enclosed by the following: Beginning at the 

northwest corner of Section 17, T21S, R3E and the city limits; thence south along the 

western boundary of Section 17, T21S, R3E along the city limits approximately 800 feet; 

thence southwesterly following the city limits approximately 750 feet; thence west along 

the city limits approximately 450 feet; thence northwesterly along the city limits 

approximately 450 feet; thence on a line south along the city limits approximately 250 

feet; thence on a line east along the city limits approximately 100 feet; thence 

southwesterly along the city limits approximately 200 feet; thence on a line east along the 

city limits approximately 400 feet; thence on a line south along the city limits to the 

channel of the Willamette River Middle Fork; thence south-easterly up the Willamette 

River Middle Fork along the city limits approximately 7200 feet; thence exiting the 

Willamette River Middle Fork with the city limits in a northerly manner and forming a 

rough semicircle with a diameter of approximately one-half mile before rejoining the 

Willamette River Middle Fork; thence diverging from the city limits upon rejoining the 

Willamette River Middle Fork and moving southeasterly approximately 5600 feet up the 

Willamette River Middle Fork to a point on the river even with the point where Salmon 

Creek Road intersects with U.S. Highway 58; thence on a line east from the channel of 

the Willamette River Middle Fork across the intersection of Salmon Creek Road and U.S. 

Highway 58 to the intersection with the Southern Pacific Railroad Line; thence northerly 

along the Southern Pacific Railroad Line to the intersection with the northern boundary 

of Section 22, T21S, R3E; thence west along the northern boundary of Section 22, T21S, 

R3E to the intersection with Salmon Creek Road; thence on a line north to the 

intersection with the Southern Pacific Railroad Line; thence east along the Southern 

Pacific Railroad Line approximately 600 feet; thence on a line north to the intersection 

with High Prairie Road; thence on a line west approximately 400 feet; thence on a line 

north to the intersection with the northern boundary of Section 15, T21S, R3E; thence 

west along the northern boundary of Section 15, T21S, R3E to the intersection with the 

southeastern corner of Section 9, T21S, R3E; thence north along the eastern boundary of 

Section 9, T21S, R3E approximately 1300 feet; thence on a line west approximately 1100 

feet; thence on a line south to the intersection with West Oak Road; thence northwesterly 

along West Oak Road approximately 2000 feet; thence on a line south to the intersection 

with the northern boundary line of the city limits; thence westerly and northwesterly 

approximately 8000 feet along the city limits to the point of beginning. 

(1112) "Particulate Matter" means all finely divided solid or liquid material, other than 

uncombined water, emitted to the ambient air as measured by an applicable reference 

method with the Department's Source Sampling Manual, (January, 1992). 

(1213) PM10: 

(a) When used in the context of emissions, means finely divided solid or liquid material, 

including condensible water, other than combined water, with an aerodynamic diameter 

less than or equal to a nominal 10 microns, emitted to the ambient air as measured by as 

Attachment 3.2b, page 3
Draft July 19, 2012 29.4 

applicable reference method in accordance with the Department's Source Sampling 

Manual (January, 1992); 

(b) When used in the context of ambient concentration, means airborne finely divided 

solid or liquid material with an aerodynamic diameter less than or equal to a nominal 10 

microns as measured in accordance with 40 CFR Part 50, Appendix J (July, 1993). 

 (1314) "UGA" means Urban Growth Area. (synonymous with “UGB”)

(1415) "UGB" means Urban Growth Boundary. 

Section 29-0020 Designation of Air Quality Control Regions

Oregon's thirty-six counties are divided into five AQCRs. The AQCR boundaries follow 

county lines, and there are no counties that belong to more than one AQCR. The five 

AQCRs are as follows: 

(1) Portland Interstate AQCR, containing ten counties: 

(a) Benton County; 

(b) Clackamas County; 

(c) Columbia County; 

(d) Lane County; 

(e) Linn County; 

(f) Marion County; 

(g) Multnomah County; 

(h) Polk County; 

(i) Washington County; 

(j) Yamhill County. 

(2) Northwest Oregon AQCR, containing three counties: 

(a) Clatsop County; 

(b) Lincoln County; 

(c) Tillamook County. 

Attachment 3.2b, page 4
Draft July 19, 2012 29.5 

(3) Southwest Oregon AQCR, containing five counties: 

(a) Coos County; 

(b) Curry County; 

(c) Douglas County; 

(d) Jackson County; 

(e) Josephine County. 

(4) Central Oregon AQCR, containing eight counties: 

(a) Crook County; 

(b) Deschutes County; 

(c) Hood River County; 

(d) Jefferson County; 

(e) Klamath County; 

(f) Lake County; 

(g) Sherman County; 

(h) Wasco County. 

(5) Eastern Oregon AQCR, containing ten counties: 

(a) Baker County; 

(b) Gilliam County; 

(c) Grant County; 

(d) Harney County; 

(e) Malheur County; 

(f) Morrow County; 

(g) Umatilla County; 

Attachment 3.2b, page 5
Draft July 19, 2012 29.6 

(h) Union County; 

(i) Wallowa County; 

(j) Wheel County. 

Section 29-0030 Designation of Nonattainment Areas 

The following areas are designated as Nonattainment Areas: 

 (1) PM10 Nonattainment Areas: 

 (a) The Oakridge Nonattainment Area for PM10 is the Oakridge UGB as defined in 

Section 29-0010. 

(2) PM2.5 Nonattainment Areas:

(a) The Oakridge Nonattainment Area for PM2.5 is defined in Section 29-0010.

Section 29-0040 Designation of Maintenance Areas 

The following areas are designated as Maintenance Areas: 

(1) Carbon Monoxide Maintenance Areas: 

(a) The Eugene Maintenance Area for Carbon Monoxide is the Eugene-Springfield UGB 

as defined in Section 29-0010. 

(2) PM10 Maintenance Areas: 

(a) The Eugene-Springfield Maintenance Area for PM10 is the Eugene-Springfield UGB 

as defined in Section 29-0010. 

Section 29-0050 Designation of Prevention of Significant Deterioration Areas

(1) All of the following areas which were in existence on August 7, 1977, shall be Class I 

Areas and may not be redesignated: 

(a) Mt. Hood Wilderness, as established by Public Law 88-577; 

(b) Eagle Cap Wilderness, as established by Public Law 88-577; 

(c) Hells Canyon Wilderness, as established by Public Law 94-199; 

(d) Mt. Jefferson Wilderness, as established by Public Law 90-548; 

Attachment 3.2b, page 6
Draft July 19, 2012 29.7 

(e) Mt. Washington Wilderness, as established by Public Law 88-577; 

(f) Three Sisters Wilderness, as established by Public Law 88-577; 

(g) Strawberry Mountain Wilderness, as established by Public Law 88-577; 

(h) Diamond Peak Wilderness, as established by Public Law 88-577; 

(i) Crater Lake National Park, as established by Public Law 88-577 and expanded in the 

1990 Clean Air Act Amendments; 

(j) Kalmiopsis Wilderness, as established by Public Law 88-577; 

(k) Mountain Lake Wilderness, as established by Public Law 88-577; 

(l) Gearhart Mountain Wilderness, as established by Public Law 88-577. 

(2) All other areas, in Oregon are initially designated Class II, but may be redesignated as 

provided in Section 29-0060. 

(3) The following areas may be redesignated only as Class I or II: 

(a) An area which as of August 7, 1977, exceeded 10,000 acres in size and was a national 

monument, a national primitive area, a national preserve, a national recreational area, a 

national wild and scenic river, a national wildlife refuge, a national lakeshore or seashore; 

and 

(b) A national park or national wilderness area established after August 7, 1977, which 

exceeds 10,000 acres in size. 

(4) The extent of the areas referred to in section (1) and (3) of this rule shall conform to 

any changes in the boundaries of such areas which occurred between August 7, 1977, and 

November 15, 1990. 

Section 29-0060 Redesignation of Prevention of Significant Deterioration Areas

(1)(a) All areas in Oregon, except as otherwise provided under Section 29-0050, are 

designated Class II as of December 5, 1974; 

(b) Redesignation, except as otherwise precluded by Section 29-0050, may be proposed 

by LRAPA, as provided below, subject to approval by the EPA Administrator as a 

revision to the State Implementation Plan. 

(2) LRAPA may submit to the EPA Administrator a proposal to redesignate areas of the 

state Class I or II provided that: 

Attachment 3.2b, page 7
Draft July 19, 2012 29.8 

(a) At least one public hearing has been held in accordance with procedures established in 

the Plan; 

(b) Other States, Indian Governing Bodies, and Federal Land Managers whose lands may 

be affected by the proposed redesignation were notified at least 30 days prior to the 

public hearing; 

(c) A discussion of the reasons for the proposed redesignation, including a satisfactory 

description and analysis of the health, environmental, economic, social and energy effects 

of the proposed redesignation, was prepared and made available for public inspection at 

least 30 days prior to the hearing and the notice announcing the hearing contained 

appropriate notification of the availability of such discussion; 

(d) Prior to the issuance of notice respecting the redesignation of an area that includes 

any Federal lands, LRAPA has provided written notice to the appropriate Federal Land 

Manager and afforded adequate opportunity, not in excess of 60 days to confer with 

LRAPA respecting the redesignation and to submit written comments and 

recommendations. In redesignating any area with respect to which any Federal Land 

Manager had submitted written comments and recommendations, LRAPA shall have 

published a list of any inconsistency between such redesignation and such comments and 

recommendations together with the reasons for making such redesignation against the 

recommendation of the Federal Land Manager; and 

(e) LRAPA has proposed the redesignation after consultation with the elected leadership 

of local general purpose governments in the area covered by the proposed redesignation. 

(3) Any area other than an area to which Section 29-0050 refers may be redesignated as 

Class III if: 

(a) The redesignation would meet the requirements of section (2) of this rule; 

(b) The redesignation, except any established by an Indian Governing Body, has been 

specifically approved by the Governor, after consultation with the appropriate 

committees of the legislature, if it is in session, or with the leadership of the legislature, if 

it is not in session, unless state law provides that the redesignation must be specifically 

approved by state legislation, and if general purpose units of local government 

representing a majority of the residents of the area to be redesignated enact legislation or 

pass resolutions concurring in the redesignation; 

(c) The redesignation would not cause, or contribute to, a concentration of any air 

pollutant which would exceed any maximum allowable increase permitted under the 

classification of any other area or any national ambient air quality standard; and 

(d) Any permit application for any major stationary source or major modification, subject 

to review under section (1) of this rule, which could receive a permit under this section 

only if the area in question were redesignated as Class III, and any material submitted as 

Attachment 3.2b, page 8
Draft July 19, 2012 29.9 

part of that application, were available insofar as was practicable for public inspection 

prior to any public hearing on redesignation of the area as Class III. 

(4) Lands within the exterior boundaries of Indian Reservations may be redesignated only 

by the appropriate Indian Governing Body. The appropriate Indian Governing Body may 

submit to the EPA Administrator a proposal to redesignate areas Class I, II, or III; 

provided that: 

(a) The Indian Governing Body has followed procedures equivalent to those required of 

LRAPA under section (2) and subsections (3)(c) and (d) of this rule; and 

(b) Such redesignation is proposed after consultation with the state(s) in which the Indian 

Reservation is located and which border the Indian Reservation. 

(5) The EPA Administrator shall disapprove, within 90 days of submission, a proposed 

redesignation of any area only if he finds, after notice and opportunity for public hearing, 

that such redesignation does not meet the procedural requirements of this paragraph or is 

inconsistent with Section 29-0050. If any such disapproval occurs, the classification of 

the area shall be that which was in effect prior to the redesignation which was 

disapproved. 

(6) If the EPA Administrator disapproves any proposed redesignation, LRAPA or Indian 

Governing Body, as appropriate, may resubmit the proposal after correcting the 

deficiencies noted by the EPA Administrator. 

Section 29-0070 Special Control Areas

The following areas are designated as Special Control Areas: 

(1) Lane County; 

 (2) Within incorporated cities having a population of 4,000 or more, and within three 

miles of the corporate limits of any such city. 

Section 29-0080 Motor Vehicle Inspection Boundary Designations

In addition to the area specified in ORS 815.300, pursuant to ORS 468A.390, the 

following geographical areas are designated as areas within which motor vehicles are 

subject to the requirement under ORS 815.300 to have a Certificate of Compliance issued 

pursuant to ORS 468A.380 to be registered or have the registration of the vehicle 

renewed. 

(1) There are currently no geographic areas in Lane County subject to motor vehicle 

inspection programs. 

Section 29-0090 Oxygenated Gasoline Control Areas 

Attachment 3.2b, page 9
Draft July 19, 2012 29.10 

There currently are no oxygenated gasoline control areas in Lane County. 

Attachment 3.2b, page 10
Oakridge Fine Particulate Matter (PM2.5) Attainment Plan 

1010 Main Street 

Springfield, Oregon 97477 

November 15, 2012 Final with changes from 

Board of Director’s Adoption October 18, 2012 and 

November 15, 2012 

Attachment 3.3, page 1
November 15, 2012 – Final 

2

Intentionally Blank 

Attachment 3.3, page 2

••• 
November 15, 2012 – Final 

3

Table of Contents

EXECUTIVE SUMMARY................................................................................................................7

THE OAKRIDGE PM2.5 ATTAINMENT PLAN..........................................................................................7

ATTAINMENT OF STANDARDS...........................................................................................................8

STRATEGIES AND CONTINGENCY PLAN................................................................................................9

Woodstove Curtailment and other Woodstove Strategies ....................................... 9

Other Strategies .....................................................................................................10

Contingency Plan Elements ....................................................................................11

INTRODUCTION ........................................................................................................................12

BACKGROUND............................................................................................................................12

WHAT IS PM2.5? ........................................................................................................................12

NATIONAL AMBIENT AIR QUALITY STANDARDS FOR PM2.5 ...................................................................12

PURPOSE OF ATTAINMENT PLAN ....................................................................................................12

OAKRIDGE AREA DESCRIPTION.......................................................................................................13

HISTORY OF EFFORTS TO ADDRESS PARTICULATE MATTER IN OAKRIDGE...................................................15

WHAT IS IN THIS ATTAINMENT PLAN? ..............................................................................................16

Nonattainment Area ..............................................................................................16

Attainment Demonstration ....................................................................................17

Implementation .....................................................................................................18

Attainment Plan Development Process ..................................................................18

NONATTAINMENT AREA...........................................................................................................19

AMBIENT AIR QUALITY MONITORING IN OAKRIDGE ............................................................................19

NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS) ....................................................................20

Annual PM2.5 standard ...........................................................................................20

24-hour PM2.5 standard ..........................................................................................20

Additional Monitoring ...........................................................................................21

VERIFICATION OF MONITORING LOCATION........................................................................................22

ATTAINMENT PLAN AND DEMONSTRATION ............................................................................24

EMISSION INVENTORY ..................................................................................................................24

BASE YEAR EMISSION INVENTORY (2008) ........................................................................................24

Residential Wood Combustion ...............................................................................25

Mobile and Nonroad Sources .................................................................................25

Industrial Point Sources..........................................................................................25

ATTAINMENT YEAR EMISSION INVENTORY (2014) ..............................................................................26

Economic Factors ...................................................................................................26

Growth Rates .........................................................................................................27

COMPARISON OF 2008 TO 2014 EMISSIONS ....................................................................................27

Attachment 3.3, page 3
November 15, 2012 – Final 

4

ATTAINMENT STRATEGIES – EMISSION REDUCTION ANALYSIS ................................................................27

PARTICULATE MATTER REDUCTION STRATEGIES (1989 -2008) .............................................................28

The Oakridge Air Pollution Control Ordinance #889 ..............................................28

LRAPA Advisory Programs ......................................................................................29

Open Burning Ordinance ........................................................................................30

Woodstove Change-out Programs .........................................................................30

Statewide Certification of Woodstoves ..................................................................30

Highway Road Sanding ..........................................................................................31

Smoke Management ..............................................................................................31

Road Paving ...........................................................................................................31

Industrial Requirements.........................................................................................31

Public Education .....................................................................................................31

Additional Strategies .............................................................................................32

CURRENT STRATEGIES 2009-2011 .................................................................................................32

Wood Stove Change-out program..........................................................................32

Heat Smart: Stove Removal upon Sale of Home ....................................................32

Public Education .....................................................................................................33

Transportation and Fuel-Related Emissions ...........................................................33

STRENGTHENED ONGOING STRATEGIES IN 2012-2014 .......................................................................33

Oakridge Air Quality Advisory Committee Strategy Recommendations ................34

Woodstove Change-outs........................................................................................34

Enforcement of Oakridge Ordinance ......................................................................34

Enhancements to Key Ongoing Strategies .............................................................34

Contingency Strategies ..........................................................................................35

Industrial Emission Reductions ...............................................................................35

ESTIMATED REDUCTIONS AND CREDITS FOR FUTURE STRATEGIES............................................................36

ATTAINMENT DEMONSTRATION .....................................................................................................36

Baseline Design Value ............................................................................................36

Background on Precursors......................................................................................37

Speciated Filter Sample Analysis ............................................................................38

Minor PM2.5 Components .......................................................................................39

Rollback Model ......................................................................................................40

Modeled Air Quality Improvements of the Key RWC Strategies.............................41

Unmonitored Area Analysis ...................................................................................41

Application of Future Strategies ............................................................................42

Contingency Plan ...................................................................................................42

ACKNOWLEDGEMENTS .............................................................................................................45

OAKRIDGE ADVISORY COMMITTEE ..................................................................................................45

PRINCIPAL AUTHORS....................................................................................................................45

CONTRIBUTORS ..........................................................................................................................45

Attachment 3.3, page 4
November 15, 2012 – Final 

5

TABLE OF TABLES

TABLE 1: PM2.5 ATTAINMENT DEMONSTRATION.....................................................................................9 

TABLE 2: 2002-2003 OAKRIDGE MONITORING SURVEY RESULTS .............................................................23

TABLE 3: 2008 ESTIMATED TYPICAL SEASON DAY AND WORST-CASE DAY PM2.5 EMISSIONS..........................24

TABLE 4: 2014 ESTIMATED TYPICAL SEASON DAY AND WORST-CASE DAY PM2.5 EMISSIONS..........................27

TABLE 5: OAKRIDGE WOOD CHANGE-OUT PROGRAMS (1993-96/2006-07) .............................................30

TABLE 6: OAKRIDGE WOOD CHANGE-OUT PROGRAMS (2009/2010-11) ..................................................32

TABLE 7: ANNUAL PM2.5 VALUES USED TO CALCULATE BASELINE DESIGN VALUE. ............................................37

TABLE 8: CONTRIBUTION BY SPECIATED COMPONENTS. RESULTS OF SANDWICH ANALYSIS FOR THE TOP 25% HIGH 

CONCENTRATION WINTER (OCT-MAR) DAYS. ................................................................................39

TABLE 9: BASELINE AND FUTURE PROJECTED DESIGN VALUES ....................................................................40

TABLE 10: ALLOCATION OF EMISSIONS AND MODELED CONCENTRATIONS FOR BASE AND FUTURE YEARS. .............42

Table of Figures

FIGURE 1: OAKRIDGE NONATTAINMENT AREA 2008 WORST CASE DAY EMISSIONS.........................................8 

FIGURE 2: SPECIAL PROTECTION ZONE SURROUNDING OAKRIDGE..............................................................10

FIGURE 3: OAKRIDGE LOCATION........................................................................................................14

FIGURE 4: NONATTAINMENT AREA.....................................................................................................15

FIGURE 5: PM2.5 ANNUAL STANDARD COMPARISON CONCENTRATIONS FROM THE OAKRIDGE MONITOR. ............20

FIGURE 6: PM2.5 24-HOUR STANDARD COMPARISON CONCENTRATIONS FROM THE OAKRIDGE MONITOR. ...........21

FIGURE 7: NEPHELOMETER ESTIMATED PM2.5 FOR OAKRIDGE AND WESTFIR DURING WINTER 2009-2010. ........22

FIGURE 8: 2002-2003 OAKRIDGE MONITORING SURVEY SITE MAP..........................................................22

FIGURE 9: OAKRIDGE PM2.5 EMISSION INVENTORY FOR 2008 WORST WINTER DAYS ...................................25

FIGURE 10: SPECIATED COMPONENTS OF PM2.5 (USING SANDWICH ANALYSIS) .........................................38

Image

IMAGE 1: SMOKE INVERSION OVER OAKRIDGE, WHERE THE WILLAMETTE ACTIVITY CENTER IS LOCATED. THE 

PARTICULATE MATTER TRAPPED NEAR THE SURFACE BY A TEMPERATURE INVERSION IS CLEARLY VISIBLE. ........19

Attachment 3.3, page 5
November 15, 2012 – Final 

6

Table of Appendices

A) Unmonitored Area Analysis (UMAA)

1) Saturation Survey

B) Meteorological conditions

C) Growth projections

1) Population & household (census 2010)

2) Employment

3) Vehicle Miles Traveled (VMT) from Lane Council of Governments (LCOG)

D) Emission inventory

E) Speciation studies

1) SANDWICH (Sulfate, Adjusted Nitrate, Derived Water, Inferred 

Carbonaceous Material Balance Approach)

2) Positive Matrix Factorization (PMF) model

F) Strategies

1) Oakridge ordinance

2) Smoke Management Directive

3) Title 38 – Major New Source Review

4) Woodstove Changeout list

5) Oakridge Advisory Committee Report

6) Oakridge Title IX – General Regulations (see p.25) 

G) Design Value

H) Rollback Modeling

I) Transportation Analysis

J) RACT/RACM Analysis

K) Transportation Conformity Analysis

Attachment 3.3, page 6
November 15, 2012 – Final 

7

EXECUTIVE SUMMARY 

The U.S. Environmental Protection Agency (EPA) adopted revisions to the National Ambient Air 

Quality Standards (NAAQS) for PM2.5 in September 2006. PM2.5 is fine particulate matter two 

and a half microns and less in diameter, or about 1/28th the diameter of a human hair. Also 

referred to as respirable particulate matter, these tiny particles are inhaled deep into the lungs 

where they accumulate and aggravate respiratory conditions, particularly asthma. Fine 

particulate (PM2.5 microns and smaller) are associated with heart and lung disease, increased 

respiratory symptoms and disease, decreased lung function, and premature death. Chronic 

exposure to fine particulate has also been implicated in increased risk for cardiac events. 

Populations especially at risk include children, the elderly, and those with existing health 

problems. 

On October 8, 2009, the Environmental Protection Agency (EPA) issued final area nonattainment designations for the 24-hour national air quality standards for fine particulate 

matter (PM2.5). Oakridge was designated a non-attainment area in Oregon. Under the Clean 

Air Act, an area that violates the federal standards is designated as “nonattainment” and must 

adopt a plan with emission reduction measures to bring the area back into compliance. The 

area designated as non-attainment for PM2.5 contains Oakridge, the small town of Westfir and 

surrounding area. 

The Oakridge PM2.5 Attainment Plan 

The City of Oakridge has struggled to meet air quality standards. Oakridge was proposed a PM10

“non-attainment” area in September 1992, and designated on January 20, 1994. The City last 

exceeded that standard in 1993. Voluntary measures to reduce wood smoke emissions 

adopted in 1999 have reduced measured particulate levels. Progress in reducing wood smoke 

emissions made it possible for the City of Oakridge to meet the 1997 PM2.5 standard of 65

μg/m3. Despite progress in improving air quality, the tightening of the PM2.5 standard in 2006 

presented yet another challenge. 

Local climate and topography make Oakridge prone to wintertime temperature inversions, low 

wind speeds and poor atmospheric dispersion. During the winter months, Oakridge air quality 

is often threatened due to high concentrations of smoke from woodstoves settling on the valley 

floor of the city. Figure 1 shows the worst case day1

 contribution of each of these source 

categories in the Oakridge nonattainment area. 

 

1

 A worst case day is defined as a design value corresponding to the 98th percentile of the data collected for a given 

year or an average of the 98th percentile of three years. 

Attachment 3.3, page 7
November 15, 2012 – Final 

8

Figure 1: Oakridge Nonattainment Area 2008 Worst Case Day Emissions 

Attainment of Standards 

Despite significant progress in reducing particle pollution, the Oakridge area exceeded and 

consequently violated the federal 24-hour fine particulate (PM2.5) 2006 standard of 35 μg/m3

but complied with the annual PM2.5 standard of 15 μg/m3 in the 2001-2011 period. PM2.5 

concentrations above the 24-hour standard during this period are linked to wintertime 

inversions and high emissions.

The main purpose of the Oakridge PM2.5 attainment plan is to return the Oakridge area back to 

compliance with the 2006 24-hour standard by 2014 as required by federal law. Oakridge does 

not violate the annual PM2.5 standard. This attainment plan fulfills federal requirements 

regarding EPA designated nonattainment areas. 

The City of Oakridge has taken steps to address pollution from woodstoves. On February 20, 

2003, the Oakridge City Council adopted a home wood heating ordinance that: 

Changed previous voluntary woodburning curtailment measures to mandatory, 

Prohibited burning garbage in woodstoves and fireplaces, 

Incorporated a 40% opacity limit on chimneys, 

Incorporated the PM2.5 standard into the program, and 

Required the removal of uncertified woodstoves from property to be sold or rented. 

Industry

0.2%

Open Fireplaces

7.7%

Non-Certified 

Woodstoves

31.7%

Certified 

Woodstoves

45.4%

Pellet Stoves

1.3%

Other Area 

Sources

0.9%

On-Road Cars & 

Trucks

6.8%

Re-entrained 

Road Dust

5.0%

Railroads

1.1%

Oakridge PM2.5 Emission Inventory for 

2008 Worst Winter Days

Attachment 3.3, page 8
November 15, 2012 – Final 

9

In December 2008, the Oakridge City Council passed an ordinance prohibiting the use of an 

uncertified solid fuel heating device in a residence. The Lane Regional Air Protection Agency 

(LRAPA) has also worked closely with the City of Oakridge and other partners to help residents 

replace old, uncertified wood stove with new, cleaner burning and energy efficient heating 

systems. LRAPA also issues daily home wood heating advisories November 1 through the last 

day of February. When air quality is forecast to be in the unhealthy for sensitive groups range, 

LRAPA activates an automatic “callware” system to alert residents by telephone about burning 

restrictions. 

The use of these strategies and others identified by an advisory committee should further 

reduce ambient concentration of PM2.5 below the national health-based standard by 2014. The 

estimated ambient concentrations for both the annual and the worst case day are predicted to 

decrease based on a ratio of the 2008 ambient concentration to the projected emission 

inventory for the year 2014. 

The base year Design Value concentration confirms that additional strategies, beyond those 

implemented by 2008, are needed to bring the area into attainment. The future year 

concentration in Table 1 is based on implementation of the additional strategies and confirms 

that these strategies will be sufficient to meet the federal 24-hour standard by 2014. 

Base Year Future Year

Worst Case Day 

Concentration 39.5 μg/m3

28.2 μg/m3

Federal Standard 35 μg/ m3

35 μg/ m3

Table 1: PM2.5 Attainment Demonstration 

Strategies and Contingency Plan 

Woodstove Curtailment and other Woodstove Strategies 

Oakridge has been proactive in adopting a number of strategies to reduce emissions from home 

wood heating. These strategies include: 

City ordinances to curtail burning during stagnant weather periods. 

City ordinance requiring the removal of an uncertified wood stove upon sale of a 

home. 

City ordinance prohibiting the use of a noncertified wood stove in a residence. 

Partnering in additional change-out programs to encourage removal of noncertified 

stoves. 

Attachment 3.3, page 9
November 15, 2012 – Final 

10

A new stove certification program by EPA and the woodstove replacement programs continue 

to result in a significant emissions reduction in Oakridge. The continued replacement of older 

woodstoves coupled with better enforcement of daily advisories is expected to continue to 

decrease emissions through 2014 even with a moderate growth in households. 

Other Strategies 

Curtailing open burning has been identified as a way to reduce PM emissions. The Oakridge 

City Ordinance prohibits burning within the City limits on days with high concentrations of 

particulate matter in the month of October and March 1 – June 15. All open burning is 

prohibited between November 1 and February 28 inside the City limits. 

Oregon Department of Forestry (ODF) requires federal land managers to follow strict smoke 

management instructions and avoid smoke impacts to Oakridge. ODF has designated Oakridge 

as a Special Protection Zone (SPZ) shown in Figure 2. During the November 15 through 

February 15 period, prescribed burning in the SPZ is allowed only when the ODF smoke 

management meteorologist believes there will be no measurable smoke impacts within the 

nonattainment area. The SPZ prohibits any prescribed burning on red advisory days. 

Figure 2: Special Protection Zone Surrounding Oakridge 

Attachment 3.3, page 10
November 15, 2012 – Final 

11

Contingency Plan Elements 

The following strategies will be implemented as contingency strategies to fully meet the air 

quality standards, if it becomes clear that the strengthened ongoing strategies will not be 

sufficient to attain the PM2.5 standards by 2014 and or to maintain compliance with the 

standards through 2024 and beyond: 

• Stricter opacity limit on all green or yellow advisory days, revising the current 40% 

opacity limit to a more restrictive 20% limit, as has been done in some other 

northwest communities. A 20% opacity limit on green and yellow advisory days will 

help reduce emissions with the goal of avoiding red advisories when no visible 

emissions are allowed. 

Stricter green-yellow-red advisory program, with more yellow and red advisory days 

each winter. 

Further restrictions on the city woodstove curtailment exemptions (for sole source, 

economic hardship). 

If Oakridge meets the EPA Clean Air Act deadline for meeting the standard, the contingency 

plan will not be implemented. While this plan is not intended to attain any proposed standard, 

LRAPA estimates that Oakridge will meet a tightened annual standard of 12 μg/m3. 

Attachment 3.3, page 11
November 15, 2012 – Final 

12

INTRODUCTION 

Background 

This plan addresses the 24-hour and the annual ambient air quality standards for PM2.5 as 

defined in the federal Clean Air Act. In September 2006, the U.S. Environmental Protection 

Agency (EPA) strengthened the daily (24-hr) PM2.5 (fine particulate) standard by lowering the 

level from 65 g/m3 to 35 g/m3and retained the annual PM2.5 standard of 15 g/m3. Areas in 

violation of the PM2.5 standard (based on the most recent three years of federal reference 

monitoring data) are designated as a “nonattainment area” by the EPA. Oakridge, Oregon has 

been designated as nonattainment for the daily PM2.5 standard. The Lane Regional Air 

Protection Agency (LRAPA) must develop an attainment plan that will bring air quality into 

compliance with the standard as soon as possible, and submit this plan to EPA. 

What is PM2.5? 

Particulate matter (PM) is the general term used for a mixture of solid particles or liquid 

droplets found in the air. Some particles are large or dark enough to be seen as soot or smoke. 

Others are so small they can be detected only with an electron microscope. These particles 

come in a wide range of sizes (“fine” particles are less than 2.5 micrometers in diameter and 

coarser-sized particles are larger than 2.5 micrometers), and originate from many different 

sources. Fine particles (PM2.5) generally result from fuel combustion from residential fireplaces 

and woodstoves, pile and forest burning, industrial facilities, and motor vehicles. Coarse 

particles (PM10) are generally emitted from sources such as vehicles traveling on paved and 

unpaved roads, materials handling, and wood products operations, as well as wind-blown dust. 

These particles can accumulate in the respiratory system and are associated with numerous 

health effects. Fine particles are most closely associated with such health effects as increased 

hospital admissions and emergency room visits for heart and lung disease, increased 

respiratory symptoms and disease, decreased lung function and premature death. Sensitive 

groups that are at greatest risk include the elderly, individuals with cardiopulmonary disease 

such as asthma, and children. 

National Ambient Air Quality Standards for PM2.5

EPA has established National Ambient Air Quality Standards (NAAQS) for PM2.5 at 35 

micrograms per cubic meter (μg/m3) for a daily (24-hour) standard and 15 μg/m3 as an annual 

standard. Any value monitored above these levels, as defined by federal rules and guidance, is 

considered an exceedance. EPA uses the 98th percentile of the 24-hr PM2.5 within any given 

year and averages it over three calendar years. An exceedance of the average 98th percentile 

over three years greater than 35 μg/m3 is considered a violation. An exceedance of the annual 

standard averaged over three years becomes a violation of the annual standard. If an area 

violates either standard, EPA designates it as a nonattainment area. This plan includes a 

demonstration of continuing attainment with both standards. 

Purpose of Attainment Plan 

This document provides a pathway for continued improvement to reduce particulate emissions 

and to return the Oakridge Nonattainment Area (NA) to attainment for PM2.5 (state 

Attachment 3.3, page 12
November 15, 2012 – Final 

13

classification will be “maintenance”) by achieving the more protective national health standards 

adopted in 2006. It is a plan to ensure Oakridge meets the 24-hour and annual National 

Ambient Air Quality Standards for PM2.5 and maintains the annual standard for PM2.5. This 

document complies with the applicable 1990 Federal Clean Air Act (CAA) requirements and 

Environmental Protection Agency (EPA) guidance and policies. The attainment plan provides 

strategies to meet the PM2.5 standards by 2014 and provides contingency measures should 

Oakridge not meet the deadline. To demonstrate "attainment" requires the collection of 

representative monitoring data using approved measuring instruments and procedures, with 

adequate quality assurance. EPA will review the plan to determine if it is approvable and 

publish its findings in the Federal Register. Redesignation back to attainment is possible only 

after Oakridge meets the standards for three consecutive years and a maintenance plan is 

drafted, adopted by the LRAPA Board of Directors, the Environmental Quality Commission 

(EQC) and approved by EPA. EPA will then formally redesignate Oakridge back into attainment 

in the Federal Register. 

Oakridge Area Description 

Oakridge, Oregon lies in an alluvial plain in the foothills at the southern end of the Willamette 

River valley. The city is in Lane County, Oregon, approximately 45 miles east-southeast of 

Eugene, and 28 miles west of Willamette Pass, the summit of the Cascade Mountain Range. 

The city limits of present-day Oakridge includes the historic City of Oakridge and, directly west, 

the area formerly known as Willamette City. Figure 3 shows the location of Oakridge in Lane 

County. 

Attachment 3.3, page 13
November 15, 2012 – Final 

14

Figure 3: Oakridge Location 

Attachment 3.3, page 14
November 15, 2012 – Final 

15

Figure 4: Nonattainment Area 

The area of applicability for this attainment plan includes an area that contains the City of 

Oakridge and the small town of Westfir. Figure 4 shows the Oakridge non-attainment area. 

The City of Oakridge is situated in a valley oriented east-west, through which flows the middle 

fork of the Willamette River. Elevation of the area ranges from 1100 feet at the lower (west) 

end to 1600 feet with areas of densest population situated between 1100 feet and 1200 feet. 

Mountains rise on the north and south sides to 1700 feet and 1600 feet, respectively. 

Westfir is a very small (population 335) isolated rural mountain community that is located along 

the north fork of the Willamette River about 1 mile NW of Oakridge. Its elevation is about the 

same as Oakridge and it is surrounded by the same high mountains. Westfir and Oakridge are 

in separate steep sided river valleys separated by a 400-foot ridge. The Westfir valley is very 

narrow, only about 1/4 mile across at its widest point, while the Oakridge valley is about 1 mile 

across at its widest point. 

History of Efforts to Address Particulate Matter in Oakridge 

Oakridge has historically struggled with air quality issues during the winter months, especially 

on cold days during periods of air stagnation. Oakridge was proposed a PM10 non-attainment 

area in December 1993, effective on January 9, 1994. PM10 is defined as particulate matter 

with an aerodynamic diameter less than or equal to a nominal 10 micrometers as measured by 

Attachment 3.3, page 15
November 15, 2012 – Final 

16

an approved method listed in 40 CFR 53. Initial efforts to curtail wood smoke were developed 

for the Oakridge Urban Growth Boundary (UGB) by 1991, however, at that time the area still 

had not met the standard. LRAPA subsequently submitted a formal PM10 plan to EPA in 1996. 

EPA approved the attainment plan on May 14, 1999. One of the key strategies in the plan 

included a mandatory woodstove curtailment program and a woodstove change-out program. 

On March 19, 1992, the Oakridge City Council amended its open burning ordinance #689 to 

allow open backyard burning only during the months of October, March, April, and May and 

bans the use of burn barrels. Oakridge City Code 92.04.A.2 currently regulates open backyard 

burning inside the Oakridge city limits. This eliminated burning during wintertime periods of 

maximum atmospheric stagnation when burning is more likely to contribute to exceedances of 

the 24-hour standard. An aggressive wood stove change-out project, along with a voluntary 

residential wood burning advisory program, further reduced winter time PM10 emissions. In a 

letter of agreement with the Oregon Department of Transportation (ODOT), dated July 29, 

1996, ODOT agreed to use a chemical de-icing compound on Highway 58 as an alternative to 

sanding roads during the winter season. As a result of these strategies, the area was able to 

meet and continue to meet the PM10 standards from 1994 to present. 

EPA revised the particulate standard in 1997 to include PM2.5 and established a daily standard 

of 65 μg/m3. LRAPA began monitoring fine particulate matter (PM2.5) concentrations in 1998. 

The original PM10 strategies included in the 1996 attainment plan were so successful in 

maintaining clean air that Oakridge also met the fine particulate (PM2.5) standard. 

In 2006, EPA modified the PM2.5 standard, cutting the threshold for the 24-hour exceedance 

day roughly in half to 35 μg/m3. Oakridge has not yet been able to meet this new daily PM2.5 

standard, so continued progress is need to further reduce particulate emissions. LRAPA has 

measured PM2.5 at the same location in the Oakridge (Willamette Activity Center) since 1998 

and PM10 since 1989. LRAPA has also operated a nephelometer in Oakridge since 1989 which 

makes it possible to estimate PM2.5 during 1989-1998. Many of the same pollutant sources for 

PM10 are the same for PM2.5. 

Between 2006 and 2011, PM2.5 concentrations in Oakridge on worst winter days violated the 

more protective 24-hour national health standard adopted in 2006. There were no 

exceedances of the annual PM2.5 standard. EPA’s deadline for meeting the standards is 

December 2014. Emission reduction strategies included in this plan should provide compliance 

with the Clean Air Act Amendments even with a modest population growth. If the community 

fails to meet the standard by 2014, automatic contingency measures will be implemented and 

are clearly identified in this plan. 

What is in this Attainment Plan? 

Nonattainment Area 

The plan provides an analysis of the existing nonattainment area situation. It describes the past 

and the current state of air quality. It identifies and quantifies the current nature of the air 

quality problem. 

Attachment 3.3, page 16
November 15, 2012 – Final 

17

Attainment Demonstration 

The key component of the plan is in the attainment demonstration analysis where emissions 

are predicted into the future but strategies are identified to reduce emissions. There is also an 

explanation of the past and current economic situation and past and current meteorological 

situation. It predicts air quality into the future based on a growth analysis to show how much 

worse the air quality can become. It tells how the air quality can improve by implementing 

these various approaches or tactics to reduce emissions enough to meet the standards. Credit 

is given to each strategy or tactic and emission reductions are estimated into the future. It 

provides for a commitment by the community to return Oakridge to attainment status and 

explains and quantifies those commitments. The commitment shows how to improve air 

quality by using these strategies and promises to watch for changes to assure the commitment 

is met. If the commitment is not met, it identifies what future additional strategies will be 

necessary to implement immediately, should the initial commitments fail to meet the standard 

by 2014. 

The following strategies are in place and critical for meeting the PM2.5 air quality health 

standards by 2014: 

• Woodstove change-out programs. A model is in place to replace non-certified 

woodstoves with heat pumps, pellet stoves, or high-efficiency certified woodstoves. 

The current funding has been committed, and the most recent phase of this 

program was completed during December 2011. 

• Continue woodstove-fireplace curtailment program (green-yellow-red advisories, 

with curtailment required during air stagnation pollution episodes); the city 

ordinance requires curtailment on red days; LRAPA provides the daily air quality and 

meteorological forecasts during November-February. 

• Continue program prohibiting backyard/open burning: Burning of garbage is 

prohibited at all times; city ordinance prohibits open burning of yard debris during 

November-February; LRAPA provides daily open burning advisory during March-May 

and October; and open burning is prohibited in June-September during the fire 

season established by fire departments. 

• Maintain the Special Protection Zone for Oakridge as required in the ODF smoke 

Management Plan. 

• Continue outdoor recreational fire (chimineas and other patio heaters) program; 

LRAPA rules prohibit outdoor recreational fires on yellow-red advisory days during 

November-February. 

• Continue Oregon Heat Smart program; requires removal of non-certified 

woodstoves upon home sale, and prohibits burning of garbage in woodstoves and 

fireplaces. 

• Prohibit the use of uncertified woodstoves 

The plan proposes strengthening existing strategies and introduces new strategies to be 

implemented in the community. The plan demonstrates that new and continued permanent 

and voluntary strategies are sufficient to meet the PM2.5 standards by 2014 and the community 

will continue to meet the standard into the future. 

Attachment 3.3, page 17
November 15, 2012 – Final 

18

The primary source of PM2.5 in Oakridge is residential wood heating. The most serious PM2.5

problems occur during the winter in the urban area of Oakridge, when cooler temperatures 

trap particles near the ground by atmospheric inversions. Monitoring data clearly shows the 

high particulate levels occurring during the nighttime periods with light winds and strong 

temperature inversion. The levels drop significantly after sunrise. These diurnal high and low 

concentration periods also correspond to the general use of woodstoves as home heating 

devices. The emissions are greatest during the evening and nighttime periods. 

Implementation 

The plan describes final commitments by Oregon and the Oakridge community to make the 

plan work. It outlines the commitment for LRAPA to work with the local community to find 

solutions to the air quality problem. 

Attainment Plan Development Process 

LRAPA used the 2008 PM2.5 emission inventory and the feedback of the Oakridge Advisory 

Committee, the Lane Council of Governments (LCOG), and the Oregon Department of 

Transportation (ODOT) to develop the PM2.5 attainment plan. The Advisory Committee 

prepared a list of strategies that was submitted to LRAPA for inclusion in the plan. 

Additional strategies recommended by the committee are included in the Attainment Plan and 

Demonstration section of this document. The LRAPA Advisory Committee and the Oregon 

Department of Transportation also reviewed and made recommendations on the plan. 

Attachment 3.3, page 18
November 15, 2012 – Final 

19

NONATTAINMENT AREA 

Since the 1990s, Oakridge has undertaken many efforts to manage or control particulate 

emissions. For example, efforts have been made on several occasions to improve air quality by

implementing very stringent controls such as a clean air ordinance to regulate both burning in 

woodstoves and open burning. Due to the success of these programs to address PM10

emissions, when EPA revised the PM standard in 1997 to include PM2.5, Oakridge was in 

compliance. Despite these aggressive efforts, in 2006 when the PM2.5 standard was revised 

Oakridge found itself in violation of the 24-hour PM2.5 standard. 

Ambient Air Quality Monitoring in Oakridge 

The Oakridge area has one particulate (PM2.5) monitoring site with the sampler located at 

47674 School Street, also known as the Willamette Activity Center. LRAPA has monitored at 

the Willamette Activity Center site since 1987 for PM10 and since 1998 for PM2.5. After rigorous 

quality assurance, the data from the Willamette Activity Center site is transferred to ODEQ and 

on to EPA’s database. The data from the Willamette Activity Center monitor was used as the 

basis for the nonattainment determination and for determining compliance with the standard. 

Image 1: Smoke inversion over Oakridge, where the Willamette Activity Center is located. The particulate matter 

trapped near the surface by a temperature inversion is clearly visible. 

Attachment 3.3, page 19
November 15, 2012 – Final 

20

National Ambient Air Quality Standards (NAAQS) 

As mentioned previously, in 2006 the EPA revised the PM2.5 standard to more accurately reflect 

the latest health information. EPA revised the 24-hour standard from 65 μg/m3 to 35 μg/m3, 

and kept the annual standard at 15.0 μg/m3. EPA determines compliance with the PM2.5 

standards based on averaging air quality measurements both annually and on a 24-hour basis. 

Annual PM2.5 standard 

The annual standard for PM2.5 is met whenever the three year average of the annual mean 

PM2.5 concentrations for a designated monitor is less than or equal to 15.0 μg/m3. Oakridge has 

met this standard since monitoring started at Willamette Activity Center (Figure 5). 

Figure 5: PM2.5 Annual Standard comparison concentrations from the Oakridge monitor. 

24-hour PM2.5 standard 

The 24-hour standard for PM2.5 is met whenever the three year average of the annual 98th

percentile of values at a monitoring site is less than or equal to 35 μg/m3. The 98th percentile is 

a concentration below which 98% of observations fall. This value is used for the 24-hour 

standard instead of the maximum observation for any given year. By doing so, EPA ensures 

infrequent peaks are ignored and a more robust value is used for comparison. 

From 2001 through 2005, Oakridge was in compliance with the PM2.5 standard of 65 μg/m3. 

However in 2006, when EPA revised the standard to 35 μg/m3, Oakridge violated the 24-hour 

standard. The three year average 98th percentile for the Oakridge monitoring site has 

continued to violate the 24-hour standard each year since the standard tightened in 2006, but 

has decreased significantly over the period 2006 - 2011.

13.2 13.7 13.4 12.8 12.4 12.0 11.5 11.0 11.0 10.5

8.9

0

2

4

6

8

10

12

14

16

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

μg/m3

Oakridge PM2.5: 3-year Average of Annual Means

Willamette Activity Center Annual PM2.5 Standard

Attachment 3.3, page 20
November 15, 2012 – Final 

21

Figure 6: PM2.5 24-hour Standard comparison concentrations from the Oakridge monitor. 

Additional Monitoring 

In addition to the Oakridge Federal Reference Method (FRM) monitor, between October 2009 

and March 2010, investigative monitoring was done in the Westfir area to determine PM2.5

concentrations there, and relative difference from the Willamette Activity Center monitor. 

Several saturation samplers and a Nephelometer were used for this purpose. Figure 7 shows 

the relative PM2.5 concentrations, as a function of Nephelometer light scattering, of Westfir and 

Oakridge. More information regarding the methods and results of this monitoring is available 

in Appendix A.1. 

56.2 55.6 56.1 51.6 52.6 47.7 46.6

40.0 40.9 37.7 38.8

0

10

20

30

40

50

60

70

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

μg/m3

Oakridge PM2.5 : 3-year Average of Annual 98th Percentile

Willamette Activity Center 24-Hour Standard

Attachment 3.3, page 21
November 15, 2012 – Final 

22

Figure 7: Nephelometer estimated PM2.5 for Oakridge and Westfir during winter 2009-2010.

Verification of Monitoring Location 

LRAPA has conducted a field study to verify that the Willamette Activity Center PM2.5

monitoring site generally represents peak level PM2.5 concentrations within Oakridge, and is the 

most appropriate location for a PM2.5 monitor. The one year, six site monitoring survey was 

conducted in 2002-2003, and is attached in Appendix A. Results are summarized in Figure 8 

and Table 2. 

Figure 8: 2002-2003 Oakridge Monitoring Survey Site Map 

Attachment 3.3, page 22
November 15, 2012 – Final 

23

n

(max 

103)

Capture 

rate

Annual 

mean

μg/m3

Maximum 

value 

μg/m3

n > 15 

μg/m3

Difference 

from 

primary 

(MV401)

(%)

WAC FRM 100 96% 12.8 56.8 28 -

MV401 (primary) 99 95% 13.6 58.1 29 -

MV402 (duplicate) 96 92% 13.5 57.1 28 -

MV403 95 91% 10.9 53.3 18 -19.9

MV404 100 96% 11.4 41.0 23 -16.2

MV405 94 90% 8.3 42.3 8 -39.0

MV406 96 92% 8.6 36.7 14 -36.8

MV407 98 94% 13.0 47.6 26 -4.4

Table 2: 2002-2003 Oakridge Monitoring Survey Results 

Findings of this survey agreed with those of PM10 saturation studies from 1991 and 1994. 

Within Oakridge the highest levels were found in the southwestern portion of the town. 

Therefore, it was confirmed that this site represents peak levels of PM2.5 concentrations in 

Oakridge. In addition, the Willamette Activity Center monitor also represents an area where 

people live, work, and play, reconfirming the monitor location is the most appropriate for 

Oakridge. 

Attachment 3.3, page 23
November 15, 2012 – Final 

24

ATTAINMENT PLAN AND DEMONSTRATION 

Emission Inventory 

An emission inventory consists of emission estimates from sources that emit PM2.5 within the 

Oakridge nonattainment area boundary. The emissions inventory data is essential in 

developing the attainment demonstration, as it helps identify the sources contributing to the 

air quality problem and the emission reduction strategies, once implemented, that reduce 

pollution levels below the standard. Sources of PM2.5 in Oakridge include minor industry, onroad mobile sources (e.g., car and truck exhaust, road dust), railroads, and area sources (e.g., 

outdoor burning, woodstoves, and fireplaces). 

Base Year Emission Inventory (2008) 

The base year emission inventory is used as the starting point for the attainment 

demonstration. This inventory includes sources in the nonattainment area during the 2008 

baseline year. 

The 2008 emission inventory is summarized in Table 3 and Figure 9. The calculation procedures 

are included in Appendix D. 

-- lbs/per day -- Percent of Total NAA Emissions

Typical Season Day Worst-Case Day Typical Season Day Worst-Case Day

Permitted Point Sources(1)

Oakridge Sand & Gravel: Rock crushing operation 0.4 0.8 0.1% 0.1%

Oakridge Sand & Gravel: Cement plant 0.1 0.1 0.0% 0.0%

Stationary Area Sources

Residential Wood Combustion: Fireplace(2) 38.5 42.3 7% 8%

Residential Wood Combustion: Non-Certified 

Woodstove/Insert(2) 158.9 174.8 30% 32%

Residential Wood Combustion: Certified 

Woodstove/Insert(2) 228.0 250.8 43% 45%

Pellet Stoves 6.7 7.4 1% 1%

All Other Stationary Area Sources 47.4 4.7 9% 1%

On-Road Sources

On-Road: Exhaust, Brake, Tire 26.6 37.3 5% 7%

Re-Entrained Road Dust 12.1 27.8 2% 5%

Nonroad Sources

Union Pacific Railroad 6.0 6.0 1% 1%

Total, All Sources, lbs/day 525 552

(1) Worst-case day = Peak month production/20 workdays. 

(2) Worst-case day = Peak Heating Degree Day

Table 3: 2008 Estimated Typical Season Day and Worst-Case Day PM2.5 Emissions.

The emissions inventory on worst winter days is of most interest since the PM2.5 concentrations 

measured in Oakridge do not meet the current 24-hour PM2.5 standard and the peak PM2.5

concentrations occur on cold, stagnant days during the November-February wood-heating 

season. Residential wood-heating emissions (from certified and non-certified woodstoves, 

fireplaces, and pellet stoves) account for about 86% of the emissions on worst winter days, as 

illustrated in Figure 9. 

Attachment 3.3, page 24
November 15, 2012 – Final 

25

Figure 9: Oakridge PM2.5 Emission Inventory for 2008 Worst Winter Days 

Residential Wood Combustion 

Residential wood combustion is a common way to heat homes in Oregon. To estimate 

emissions from wood burning, LRAPA conducted a survey for the 2009-2010 heating season in 

Oakridge-Westfir. The survey provided LRAPA with information on how many homes use 

various types of wood-heating devices, the amount of wood burned, and other information on 

wood-heating practices. 

Mobile and Nonroad Sources 

Road dust and tailpipe emissions of PM2.5 from motor vehicles were calculated by Lane Council 

of Governments (LCOG) transportation staff by applying emission factors from the EPA MOVES 

computer program to total vehicle miles traveled in the nonattainment area. Estimated vehicle 

miles traveled are from previous transportation modeling by LCOG for the Oregon Department 

of Transportation. Emissions from railroads were provided by Union Pacific Railroad staff using 

the EPA NONROAD2008a emissions protocol. 

Industrial Point Sources 

LRAPA maintains data on industrial point source emissions in Lane County. The only operating 

industrial point sources within Oakridge-Westfir area are two minor aggregate industry sources 

operated by Oakridge Sand & Gravel. 

Industry

0.2%

Open Fireplaces

7.7%

Non-Certified 

Woodstoves

31.7%

Certified 

Woodstoves

45.4%

Pellet 

Stoves

1.3%

Other Area 

Sources

0.9%

On-Road Cars & 

Trucks

6.8%

Re-entrained 

Road Dust

5.0%

Railroads

1.1%

Oakridge PM2.5 Emission Inventory for 

2008 Worst Winter Days

Attachment 3.3, page 25
November 15, 2012 – Final 

26

Attainment Year Emission Inventory (2014) 

The attainment year inventory is an estimation of emissions for the year that the area is 

expected to have attained the PM2.5 standard. It includes projected emissions for the 

attainment year based on a number of different factors. Growth rates for population, 

employment, and VMT through 2014 were used to estimate 2014 emissions. LRAPA took credit 

for emissions reductions as a result of the woodstove replacement project implemented during 

2009-2012 that reduced the number of non-certified woodstoves accounted for in the 2008 

emission inventory. 

The attainment year emission inventory is based on 2008 emissions inventory, estimated 

growth rates and the emission reduction strategies that have recently been put into effect. The 

emission reduction strategies primarily include the continued implementation (with specific 

strengthening revisions in some cases) of the existing control measures that have been 

effective in achieving the PM10 standards and the initial (1997) PM2.5 standards on schedule. 

The key ongoing control strategies, which were in place prior to 2008, include: 

• City ordinance to curtail burning during stagnant weather periods; 

• City ordinance requiring the removal of a non-certified wood stoves upon sale of a 

home; 

• City ordinance prohibiting the use of a non-certified wood stove in a residence; and 

• Partnering in additional change-out programs to encourage removal of non-certified 

woodstoves. 

Details of the ongoing control strategies, strengthened control strategies, and contingency 

measures are described in the subsequent section on the Oakridge Advisory Committee 

recommendations. 

Economic Factors 

The economy in Oakridge has shifted from logging-based industries to a more recreationoriented model. The decline in the harvesting and processing of timber has left Oakridge with 

no industrial employer or businesses that support the lumber industry. In the 1990’s, the 

population in Oakridge declined sharply as jobs disappeared. Current census figures show only 

modest growth of 1.8% between 2000 and 2010, with the current population at 3,205. Within 

the civilian labor force, 16% were unemployed in 2010 and 21.7% of all families had incomes 

below the poverty level. The low cost of living has attracted low-income and unemployed 

people to Oakridge. 

The recreation industry has picked up in Oakridge, with mountain biking being very popular. A 

hostel, brew pub, and other small businesses have opened to support the visitors attracted to 

the area. Despite the recent business growth, few jobs have been created. Population and 

employment in Oakridge are expected to increase only modestly over the next 20 years. The 

population estimate for the year 2025 is 4,000. Any new employment has been assigned to the 

potential development of the Oakridge Industrial Park. 

Attachment 3.3, page 26
November 15, 2012 – Final 

27

Growth Rates 

Growth is expected to be low to moderate in the Oakridge-Westfir area through 2014. 

Population, housing, and employment forecasts are expected to increase gradually. VMT 

growth is based on the previous transportation modeling by LCOG in the Highway 58 corridor. 

The 2014 emission inventory is summarized in Table 4. The calculation procedures are included 

in Appendix D. 

Percent of Total

-- lbs/per day -- NAA Emissions

Typical Season 

Day

Worst-Case 

Day

Typical Season 

Day

Worst-Case 

Day

Permitted Point Sources(1)

Oakridge Sand & Gravel: Rock crushing operation 1.7 4.0 0.4% 1.1%

Oakridge Sand & Gravel: Cement plant 4.3 14.0 0.9% 3.7%

Stationary Area Sources

Residential Wood Combustion: Fireplace(2) 38.5 29.6 8% 8%

Residential Wood Combustion: Non-Certified Woodstove/Insert(2) 106.1 81.7 22% 21%

Residential Wood Combustion: Certified Woodstove/Insert(2) 252.4 194.4 52% 51%

Pellet Stoves 7.3 8.0 1% 2%

All Other Stationary Area Sources 47.4 4.7 10% 1%

On-Road Sources

On-Road: Exhaust, Brake, Tire 15.7 22.2 3% 6%

Re-Entrained Road Dust 7.1 16.3 1% 4%

Nonroad Sources

Union Pacific Railroad 6.0 6.0 1% 2%

Total, All Sources, lbs/day 486 381

(1) Worst-case day = Permitted hourly (x24) operating capacity 

(2) Worst-case day = Peak Heating Degree Day

Table 4: 2014 Estimated Typical Season Day and Worst-Case Day PM2.5 Emissions. 

Comparison of 2008 to 2014 Emissions 

The emission inventory shows an overall decrease in emissions for the attainment year (2014) 

based on the effectiveness of the emission control strategies. 

The differences in the 2008 and 2014 emission inventories are the combination of increases 

due growth factors and decreases due to emission control strategies. For example, motor 

vehicle emissions decreased overall due to progressively cleaner gasoline and diesel fuels and 

motor vehicles, but part of the emissions decrease was offset by gradual growth in traffic 

volumes. Industry emissions were conservatively increased to reflect operation at maximum 

capacity in 2014, but both industrial sources are minor so this did not have a major effect on 

the 2014 inventory. The most significant category is residential wood-heating; emissions were 

increased to reflect population growth during 2008-2014, decreased due to non-certified 

woodstove replacements with cleaner burning units during 2009-2012, and decreased due to 

improvements in the programs for curtailment during stagnant air episodes. 

Attainment Strategies – Emission Reduction Analysis 

This section describes strategies currently in place or those to be implemented to achieve 

compliance with the 24 hour PM2.5 standard. These strategies are expected to improve air 

quality and meet the PM2.5 standard by the required 2014 attainment date. These strategies 

Attachment 3.3, page 27
November 15, 2012 – Final 

28

are also known as Reasonably Available Control Measures (RACM). For large industrial 

emission sources they are called Reasonably Available Control Technologies (RACT) but 

currently there are not any large industrial facilities located in the Oakridge-Westfir area. For 

the Oakridge nonattainment area, the main source of emissions is wood smoke from residential 

wood combustion, and RACM is applicable to this emission category. The current and proposed 

emission control strategies are consistent with the RACM requirements for residential wood 

combustion (EPA-450/2-89-015). 

The RACT / RACM analysis took into account direct PM2.5 and the precursors NOx and SO2 as 

required by the 2007 implementation rule. Preliminary analysis of the airshed found very little 

contribution of local sources to secondary sulfate and nitrate relative to direct PM2.5. Since the 

total local emissions of NOx and SO2 are not a major factor in ambient PM2.5 at the violating 

monitor, it was a reasonable hypothesis that small changes in that total NOx and SO2 emission 

budget would be a very minor factor in PM2.5 in Oakridge relative to primary PM2.5 emissions. 

Thus the attainment model was simplified to not take attainment credit for emission changes in 

PM2.5 nitrate and sulfate precursors. LRAPA is confident that direct PM2.5 is the cause of (and 

solution to) PM2.5 nonattainment and that there is little opportunity for reducing PM2.5 

through emission reductions of NOx and SO2. 

Particulate Matter Reduction Strategies (1989 -2008) 

The strategies and regulations implemented between 1989 and 2008 resulted in a reduction of 

PM2.5 emissions. Projections show implementing and strengthening ongoing strategies will 

make it possible for the Oakridge area to achieve the standard by 2014. Future strategies are a 

continuum of past strategies developed over the years that have been adjusted and updated to 

address the current PM2.5 standard. Local efforts include revisions to the existing Oakridge 

clean air ordinance, public education, and woodstove change-outs. State and federal 

regulations recently implemented affect woodstoves and transportation emissions. 

These strategies are permanent and enforceable; they are currently implemented and enacted 

by city ordinance, state, or federal rules. There are penalties for violating these ordinances or 

rules. 

The Oakridge Air Pollution Control Ordinance #889

LRAPA and the City of Oakridge initiated a voluntary home wood heating advisory program in 

1989 after air quality data showed Oakridge exceeded the federal PM10 standard on numerous 

occasions. Five years later, on January 20, 1994, EPA officially declared Oakridge a PM10 nonattainment area. In August of 1996, the City of Oakridge adopted a wood heating curtailment 

program. A plan to get the area back into attainment with the standards was adopted by EPA in 

March 1999, and became effective on May 14th of that year. The Oakridge plan included 

voluntary measures. 

On February 20, 2003, the Oakridge City Council revised the home wood heating ordinance 

that: 

• Changed their voluntary curtailment measures to mandatory, 

Attachment 3.3, page 28
November 15, 2012 – Final 

29

• Prohibited burning garbage in woodstoves and fireplaces, 

• Incorporated a 40% opacity limit on chimneys, 

• Incorporated the PM2.5 standard into the program, and 

• Required the removal of uncertified woodstoves from property to be sold or rented. 

In fall 2007, the City of Oakridge revised its home wood heating ordinance to reflect the 

tightened PM 2.5 standard of 35 μg/m3. The revision changed the concentration levels that 

trigger the green/yellow/red advisories. A revision to the ordinance in December 2008 

included a provision that stated a person or persons may not install or use any solid fuel heating 

device in any structure within the City except for certified wood stoves or certified pellet stoves 

with emissions that do not exceed 1.0 grams/hour weighted average tested in conformance 

with the EPA method, or a fireplace that is not a sole source of heat. 

LRAPA Advisory Programs 

Since initiated in 1989, the LRAPA advisory program has provided a daily wood burning advisory 

for Oakridge. The program is operated by LRAPA in cooperation with the City of Oakridge and 

local news media. The advisory, issued daily by LRAPA staff during the months of November 

through February, is determined by comparing current pollution levels to meteorological 

conditions and weather forecasts. The advisories are displayed daily on the LRAPA website and 

can be obtained via telephone at a dedicated hotline number. Advisories are broadcast on 

radio and television and daily in the regional newspaper. An automatic phone “callware” 

system is activated when air quality is deteriorating and long periods of stagnant conditions are 

forecast. The phone system calls all numbers with the 782 prefix in the Oakridge/Westfir area 

and leaves a recorded message. 

(a) The advisory operates using a "green-yellow-red" system as described in the 

Oakridge City ordinance. A "green" advisory is issued when PM2.5 levels are 

forecast by LRAPA to be less than 25 g/m3

, and good smoke dispersion 

conditions are forecast. "Yellow" advisories are posted when PM2.5 levels are 

forecast by LRAPA to be equal to or greater than 25 g/m3, but less than 30 

g/m3, and the forecast is for marginal smoke dispersion conditions. Under this 

advisory, residents are advised to burn wood sparingly, and only if alternatives 

are unavailable. A "Red" advisory is posted when PM2.5 levels are forecast to be 

equal to or greater than 30 g/m3, and the forecast is for marginal or poor 

smoke dispersion conditions. During a Red advisory, no person in charge of a 

property shall operate or allow to be operated a solid fuel heating device which 

emits visible emissions unless the person has been granted an exemption by the 

Oakridge City Administrator. Residents with exemptions may use any solid fuel 

heating device. Exemptions are based on sole source of heat or economic need. 

During Stage II Red II advisory, when PM2.5 levels are forecast to be equal to or 

greater than 35 micrograms per cubic meter no person in charge of property 

shall operate or allow to be operated a solid fuel burning device unless: the 

person has been granted an exemption to use the device by the City 

Attachment 3.3, page 29
November 15, 2012 – Final 

30

Administrator; or the person is operating a pellet stove which emits no visible 

emissions into the air outside of the building housing the device. 

Open Burning Ordinance 

On March 19, 1992, the Oakridge City Council amended its open burning ordinance #689 to 

allow open backyard burning only during the months of October, March, April, and May and 

bans the use of burn barrels. Oakridge City Code 92.04.A.2 currently regulates open backyard 

burning inside the Oakridge city limits. This eliminates burning during wintertime periods of 

maximum atmospheric stagnation when burning is more likely to contribute to exceedances of 

the 24-hour PM2.5 standard. The open burning restrictions provide a more protective measure 

to avoid additional contributions to the particulate levels. 

Woodstove Change-out Programs 

Since 1993, LRAPA has administered woodstove change-out programs to help residents replace 

old, uncertified wood stoves with cleaner burning, more efficient heating systems. This control 

measure is central to achieving attainment, and will enhance both long- and short-term 

compliance. The first program conducted in 1993 provided economic incentives for residents 

to replace old, high polluting woodstoves with alternative heating systems with lower emission 

rates. These include electric furnaces and heat pumps, oil, gas, pellet stoves, or EPA certified 

low-emission woodstoves. 

The initial program was funded by the U.S. EPA, together with support from the Oregon 

Department of Environmental Quality and LRAPA. The program provided up to $2,500.00 per 

low- or moderate- income household for installation of approved alternative heat sources, 

either as no-interest loans or outright grants. Participants were required to certify, in writing, 

that they disposed of their old stoves, and would not utilize non-approved alternatives in the 

future. A total of 130 stoves were replaced. 

In 2005, LRAPA developed the Warm Homes, Clean Air Program for Oakridge. The program is 

ongoing as funding becomes available. Warm Homes matches Oakridge and Westfir residents 

with funding from nine partner agencies to help with heating upgrades, weatherization, and 

home repairs. As part of the program, LRAPA has provided funding for woodstove 

replacements. During a change-out conducted between 2006 and 2008, 59 uncertified 

woodstoves were replaced. Table 5 shows a historical view of the Oakridge Wood Stove 

Change-outs. 

Oakridge Wood Stove Change-out Programs

Years 1993-96 2006-07

# of Stoves 130 59

Table 5: Oakridge Wood Change-out Programs (1993-96/2006-07)

Statewide Certification of Woodstoves 

In 1986, the Oregon Legislature required the certification of any woodstove sold in Oregon. 

This requirement was subsequently adopted by EPA on a national basis in 1990. Additionally, 

Attachment 3.3, page 30
November 15, 2012 – Final 

31

the State Building Code Agency prohibits the installation of uncertified woodstoves. The dual 

effect of this certification and installation requirement resulted in reducing the amount of 

wood smoke pollution that used to be emitted from the uncertified stoves. 

Highway Road Sanding 

In an effort to reduce PM10 emissions from road sanding during winter months, the Oregon 

Department of Transportation (ODOT) signed a letter of agreement regarding using anti-icing 

agents as an alternative to sand on Highway 58 running through Oakridge. The use of the 

chemical de-icing compound, calcium magnesium acetate, inhibits ice formation. The practice 

has resulted in a significant reduction of particulate, however it is not likely to contribute to 

PM2.5 reductions. 

Smoke Management 

By statute, the Oregon Department of Forestry (ODF) is responsible for administering a smoke 

management program. Smoke from prescribed burning has not significantly impacted the 

nonattainment area in the past, however, there have been safeguards implemented to prevent 

unintended smoke impacts to the Oakridge nonattainment area. Oakridge is protected under 

the Oregon Smoke Management Plan as a smoke sensitive area. This means that all prescribed 

burning during the year is managed in such a way as to avoid any smoke intrusions into the 

community. 

In addition, a Special Protective Zone (SPZ) surrounds Oakridge where additional restrictions 

apply to prescribed burning within the zone during the winter months (November 15 through 

February 15). During this time, prescribed burning is allowed only when the ODF smoke 

management meteorologist determines there would be no measurable smoke within the 

nonattainment area. Between December 1 and February 15, no prescribed burning is allowed 

in the SPZ on “red” woodstove days. Between November 15 and February 15, no pile burning is

allowed if ODF believes that the piles will produce significant smoke after the third day. 

Road Paving 

According to the emissions inventory done prior to 1991, there were about 2.4 miles of 

unpaved streets in Oakridge. Since then, based on city records, virtually all unpaved roads have 

been paved, along with numerous unpaved commercial driveways and parking lots. 

Industrial Requirements 

Within the designated Oakridge PM2.5 nonattainment area, new major sources and major 

modifications of a nonattainment pollutant, including PM2.5 precursors SO2 or NOX, are required 

to meet LAER control technology. Industrial sources must also obtain emission offsets and 

demonstrate that a net air quality benefit will be achieved. These are the most stringent 

requirements for industry. In addition, existing sources will be evaluated for RACT and will be 

required to meet performance standards for certain industry. 

Public Education 

LRAPA has maintained a strong presence on the Oakridge community through public education 

programs aimed to inform residents and teach school age children about air quality issues. In 

2006, LRAPA developed a school flag project for Oakridge Elementary School. LRAPA provides 

Attachment 3.3, page 31
November 15, 2012 – Final 

32

air quality flags that are hung at the entrance to the school, which is located on a main street 

near downtown Oakridge. The highly visible flags display the current Air Quality Index (AQI) 

reading for that day. Information on air quality is obtained by students from the LRAPA website. 

The flags have also been used during periods of bad air quality caused by wildfires. A specialized 

curriculum was developed by LRAPA public affairs staff for third –fifth grade students. An 

LRAPA staff person makes an annual visit to the school in the fall to teach a class on air quality 

and explain how to use the flags. 

For over ten years, LRAPA has taught an air quality class at outdoor school, held each May in 

Oakridge. The class focuses on the science of air pollution and the specific challenges of wood 

smoke pollution in Oakridge. An average of 75 sixth grade students attends the class each year. 

Additional Strategies 

Beginning in the early 90’s, LRAPA developed various strategies to reduce and track wood 

smoke emissions. LRAPA provided plastic tarps to residents for covering wood piles to keep 

wood dry. A seasonal worker, hired by LRAPA, conducts drive-by compliance surveys on green, 

yellow, and red days using pre-established survey routes. Surveys are turned in monthly 

November- February. 

Current Strategies 2009-2011 

Wood Stove Change-out program 

The Warm Homes wood stove change-out program continued in 2009. Funding from U.S. EPA 

helped replace 11 uncertified wood stoves with new heating devices. In October 2010, LRAPA 

received funds from the American Recovery and Reinvestment Act. LRAPA used the funding to 

conduct another round of wood stove change-outs in Oakridge and Westfir. The program 

offered two-tier funding for qualified residents within the non-attainment boundary designated 

by U.S. EPA. Residents who qualified as low income based on Housing and Urban 

Development’s (HUD) income guidelines received a full rebate of up to $5,000 to pay for a 

ductless heat pump, certified wood stove or pellet stove. All other qualified applicants received 

a rebate of up to $2,000 based on emission reductions. The program ended in December 2011. 

LRAPA provided rebates to replace 79 stoves. Wood heat was most popular; 56 new wood 

stoves were installed, 10 pellet stoves, and 13 electric ductless systems. 

Oakridge Wood Stove Change-out Programs

Years 2009 2010-11

# of Stoves 11 79

Table 6: Oakridge Wood Change-out Programs (2009/2010-11)

Heat Smart: Stove Removal upon Sale of Home 

In 2010, a statewide requirement mandating the removal of an uncertified stove at the time of 

home sale went into effect. This statewide rule closely mirrored the existing requirement in the 

Oakridge ordinance. Under the rule, all uncertified devices that are on the property being sold 

(including residences, shops, garages, and outbuildings) must be removed at the time of home 

Attachment 3.3, page 32
November 15, 2012 – Final 

33

sale. The Oregon Heat Smart law requires DEQ to confirm residences where owners removed 

or changed-out uncertified woodstoves upon home sale. DEQ currently administers the Heat 

Smart program and tracks submittals of all uncertified removals at the time of home sale. 

These submittals can be used to estimate the level of compliance in Oakridge and identify any 

need for additional education or follow-up. DEQ has established in rules, penalties for 

noncompliance and hopes to conduct periodic enforcement sweeps throughout the state. 

Public Education 

As mentioned earlier in this section, LRAPA has maintained a vigorous public education 

program in Oakridge. In 2009 -2011, the program was expanded to reach a wider audience. In 

2010, LRAPA produced a television commercial to promote compliance with home wood 

heating advisories and clean burning practices. The commercial has run every fall on three 

major television networks; all are available to Oakridge viewers. Radio ads targeting open 

burning and home wood heating have aired on a network of radio stations in Lane County since 

2009. Almost stations all are available in Oakridge. 

Articles in the weekly newspaper, the Dead Mountain Echo, serving the Oakridge area have 

been submitted by LRAPA staff periodically to keep the public informed about poor air quality, 

LRAPA programs, and other topics related to wood smoke. Display advertisements and fliers 

inserted into the paper are also used to promote high profile projects, the Warm Homes 

program being an example. 

Transportation and Fuel-Related Emissions 

Federal, state and local transportation regulations and programs recently implemented will 

reduce mobile and non-road emissions. These include: 

Federal regulations requiring: 

 Reduced sulfur content of gasoline and diesel 

 Increased fuel economy 

Oregon regulations requiring: 

 Low emissions vehicles beginning with model year 2009 and newer 

 Renewable fuel standard for biodiesel – 5%

Local programs: 

 Implementing diesel retrofits of school buses 

The Transportation Conformity Analysis is included in Appendix K. The Motor Vehicle 

Emissions Budgets are: 

 On-Road Worst Case Day PM2.5 Emissions of 38.5 pounds per day (22.2 pounds per day of 

exhaust, brake and tire wear, and 16.3 pounds per day of re-entrained road dust); and

 On-Road Worst Case Day NOx Emissions of 562.3 pounds per day.

Attachment 3.3, page 33
November 15, 2012 – Final 

34

Strengthened Ongoing Strategies in 2012-2014 

While the current strategies in place indicate Oakridge will reach attainment with the PM2.5

standard by 2014, to ensure compliance, a number of future strategies were identified by a 

local advisory committee. The advisory committee evaluated options for how to improve air 

quality in Oakridge and suggested potential control measures. With the help of the committee, 

LRAPA developed a list of strategies to ensure Oakridge meets the 2014 attainment date. 

Oakridge Air Quality Advisory Committee Strategy Recommendations 

In July 2011, LRAPA formed an advisory committee in Oakridge to discuss current air quality 

strategies and explore the feasibility of a number of new strategies identified that would reduce 

PM2.5 emissions. They also discussed contingency strategies should Oakridge fail to meet the 

standard by 2014. While the strategies in place (e.g., City ordinance, LRAPA’s advisory 

programs, federal and state regulations) indicated the area would meet the standard by 2014, 

the committee suggested strengthening the strategies to provide a cushion to ensure 

attainment by 2014. The following strategies are included as part of this plan. 

Woodstove Change-outs 

Due to the effectiveness of this strategy in the past, LRAPA will continue to pursue funds to 

continue offering woodstove change outs within the nonattainment area. Implementation of 

this strategy may provide substantial reductions in PM2.5 in the future. LRAPA is not applying 

any emission credit for this strategy to the 2014 inventory, as it is dependent upon the 

acquisition of funding which affects the number of stoves replaced. In the most recent round 

of wood stove change-outs, 75% of the participants qualified as low-income. The poor 

economy in Oakridge makes it essential any future change-out incentives include grants to 

cover all of the cost of replacement for low income individuals and substantial (at least 50%) 

incentives to residents who are not “low income”. 

Enforcement of Oakridge Ordinance 

Oakridge Ordinance #889 allows the City to impose a penalty not greater than $500.00 upon 

anyone who violates City Code related to the use of a solid fuel heating device. Each day’s 

violation will incur additional fines. At this time, the City of Oakridge has enforcement 

authority of the ordinance. LRAPA is working with the Oakridge Police Department to 

strengthen enforcement on Red advisory days. LRAPA has provided a series of door hangers 

that can be left at a residence with an excessively smoky chimney. The door hangers include 

language from the City Ordinance, including potential fines for a violation. 

Enhancements to Key Ongoing Strategies 

The Oakridge Advisory Committee identified several strategy enhancements that were felt to 

be key to the success of the ongoing strategies. Most of these strategies can be implemented 

without additional resources. 

• Expanded education and outreach, including multiple versions of educational doorhangers that can be distributed to all homes in Oakridge. 

• Training and certification of police on smoke reading and opacity limits 

enforcement. 

Attachment 3.3, page 34
November 15, 2012 – Final 

35

• Enforcement with citations as appropriate for violations of curtailment during 

pollution episodes, excessive opacity (40%) requirements, operation of non-certified 

woodstoves, and burning of garbage. 

• Ongoing improvements in the air quality forecasting and green-yellow-red advisory 

programs to ensure that all problem stagnation days are addressed appropriately, 

which may increase the number of yellow or red days. 

• Alternatives to fines payment as appropriate (e.g., attend workshop on clean 

burning practices, replacement of non-certified woodstove with cleaner burning 

unit, etc.). 

• Use of fines to fund ongoing woodstove replacement program or other emission 

reduction strategies. 

Contingency Strategies 

The following strategies are recommended as contingency strategies to fully meet the air 

quality standards, if it becomes clear that the strengthened ongoing strategies described above 

will not be sufficient to attain the PM2.5 standards by 2014 and or to maintain compliance with 

the standards through 2024 and beyond: 

• Stricter opacity limit on all green or yellow advisory days, revising the current 40% 

opacity limit in the city ordinance to a more restrictive 20% limit, as has been done 

in some other northwest communities. A 20% opacity limit on green and yellow 

advisory days will help reduce emissions with the goal of avoiding red advisories 

when no visible emissions are allowed. 

• Stricter green-yellow-red advisory program, with more yellow and red advisory days 

each winter. 

• Further restrictions on city woodstove curtailment exemptions (for sole source, 

economic hardship). 

Industrial Emission Reductions 

Reasonably Available Control Technology. The two existing industrial sources in the OakridgeWestfir area are minor industrial sources of PM2.5 emissions. The facilities are a portable rock 

crusher and a ready-mix concrete plant owned and operated by Oakridge Sand & Gravel. 

These two minor sources together emit less than one ton per year of PM2.5 emissions and 

contribute less than 1% to the base year emission inventory. These two minor sources are well 

below the LRAPA significant emission rate (SER) for PM2.5 of 10 tons per year. 

The air pollution control technology installed on these sources are the standard for the industry 

and meet RACT requirements. The rock crusher has water-spray controls and the concrete plant 

has baghouse controls. 

Even the elimination of the emissions from these two sources would not significantly affect 

progress to meet the PM2.5 standard. For example, the worst-day PM2.5 concentrations need to 

be reduced by about one microgram per cubic meter (μg/m3) per year in order to meet the 

PM2.5 standard by 2014 (i.e., reduced from 39.5 μg/m3 in the 2006-2010 baseline period to 35 

Attachment 3.3, page 35
November 15, 2012 – Final 

36

μg/m3 by the 2014 attainment date). The modeled impact of these two sources if operated at 

maximum permitted production rates in 2014 is much less than one μg/m3, or much less than 

the annual progress required by 2014. Further, both of these sources consistently operate well 

below maximum production rates, especially during the winter months when PM2.5

concentrations are a problem. 

Estimated Reductions and Credits for Future Strategies 

The emission changes between 2008 and 2014 are due to the combination of increases due to 

growth factors and decreases due to emission control strategies. 

The most significant category is residential wood-heating; emissions were increased in the 2014 

inventory to reflect population growth during 2008-2014, decreased due to non-certified 

woodstove replacements with cleaner burning units during 2010-2012, and decreased due to 

2012-2013 improvements in the programs for curtailment during stagnant air episodes. The 

emission decrease due to woodstove replacements was based on the actual number of 

woodstove replacements documented after the 2008 baseline year. The emission decrease for 

the more effective woodstove curtailment program is conservatively estimated at a 30% 

emission reduction on worst winter days as a result of enforcement of the existing city 

ordinances during stagnant air episodes subsequent to the 2006-2010 baseline period; 

mandatory curtailment programs in Oregon have historically documented reductions of 50% or 

more. 

Traffic volumes are projected to gradually increase in future years but motor vehicle emissions 

are calculated to decrease overall due to progressively cleaner gasoline and diesel fuels and 

motor vehicles. Industry emissions were conservatively increased in the inventory to reflect 

operation at maximum capacity in 2014, but both industrial sources are minor so this did not 

have a major effect on the 2014 emission inventory. 

Attainment Demonstration 

The attainment demonstration shows how Oakridge will meet the PM2.5 standard by 2014 

through the implementation of control measures listed above. LRAPA used a “proportional 

rollback/rollforward analysis” or rollback model to conduct the analysis. The goal of this 

section is to demonstrate that future concentrations are less than the NAAQS at the Willamette 

Activity Center monitor and other unmonitored parts of the designated nonattainment area. 

Baseline Design Value 

The demonstration starts with estimating the baseline design value, or baseline concentration, 

for PM2.5. The baseline design value is a statistic, expressed as a concentration that describes 

the PM2.5 levels at the Willamette Activity Center monitor relative to the NAAQS. The 

procedure for its calculation is presented in Appendix N to 40 CFR 50, “Interpretation of the 

National Ambient Air Quality Standards for Particulate Matter” and “EPA Guidance on the Use 

of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for O3, PM2.5, 

and Regional Haze”. PM2.5 measurements from 2006 to 2010 are used to calculate the design 

Attachment 3.3, page 36
November 15, 2012 – Final 

37

value of 39.5 μg/m3 (see Table 7). Detailed methods on the baseline design value calculation 

are in Appendix G. 

Year PM2.5 (μg/m3)

2006 38.6

2007 42.7

2008 38.7

2009 41.3

2010 33.0

Baseline DV 39.5

Table 7: Annual PM2.5 values used to calculate baseline design value. 

Background on Precursors 

Speciated PM2.5 samples were collected at Willamette Activity Center for the period July 2009-

2011. The samples showed the dominance of organic and elemental carbon, with secondary 

inorganic aerosol nitrate and sulfate comprising relatively minor concentrations of total PM2.5. 

Concern had been expressed about the role of secondary organic aerosols (SOAs) as 

components of total organic carbon, and an additional analysis was conducted by a research 

scientist at Portland State University (PSU) in collaboration with ODEQ to better understand the 

magnitude of these aerosols in the Klamath Falls, Oregon air shed. The results of this analysis 

showed that the contributions from both biogenic and anthropogenic sources to be minor, less 

than 1% and 3%, respectively, of total design value PM2.5. In consultation with EPA, LRAPA 

chose to adopt these percent contributions as a conservative assumption for the Oakridge NAA 

demonstration. Because all secondary aerosols were determined to be minor contributors to 

total PM2.5, these components and their concentrations are held constant in the rollback model 

and assigned a Relative Response Factor (RRF) of 1.0, assuming future year precursor 

concentrations are constant or declining. The precursor emissions to secondary aerosols, 

including NOX, SO2, ammonia, and biogenic and anthropogenic VOCs, are not used in the 

attainment demonstration (LRAPA is utilizing a rollback analysis for the attainment 

demonstration). 

In addition to the study of secondary aerosols, a positive matrix factorization (PMF) study based 

on the speciated data from Willamette Activity Center was conducted by EPA Region 10 to 

identify likely sources of speciated PM2.5. The study showed the importance of residential 

woodsmoke to the high levels of organic carbon, an estimated 70-75% of total PM 

concentrations. 

The SANDWICH speciation formulation, based on adjusted and corrected Willamette Activity 

Center speciation data, is used to speciate the FRM measured design value (DV) for use in the 

rollback model. The SANDWICH is a profile of the DV with which to describe the components 

that contribute to PM2.5 exceedances. This profile is shown in Figure 10, and shows that over 

95% of total PM is from organic and elemental carbon with smaller amounts of secondary 

inorganic aerosols, such as sulfate (1%) and nitrate (0.4%). The SANDWICH analysis, and the 

Attachment 3.3, page 37
November 15, 2012 – Final 

38

PMF study are described in more detail in Appendix E.1 and Appendix E.2. Based on the 

evidence cited above, the major sources contributing to nonattainment in Oakridge are 

considered to be those that emit direct emissions of PM2.5. As a result, LRAPA has focused its 

strategies for the attainment demonstration on these sources. 

Figure 10: Speciated Components of PM2.5 (using SANDWICH analysis) 

Speciated Filter Sample Analysis 

PM2.5 is a mixture and can be divided into major components: mass associated with sulfates, 

nitrates, ammonium, organic carbon, elemental carbon, particle bound water, and other 

primary inorganic particulate matter. Percent contribution to the total mass by each of these 

major components is used to estimate relative contribution by different emission sources. 

From July 2009 to 2011, LRAPA conducted PM2.5 speciation monitoring at the Willamette 

Activity Center location. Total PM2.5 mass measurements using the FRM are used mainly to 

determine attainment or nonattainment of the standard. However, to provide information 

about particular source contribution to that total mass it was necessary to co-locate a 

speciation sampler that allows the breakdown of the total mass into different chemical species. 

The total mass of PM2.5 using the FRM sampler is not equal to the simple sum of the measured 

components from the speciation filter, therefore it is necessary to make adjustments to 

1%

0.4%

88%

8%

0.03%

3%

Oakridge PM2.5 Composition

Sulfate

Nitrate

Organic Carbon

Elemental Carbon

Ammonium

Other

Attachment 3.3, page 38
November 15, 2012 – Final 

39

represent FRM mass. In order to apply the results of the speciated filter analysis to the aerosol 

mass measurements, EPA Region 10 conducted the Sulfate, Adjusted Nitrate, Derived Water, 

Inferred Carbonaceous Material Balance Approach (SANDWICH) which is the default method in 

EPA modeling guidance to define baseline PM2.5. The SANDWICH approach uses a combination 

of speciation measurements and modeled estimates to represent FRM PM2.5 measurements. 

The goal is to reconstruct the measured speciated components so that they add up to the 

measured FRM PM2.5 mass. Table 8 shows the results as percent contribution by a speciated 

component (sulfates, nitrates, organic carbon (OC), elemental carbon (EC), ammonia (NH3), and 

other primary particulate (OPP)). Detailed methods of the SANDWICH analysis are included in 

Appendix E.1. 

% Sulfate % Nitrate % OC % EC % Water % NH3 % OPP

1.1 0.4 88.4 7.6 1.4 0.03 1.1

Table 8: Contribution by speciated components. Results of SANDWICH analysis for the top 25% high 

concentration winter (Oct-Mar) days. 

Minor PM2.5 Components 

In addition to the speciated components in Table 8, ODEQ, in partnership with Portland State 

University, examined contribution by secondary organic aerosols in Klamath Falls, Oregon and 

found it to be relatively low. Anthropogenic secondary organic aerosols contribute 3% and 

biogenic 1% to the total measured PM2.5 mass. LRAPA chose to adopt these percent 

contributions as a conservative assumption for the Oakridge NAA demonstration. Secondary 

organic aerosols and the other minor components sulfate, nitrate, and background EC and OC 

are assumed to be constant in rollback modeling. More details about this analysis are included 

in Appendix E.1. 

Each source emits a different proportion of OC, EC, and OPP, the three components used to 

develop a speciated emissions inventory. This proportion, or the speciation profiles, for each 

source category are taken primarily from EPA SPECIATE 4.2 and 4.3 databases. The following 

source categories are included in the analysis: 

1 Cement Production

2 Sand and gravel mining

3 Fireplace

4 Woodstove Insert Non-Cert

5 Woodstove Insert Cert (Non-Cat)

6 Pellet / Woodstove Cert

7 Ag and open burn

8 Rail

9 Passenger Vehicles - light diesel

10 Trucks - Heavy diesel

11 Passenger Vehicles - gas

12 Vehicle Road Dust

Attachment 3.3, page 39
November 15, 2012 – Final 

40

Rollback Model 

In evaluating the appropriate modeling analysis of PM2.5 for Oakridge, LRAPA considered many 

different modeling approaches, including rollback and more sophisticated methods such as 

dispersion modeling. However, both dispersion and receptor are more resource intensive and 

do not offer substantial improvements in demonstrating attainment under conditions that exist 

in Oakridge. A rollback model can simulate worst case day conditions when stagnant conditions 

and slow emissions movement within the nonattainment area occur. 

Oakridge is particularly well suited for a rollback demonstration because of a) the relatively 

small area of the NAA, b) the bowl shape of the local airshed and the presence of inversions and 

low mixing heights during evening hours when measured particulates are highest, c) the very 

few types of emissions sources in the NAA, with home wood heating devices dominating the 

emissions. Based on these considerations, LRAPA has chosen a rollback model for the area. 

The rollback model is based on the assumption that there is a direct correlation between 

emissions of a pollutant and measured concentrations of that pollutant in the same airshed, 

and that changes in emissions will result in corresponding changes in concentration. This 

correlation is used to predict future concentrations based on future emissions. The change in 

concentrations caused by changes in emissions is represented by the Relative Response Factor 

(RRF). An RRF less than one indicates a reduction in future concentrations, RRF equal to one 

indicates no change, and RRF larger than one indicates an increase. RRFs are calculated for 

each speciated component (EC, OC, and OPP) used in the rollback model. Details of the analysis 

are presented in Appendix H. The results show a cumulative RRF = 0.696, which indicates a 

decrease in future concentrations. After the cumulative RRF is applied to the input data for the 

baseline design value, the results are used to calculate a future design value of 28.2 μg/m3. 

Year Baseline DV 

PM2.5 (μg/m3)

Future DV 

PM2.5 (μg/m3)

2006 38.6 27.5

2007 42.7 30.4

2008 38.7 27.6

2009 41.3 29.6

2010 33.0 23.6

Design 

Value 39.5 28.2

Table 9: Baseline and Future projected design values 

The future ambient concentration levels are below the NAAQS (35 μg/m3) for a 24-hour 

average and the attainment of the standard is demonstrated with the application of the current 

strategies in place. The current reduction strategies described earlier in this section lower the 

emissions enough to meet the NAAQS at the Willamette Activity Center monitor. 

Attachment 3.3, page 40
November 15, 2012 – Final 

41

Modeled Air Quality Improvements of the Key RWC Strategies 

The key long-term permanent residential wood combustion (RWC) strategies have been: 

the woodstove change-out programs replacing uncertified woodstoves with cleaner 

burning and more efficient home heating units; 

the Oregon and EPA woodstove certification programs requiring any new woodstoves 

installed since 1986 to be certified woodstoves; and 

the Oakridge ordinance and Oregon Heat Smart law requiring removal of uncertified 

woodstoves upon home sale. 

These programs have been critical to the significant improvement in Oakridge PM2.5

concentrations during 2005-2011 as outlined in Figures 5 and 6. In addition, the combined 

emission reduction of these programs will more than offset the growth in population and 

housing between 2008 and 2014, with a net RWC emission reduction of about 28 lb/day on 

typical season days and 31 lb/day on worst-case days and reduce future PM2.5 concentrations 

by 2.1 μg/m3 on worst-case days. 

The key short-term RWC strategy is a strengthened mandatory curtailment program to reduce 

fireplace and woodstove emissions by 30% on an average of 20 red days per year (based on the 

number of days above 30 μg/m3 PM2.5 during 2005-2011). This will reduce RWC emissions by 

131 lb/day and reduce future PM2.5 concentrations by 8.7 μg/m3 on worst-case days. 

Additional details on the modeled air quality improvements due to these emission reductions 

are included in Appendix H (Rollback Analysis) and Appendix J (Residential Wood Combustion 

RACM). 

Unmonitored Area Analysis 

The previous section describes the demonstration of attainment at the Willamette Activity 

Center monitor. In addition, a supplemental analysis was conducted to examine future design 

values away from the Willamette Activity Center, both within Oakridge and in the neighboring 

city of Westfir. The unmonitored area analysis is based on a 2002–2003 saturation survey of 

Oakridge, and the 2009-2010 monitoring of Westfir. These monitoring efforts are described in 

greater detail in Appendix A. 

The ratio of average concentration at each of these monitors to the average concentration at 

Willamette Activity Center is applied to the baseline design value at Willamette Activity Center 

to establish a “baseline” design value for each monitor. The same ratio is then applied to the 

Willamette Activity Center future design value to estimate a future design value for each site. 

Since there is currently only one small point source in the emissions inventory for Oakridge, a 

dispersion modeling exercise to estimate source impacts was deemed unnecessary. 

In both monitoring efforts referenced here, the Willamette Activity Center was the location of 

the highest observed concentration. Base and future design values for all monitored locations 

Attachment 3.3, page 41
November 15, 2012 – Final 

42

were below the NAAQS, indicating that the Willamette Activity Center concentration is the 

highest in the area. More detail of the unmonitored area analysis is available in Appendix A. 

Application of Future Strategies 

Including current strategies, and strengthening of these strategies, the rollback model shows 

that the Oakridge non-attainment area will achieve the standard of 35 μg/m3 by 2014. At 28.2 

μg/m3, the future design value includes a buffer for potential variation while still meeting the 

standard. The Oakridge Advisory Committee developed contingency strategies that are part of 

the attainment plan and will automatically take effect, if necessary, in order to make continued 

progress should the area not achieve the standard by 2014. Using these contingency strategies 

would result in additional emission reductions and consequently could also be used to show 

further reduction in the attainment demonstration roll back model. At this time, these 

additional measures do not appear necessary. The results of the rollback at Willamette Activity 

Center show a cumulative RRF of 0.70 with current strategies and future strengthening of these 

strategies recommended by the committee. 

Table 10 shows the estimated emissions, and proportional concentrations, based on all current 

attainment strategies: 

Table 10: Allocation of emissions and modeled concentrations for base and future years. 

Contingency Plan 

The attainment plan must contain contingency measures that would be implemented in the 

event that the Oakridge nonattainment area fails to meet the standard on or after December 

2014. The contingency measures are designed to correct the violation of the PM2.5 standards 

and be implemented immediately. EPA requires that any contingency measures must equal 

one year equivalent of reasonable further progress (RFP). 

Emissions % PM2.5 μg/m3Emissions % PM2.5 μg/m3

Residential Wood Combustion 79.6% 31.4 74.7% 21.1

Industry 0.0% 0.0 1.2% 0.3

On-road vehicles 8.4% 3.3 7.1% 2.0

Other 2.1% 0.8 2.9% 0.8

Background + secondary aerosols 9.9% 3.9 14.1% 4.0

Total 100.0% 39.5 100.0% 28.2

Base Year Future Year

Source Category

Emissions % PM2.5 μg/m3Emissions % PM2.5 μg/m3

Residential Wood Combustion 79.6% 31.4 74.7% 21.1

Industry 0.0% 0.0 1.2% 0.3

On-road vehicles 8.4% 3.3 7.1% 2.0

Other 2.1% 0.8 2.9% 0.8

Background + secondary aerosols 9.9% 3.9 14.1% 4.0

Total 100.0% 39.5 100.0% 28.2

Base Year Future Year

Source Category

Attachment 3.3, page 42
November 15, 2012 – Final 

43

In Oakridge, the worst-day PM2.5 concentrations need to be reduced by about one microgram 

per cubic meter (μg/m3) per year in order to meet the PM2.5 standard by 2014 (i.e., reduced 

from 39.5 μg/m3 in the 2006-2010 baseline period to 35 μg/m3 by the 2014 attainment date). 

Therefore the RFP requirement in Oakridge would equal about one μg/m3 of further reduction. 

The Oakridge PM2.5 attainment plan includes the following strategies as contingency strategies 

to fully meet the air quality standards, if it becomes clear that the strengthened ongoing 

strategies described above will not be sufficient to attain the PM2.5 standards by 2014 and or to 

maintain compliance with the standards through 2024 and beyond: 

• Stricter opacity limit, revising the current 40% opacity limit in the city ordinance to a 

more restrictive 20% limit, as has been done in some other northwest communities. 

• Stricter green-yellow-red advisory program, with more yellow and red advisory days 

each winter. 

• Further restrictions on city woodstove curtailment exemptions (for sole source, 

economic hardship). 

The most quantifiable and most quickly implemented of these contingency measures would be 

further strengthening of the mandatory curtailment program by more consistent enforcement 

of the city curtailment ordinance and stricter criteria for expanding the number of yellow and 

red advisory days. If the standard is not met by 2014, the number of red curtailment days 

would be increased to an average of 30 days per year (based on the number of days above 25 

μg/m3 PM2.5 during 2005-2011) and the frequency of curtailment enforcement (warnings and 

citations) would be increased accordingly in order to increase the effectiveness of the 

curtailment to 40% (or to 50% if necessary) on worst case days. 

As outlined in the earlier section on Attainment Demonstration, a 30% RWC emission reduction 

from a strengthened mandatory curtailment program is projected to reduce concentrations on 

worst-case days by about 8.7 μg/m3 in 2014. If the mandatory curtailment program is increased 

from an average of 20 days per year (based on 30 μg/m3 PM2.5) to 30 days per year (based on 

25 μg/m3 PM2.5 in the contingency plan) this will further ensure that the full 8.7 μg/m3 is 

achieved. The contingency measures for stronger enforcement on more red advisory days is 

expected to increase the curtailment effectiveness. 

Using these contingency strategies to increase curtailment effectiveness to 40% is 

expected to reduce RWC emissions by 44 lb/day and reduce PM2.5 concentrations by 

an additional 2.9 μg/m3 on worst case days. 

Using these contingency strategies to increase curtailment effectiveness to 50% is 

expected to reduce RWC emissions by 87 lb/day and reduce PM2.5 concentrations by 

5.8 μg/m3 on worst case days. 

Attachment 3.3, page 43
November 15, 2012 – Final 

44

Either of these contingency measures would more than achieve the one μg/m3 target needed 

to meet the EPA RFP test. 

If Oakridge meets the PM2.5 standard by the EPA Clean Air Act 2014 deadline, the contingency 

plan will not be enacted. If Oakridge does not meet the PM2.5 standard by the EPA Clean Air Act 

2014 deadline, the contingency plan will be enacted by the beginning of the immediate next 

wood-heating season, November 15, 2015. 

If the high PM2.5 concentration was determined to be an Exceptional Event based on EPA's 

Exceptional Events Rule, as flagged by ODEQ and concurred by EPA, no further action may be 

needed. 

Attachment 3.3, page 44
November 15, 2012 – Final 

45

Acknowledgements 

Oakridge Advisory Committee 

LRAPA would like to thank the members of the Oakridge Advisory Committee for their efforts in 

developing the list of strategies aimed at reducing PM 2.5 emissions in the community. 

Committee Members: 

James Affa Private Citizen 

James Coey Private Citizen 

Rob DeHarpport Private Citizen 

Herb Hilton Private Citizen 

Glenn Fortune Oakridge City Council 

Don Hampton Former Oakridge Mayor 

Gordon Zimmerman Former Oakridge City Manager 

John Murray Lane Electric Coop 

Paul Engelking University of Oregon Chemistry Professor, LRAPA Citizens Advisory 

Committee 

Brian Forge LRAPA Board Member 

LRAPA Staff Support to Committee: 

Merlyn Hough Director 

Tim Sawyer Data Management Coordinator 

Ralph Johnston Senior Scientist 

Sally Markos Public Affairs Coordinator 

Principal Authors 

Merlyn Hough LRAPA Director 

Tim Sawyer LRAPA Data Management Coordinator 

Sally Markos LRAPA Public Affairs Coordinator 

Robbye Lanier LRAPA Environmental Technician 

Contributors 

Lane Council of Governments 

Oregon Department of Transportation 

Oregon Department of Environmental Quality 

U.S. Environmental Protection Agency 

Attachment 3.3, page 45
Appendix A 

Appendix A - Unmonitored Area Analysis 

An additional analysis, or unmonitored area analysis (UMAA), was used to evaluate future year 

DVs in other areas of the NAA. The UMAA was based on a saturation survey conducted by 

LRAPA between May 2002 and May 2003, and a survey study of the Westfir area performed 

over the winter of 2009 – 2010. 

The 2002-2003 study was performed in order to validate the location of the Willamette Activity 

Center FRM site. This study included five sites within 2 kilometers of the FRM site, along with 

two collocated reference monitors at the FRM site. Samples were taken every third day over 

the year. The Willamette Activity Center site measured the highest annual average and highest 

peak value of all sites in the study. This study is included as an appendix to this demonstration. 

The October 2009 – March 2010 sampling in Westfir, Oregon was performed to measure PM2.5 

impacts in the Westfir area. A MiniVol portable air sampler was collocated with the Willamette 

Activity Center (WAC) FRM, one was placed in the east end of Westfir at the cityhall, and one 

was collocated with a Nephelometer at the Westridge School. The Westridge School is at the 

west end of Westfir, at the confluence of the rivers that pass through Oakridge and Westfir. A 

map of these sites is included below. 

Figure 1 2009-2010 Westfir survey site locations. 

Attachment 3.3a, page 1
Appendix A 

This study consisted of 20 sample events, roughly every sixth day, and completed capture rates 

at all sites was 90% or greater. All samplers used in the study had entrance and exit calibrations 

using an NIST traceable flow transfer standard. Sampling for this study followed LRAPA’s 

existing PM2.5 quality assurance and quality control procedures. The Nephelometer collected 

minute and hourly values over the study period. The Willamette Activity Center measured the 

highest peak PM2.5 value of 33.1 μg/m3, and the highest study average value of 13.0 μg/m3. The 

Nephelometer comparison between the Westfir site and the Willamette Activity Center (plot 

included in the attainment demonstration) shows that Oakridge regularly experiences 

significantly higher concentrations than the Westfir area. 

The UMAA was conducted using the survey sampler concentrations from these two studies. 

The reference survey sampler collocated at the FRM site were used as the basis to calculate a 

concentration ratio for other survey sites. This ratio of reference site to survey site was applied 

to the base year concentration to calculate an estimated future year concentration for each 

survey location. The results of these calculations for each study are included in the table below. 

Figure 2 : UMAA calculation table of values. 

For example, the 98th percentile for site 404 in the 2002-2003 study was 37.2 μg/m3. 

Calculating the ratio to the reference sampler (401) gives 37.2/55.3 = 0.7. Multiplying this ratio 

by the rollback base and future year concentrations of 39.5 and 28.2 μg/m3, site 404 has a 

calculated base year value of 26.6 μg/m3 and a calculated future year of 19.0 μg/m3. 

A map of the 2002-2003 Oakridge survey sites is provided below as a reference for the site 

numbers listed here. 

2009-2010 Westfir Study WAC Westridge Westfir Cityhall

Average 13.0 5.6 7.3

Ratio to WAC 1.0 0.4 0.6

Ratio derived Base DV 39.5 16.8 22.2

Ratio derived Future DV 28.2 12.0 15.9

2002-2003 WAC study 401 (WAC) 403 404 405 406 407

98t h percentile 55.3 51.9 37.2 19.4 23.0 41.4

Ratio to WAC 1.0 0.9 0.7 0.4 0.4 0.7

Ratio derived Base DV 39.5 37.1 26.6 13.9 16.4 29.6

Ratio derived Future DV 28.2 26.5 19.0 9.9 11.7 21.1

Attachment 3.3a, page 2
Appendix A 

Figure 3 : 2002-2003 Oakridge survey site locations.

Future year concentration estimates for all survey sites are lower than that of the Willamette 

Activity Center. 

Attachment 3.3a, page 3
Oakridge, Oregon 

PM2.5 Saturation Study 

Lane Regional Air Pollution Authority 

Monitoring & Data Analysis Section 

October 2003

Attachment 3.3a1, page 1
TABLE OF CONTENTS 

I. INTRODUCTION ....................................................... 1

II. DESIGN .................................................................. 1

III. RESULTS ................................................................ 3

IV. DISCUSSION AND CONCLUSIONS................................ 8

LIST OF TABLES 

1. Saturation site locations ....................................................... 1

2. Laboratory and field error statistics .......................................... 3

3. PM2.5 concentrations in μg/m3 ................................................ 4

4. Data summary ................................................................... 5

5. MiniVol precision data ......................................................... 6

6. MiniVol accuracy data ......................................................... 7

LIST OF FIGURES 

1. Oakridge survey site locations ................................................. 2

2. MiniVol precision ............................................................... 6

3. MiniVol accuracy ............................................................... 7

This study was funded, in part, by a supplemental grant from Region 10 of the U.S. 

Environmental Protection Agency. 

The following staff members of the Lane Regional Air Pollution Authority’s Monitoring and 

Data Analysis Section performed this study: 

 Jerry Boyum 

Lance Giles 

 Gordon Griffin 

 Tim Sawyer 

Calvin Yoshida

i

Attachment 3.3a1, page 2
I. INTRODUCTION

The Lane Regional Air Pollution Authority (LRAPA) conducted a one year monitoring study for 

PM2.5 in the city of Oakridge, Oregon. The purpose of this study was to validate the 

representativeness of a previously established PM2.5 site. The site to be validated was the 

Willamette Activity Center (WAC) in Oakridge1. A federal reference method (FRM) PM2.5

sampler at this site determines the fine particulate levels for the Oakridge area. This site must be 

shown to accurately represent the PM2.5 levels on a neighborhood scale. 

II. DESIGN

This was a one year study beginning May 2002 and ending May 2003. A total of seven 

AirMetrics MiniVol PM2.5 samplers were used. Two MiniVols were collocated at the FRM site 

to be validated, and three samplers were placed within a two kilometer distance of the FRM site. 

 Two samplers were placed further east in Oakridge to gather data for comparison to a previous 

PM10 study. Table 1 lists the locations of each survey site. Figure 1 displays these site 

locations. The sampling was carried out on the E.P.A. 3-day monitoring schedule. The FRM 

sampler used in this study was a Rupprecht & Patashnick (R&P) Partisol-Plus model 2025. 

Table 1. Saturation site locations: 

Oakridge Sites

MV401 WAC-A MV405 Commercial St. and Ash St. 

MV402 WAC-B (collocated) MV406 48284 Hills St. 

MV403 Teller Rd., St. Luke’s 

Church 

MV407 Jones Rd. and Elgin St. 

MV404 W. 1st St. and Portal Dr. 

The MiniVol and FRM samplers were operated with Whatman PTFE 47mm filters, a pure teflon 

filter. All filters were weighed on a Sartorius MC 5 microbalance. Field and laboratory 

procedures, including gravimetric analysis of these filters, were performed in accordance with 

E.P.A. and Oregon Department of Environmental Quality PM2.5 quality assurance plans. 

 

1 Willamette Activity Center E.P.A. ID: 410392013, O.D.E.Q. ID: 2030003 

1

Attachment 3.3a1, page 3
Figure 1. Oakridge survey site locations. 

A
All MiniVols were calibrated before being placed in the field, again within one year, and once 

more upon completion of study. Each calibration was performed using a National Institute of 

Standards and Technology (NIST) traceable laminar flow element. Quarterly audits were 

performed on the MiniVols using NIST traceable transfer standards. MiniVol rotometer set 

points were determined seasonally using historical temperature and pressure averages for the 

area. The MiniVols were rotated through the sites regularly to avoid any site bias due to a 

particular sampler. The FRM sampler underwent annual calibration along with monthly audits, 

both performed with NIST traceable transfer standards. 

III. RESULTS

The sampling began on May 11, 2002 and ended May 30, 2003. The survey samplers were run 

on the E.P.A. 3-day schedule, however not every run day was observed. Sample days near New 

Year’s Day were changed to sample on that holiday, when concentrations were expected to be 

higher. There were 104 possible sampling events for each site. Table 3 is a complete list of all 

sample events considered in this study. All failures are shown in Table 3 as a missing value. 

Most failures were due to sampler component or battery failure (67%), operator error (11%), or 

filter problems or damage (11%). The total capture rate for the MiniVols was 93%. Individual 

site capture rates are shown in Table 4, along with a general summary of the data. All QA/QC 

checks of MiniVols and FRMs were within E.P.A. tolerances. 

Laboratory quality assurance included use of lab blanks and re-weighing 10% of all filters 

weighed, both pre-sampling and post-sampling. Field blanks were used to determine error in 

loading and unloading filters, as well as transporting filters. Table 2 shows the statistics 

regarding these errors. In translating error from mass to μg/m3, we assume that each MiniVol 

ran for 24 hours at 5 LPM, yielding a volume of 7.2 m3

. Further, we assume that the FRM ran 

for 24 hours at 16.67 LPM, yielding a volume of 24.0 m3. Combining the re-weigh and lab 

blank 95% limits, the total laboratory error is 1.0 μg/m3 for the MiniVol and 0.4 μg/m3 for the 

FRM. Considering laboratory and field error together, the total measurable error is 1.3 μg/m3

 for 

the MiniVol and 0.4 μg/m3 for the FRM. 

Table 2. Laboratory and field error statistics: 

n 

Average 

difference 

(μg) 

Standard 

deviation 

(μg) 

Maximum 

difference 

(μg) 

Upper 

95% limit 

(μg) 

Lower 

95% limit 

(μg) 

MiniVol Re-weighs 210 0.0 1.3 -4.0 2.6 -2.6 

MiniVol Lab blanks 103 -0.3 2.6 -8.0 4.7 -5.3 

MiniVol Field blanks 27 4.1 3.5 10.0 10.9 -2.8 

Total MiniVol error 340 0.2 2.3 10.0 4.8 -4.3 

FRM Re-weighs 99 0.0 1.6 6.0 3.2 -3.1 

FRM Lab blanks 43 0.2 3.0 9.0 6.2 -5.7 

FRM Field blanks 15 3.8 4.1 14.0 11.8 -4.2 

Total FRM error 157 0.4 2.6 14.0 5.5 -4.7 

3

Attachment 3.3a1, page 5
Table 3. PM2.5 concentrations in μg/m3

: 

Sample 

Date 

WAC 

FRM 

MV 

401 

MV 

402

MV 

403

MV 

404

MV 

405

MV 

406 

MV 

407

Sample

Date 

WAC

FRM

MV 

401 

MV 

402

MV 

403

MV 

404

MV 

405

MV 

406 

MV 

407

05/11/02 14.8 14.4 14.6 8.8 7.1 8.3 8.9 13.2 11/22/02 19.0 23.8 24.0 - 15.3 12.3 - - 

05/14/02 6.2 5.7 6.3 4.8 6.0 5.9 5.6 6.4 11/28/02 35.8 35.1 35.7 49.1 34.9 14.8 23.0 25.3

05/17/02 3.6 4.7 4.3 4.1 4.4 4.1 - 5.8 12/04/02 31.3 31.4 31.9 32.7 25.1 19.4 19.5 29.4

05/23/02 4.6 - 4.9 4.0 3.2 2.7 2.4 4.2 12/07/02 26.0 26.8 27.0 29.6 19.2 14.9 18.3 17.3

05/26/02 2.8 3.3 3.9 3.0 4.9 4.1 4.6 3.9 12/10/02 19.4 19.5 19.6 11.8 21.4 9.7 13.3 24.8

05/29/02 1.8 3.1 2.7 3.5 2.4 1.7 3.2 2.8 12/13/02 21.5 11.3 9.9 6.9 10.9 6.0 4.6 12.9

06/01/02 6.2 6.3 - 7.3 7.1 7.3 7.5 7.6 12/19/02 31.5 30.7 31.4 23.2 24.6 16.3 18.7 34.8

06/04/02 3.3 3.0 3.6 3.9 3.1 4.5 3.8 4.2 12/22/02 11.8 13.3 12.7 7.6 15.0 9.1 6.4 10.9

06/07/02 4.1 4.2 4.4 4.6 2.9 4.0 3.5 3.9 12/25/02 16.7 17.1 16.2 - 20.3 11.2 7.7 18.3

06/13/02 7.7 7.7 8.2 7.9 6.3 7.0 7.9 8.1 12/28/02 13.3 - - - - - - - 

06/16/02 4.2 4.2 2.9 3.8 4.9 4.4 4.8 5.0 01/01/03 22.9 23.8 25.2 15.4 20.7 8.8 11.3 22.9

06/19/02 3.8 4.7 4.2 4.8 3.4 4.6 5.4 5.4 01/06/03 31.2 29.7 29.1 27.3 22.4 11.8 12.9 - 

06/22/02 4.0 4.8 5.7 4.9 5.3 4.6 4.9 5.2 01/09/03 30.0 28.8 29.0 - 35.9 18.2 17.4 25.6

06/25/02 5.2 7.7 8.7 - 5.9 6.9 7.6 6.9 01/12/03 32.4 31.8 - 28.7 31.6 12.2 9.9 27.2

06/28/02 3.1 2.8 3.2 2.9 3.2 3.0 3.2 2.6 01/15/03 16.3 17.4 16.9 18.0 12.9 9.2 10.3 12.1

07/04/02 - - - - - - - - 01/21/03 54.0 53.7 54.2 51.9 41.0 15.9 16.6 47.6

07/10/02 10.5 10.6 11.1 9.9 9.8 9.6 9.8 11.6 01/27/03 - 9.4 9.5 8.9 - 6.7 - 11.6

07/13/02 10.1 10.9 10.0 10.4 9.3 9.6 10.3 10.6 01/30/03 27.0 25.0 24.2 17.3 28.6 18.2 14.8 25.2

07/16/02 6.0 9.0 6.7 6.2 6.9 9.4 7.0 7.3 02/02/03 8.0 8.6 9.3 5.8 7.4 4.6 5.3 9.5 

07/22/02 11.3 11.5 11.6 12.5 10.9 - 11.2 14.2 02/05/03 23.1 25.9 24.3 17.0 18.1 11.8 9.7 27.4

07/25/02 7.9 8.7 7.7 8.1 8.1 8.6 9.2 8.1 02/08/03 56.8 55.3 56.1 33.0 14.7 16.7 17.1 41.4

07/31/02 7.6 7.7 8.5 7.9 9.9 9.6 9.1 7.7 02/11/03 45.1 43.5 42.8 - 15.9 15.0 15.4 31.7

08/03/02 5.3 6.3 5.5 6.1 4.9 5.6 6.0 6.6 02/17/03 7.7 8.6 - 8.0 - 6.4 8.3 11.2

08/07/02 13.8 13.0 13.8 14.4 12.2 11.5 13.1 13.6 02/20/03 10.2 10.2 10.1 6.3 10.3 - 4.9 12.5

08/09/02 - 23.0 23.0 24.6 22.6 - 19.0 23.8 02/23/03 9.0 9.2 - 6.9 10.0 3.3 3.0 10.0

08/15/02 7.4 8.7 7.9 6.3 6.4 6.3 5.9 - 02/26/03 37.3 36.3 35.6 - 20.2 14.9 16.0 38.8

08/18/02 5.4 6.3 5.2 6.3 5.8 5.3 6.1 6.3 03/01/03 13.3 11.9 11.6 6.4 10.7 6.1 - 12.1

08/21/02 3.9 5.1 4.9 4.5 4.0 4.5 4.7 4.5 03/04/03 8.6 8.0 - 8.1 9.7 7.5 - 4.6 

08/24/02 6.3 7.3 - 6.4 6.1 6.2 6.6 7.4 03/07/03 13.1 12.4 12.0 10.7 11.9 6.9 5.8 11.7

08/27/02 6.2 6.6 6.4 5.9 6.3 6.4 6.6 7.7 03/13/03 11.3 10.7 11.3 7.5 11.2 5.1 4.3 11.5

09/02/02 26.5 26.9 26.1 17.8 37.2 42.3 36.7 33.3 03/16/03 5.4 5.8 5.6 5.4 7.1 5.6 3.6 7.6 

09/05/02 9.1 - 10.7 11.6 10.1 10.0 9.1 10.4 03/19/03 11.7 12.1 11.9 9.7 13.5 - 4.4 12.6

09/08/02 4.8 4.6 4.2 4.2 4.2 4.1 3.4 5.0 03/22/03 9.9 10.4 10.9 4.8 8.2 4.3 4.4 12.6

09/11/02 7.5 8.7 7.2 8.1 7.7 7.7 7.4 7.9 03/28/03 6.8 - 7.6 4.9 7.3 - 4.0 8.1 

09/14/02 10.6 10.9 10.0 10.6 10.0 11.5 10.4 11.0 04/03/03 6.1 5.9 5.9 6.8 10.2 4.0 3.8 7.2 

09/20/02 4.1 3.5 3.5 4.4 4.4 - 4.2 4.9 04/06/03 6.6 6.5 6.6 6.4 7.8 6.7 5.1 9.1 

09/26/02 11.5 12.1 11.8 10.8 9.0 10.5 9.2 13.7 04/09/03 2.7 4.1 2.9 3.3 4.4 3.8 2.5 4.0 

09/29/02 4.8 5.3 4.8 4.4 4.7 4.5 3.4 6.3 04/12/03 3.1 4.4 6.4 4.6 6.5 4.1 - 4.3 

10/02/02 10.4 11.5 10.5 7.0 6.3 5.7 4.4 14.8 04/15/03 3.8 3.0 3.5 4.8 5.2 2.1 2.6 5.0 

10/05/02 4.9 5.9 5.9 3.5 4.8 3.8 5.4 6.0 04/18/03 9.5 10.0 9.8 6.3 9.3 7.5 5.9 - 

10/11/02 17.5 16.1 16.4 7.1 7.7 4.5 4.3 17.0 04/24/03 4.5 2.2 5.3 4.4 7.0 5.3 3.8 6.6 

10/17/02 17.8 17.2 17.9 10.2 7.4 7.5 11.0 11.5 04/27/03 5.8 6.2 6.3 6.0 8.9 5.2 3.2 5.4 

10/20/02 15.1 15.2 13.9 9.0 12.7 8.4 10.1 15.7 04/30/03 3.3 3.6 3.3 3.9 4.4 0.7 1.5 3.4 

10/23/02 28.6 27.2 27.2 15.7 12.0 11.4 11.6 21.6 05/03/03 5.7 5.6 5.6 6.2 7.8 6.6 5.9 7.9 

10/26/02 22.4 21.4 22.1 17.7 16.9 15.0 17.5 22.8 05/06/03 7.3 8.1 8.1 6.6 7.4 7.6 8.0 9.0 

10/29/02 18.2 17.8 17.6 14.2 12.6 9.0 7.6 20.3 05/12/03 4.2 3.9 4.3 4.1 3.5 4.9 4.1 4.5 

11/04/02 - 58.1 57.1 53.3 25.8 16.2 19.1 34.7 05/15/03 5.3 5.1 6.1 5.4 6.3 5.2 5.4 7.6 

11/07/02 10.6 11.2 10.0 7.5 9.5 7.1 7.1 12.5 05/18/03 6.0 6.1 6.2 4.2 6.2 3.5 3.4 5.4 

11/10/02 13.6 14.7 16.4 8.9 17.5 7.7 7.6 19.0 05/21/03 8.6 9.3 9.7 8.6 8.5 - 9.0 10.8

11/13/02 16.1 16.0 16.2 15.0 17.3 9.9 8.7 16.7 05/24/03 4.9 5.7 6.4 6.4 6.4 6.0 6.4 5.6 

11/16/02 12.4 12.2 12.5 13.3 14.0 11.0 11.3 11.8 05/27/03 4.0 5.3 6.0 6.3 5.6 7.4 8.7 6.9 

4

Attachment 3.3a1, page 6
11/20/02 23.3 23.0 21.3 23.6 15.7 - 16.6 21.3 05/30/03 5.3 6.3 6.4 - 6.6 7.2 7.1 8.0 

Table 4. Data summary: 

n 

(max 

103) 

Capture 

rate 

Annual 

mean 

(μg/m3) 

Maximum 

value 

(μg/m3) 

n > 15 

μg/m3

Site 

average1

(μg/m3) 

Difference 

from Site 

average

(%) 

WAC FRM 100 96% 12.8 56.8 28 - - 

MV401 (primary) 99 95% 13.6 58.1 29 WAC 

13.6 

- 

MV402 (duplicate) 96 92% 13.5 57.1 28 - 

MV403 95 91% 10.9 53.3 18 - -19.9 

MV404 100 96% 11.4 41.0 23 - -16.2 

MV405 94 90% 8.3 42.3 8 - -39.0 

MV406 96 92% 8.6 36.7 14 - -36.8 

MV407 98 94% 13.0 47.6 26 - -4.4 

1 Site average represents the arithmetic average of annual mean values for the two collocated MiniVols at the FRM site. 

According to the Code of Federal Regulations1

, collocated measurement pairs where one or both 

concentrations are 6 μg/m3 or less may agree relatively poorly. Therefore, the following 

precision and accuracy calculations use only collocated pairs where both measurements are 

greater than 6 μg/m3. 

 

Precision statistics for the MiniVols were derived using data obtained from the set of collocated 

samplers. Table 5 shows the sample data used in a simple linear regression, displayed in Figure 

3. Sampler MV401 is considered primary; while collocated sampler MV402 is considered 

duplicate. The precision results indicate that during this study the concentrations reported by the 

MiniVols varied less than 1%. 

Accuracy statistics for the MiniVol as compared to the R&P model 2025 FRM sampler were 

computed by pairing each collocated MiniVol with the R&P from the FRM site. The data set 

can be found in Table 6 by looking at the two pairs made up from WAC FRM with MV401 then 

MV402. The concentrations found using MiniVols were consistently higher than those found 

using FRM samplers. The accuracy results indicate that during this study the MiniVol reported 

concentrations approximately 2% higher than the R&P. Figure 4 displays these results. These 

accuracy results show the MiniVol annual average values are comparable to the R&P annual 

averages, making the MiniVol a suitable tool for PM2.5 measurement. 

 

1 40 CFR Part 58 Appendix A, Section 5.5 

5

Attachment 3.3a1, page 7
Table 5. MiniVol precision data: 

Sample 

Date 

MV 

401 

MV 

402 Diff Sample Date 

MV 

401 

MV 

402 Diff Sample Date 

MV 

401

MV 

402 Diff 

05/11/02 14.4 14.6 -0.2 10/26/02 21.4 22.1 -0.7 01/27/03 9.4 9.5 -0.1 

06/13/02 7.7 8.2 -0.5 10/29/02 17.8 17.6 0.2 01/30/03 25 24.2 0.8 

06/25/02 7.7 8.7 -1.0 11/04/02 58.1 57.1 1.0 02/02/03 8.6 9.3 -0.7 

07/10/02 10.6 11.1 -0.5 11/07/02 11.2 10.0 1.2 02/05/03 25.9 24.3 1.6 

07/13/02 10.9 10.0 0.9 11/10/02 14.7 16.4 -1.7 02/08/03 55.3 56.1 -0.8 

07/16/02 9.0 6.7 2.3 11/13/02 16 16.2 -0.2 02/11/03 43.5 42.8 0.7 

07/22/02 11.5 11.6 -0.1 11/16/02 12.2 12.5 -0.3 02/20/03 10.2 10.1 0.1 

07/25/02 8.7 7.7 1.0 11/20/02 23 21.3 1.7 02/26/03 36.3 35.6 0.7 

07/31/02 7.7 8.5 -0.8 11/22/02 23.8 24 -0.2 03/01/03 11.9 11.6 0.3 

08/07/02 13.0 13.8 -0.8 11/28/02 35.1 35.7 -0.6 03/07/03 12.4 12 0.4 

08/09/02 23.0 23.0 0.0 12/04/02 31.4 31.9 -0.5 03/13/03 10.7 11.3 -0.6 

08/15/02 8.7 7.9 0.8 12/07/02 26.8 27 -0.2 03/19/03 12.1 11.9 0.2 

08/27/02 6.6 6.4 0.2 12/10/02 19.5 19.6 -0.1 03/22/03 10.4 10.9 -0.5 

09/02/02 26.9 26.1 0.8 12/13/02 11.3 9.9 1.4 04/06/03 6.5 6.6 -0.1 

09/11/02 8.7 7.2 1.5 12/19/02 30.7 31.4 -0.7 04/18/03 10 9.8 0.2 

09/14/02 10.9 10 0.9 12/22/02 13.3 12.7 0.6 04/27/03 6.2 6.3 -0.1 

09/26/02 12.1 11.8 0.3 12/25/02 17.1 16.2 0.9 05/06/03 8.1 8.1 0.0 

10/02/02 11.5 10.5 1.0 01/01/03 23.8 25.2 -1.4 05/18/03 6.1 6.2 -0.1 

10/11/02 16.1 16.4 -0.3 01/06/03 29.7 29.1 0.6 05/21/03 9.3 9.7 -0.4 

10/17/02 17.2 17.9 -0.7 01/09/03 28.8 29 -0.2 05/30/03 6.3 6.4 -0.1 

10/20/02 15.2 13.9 1.3 01/15/03 17.4 16.9 0.5 

10/23/02 27.2 27.2 0.0 01/21/03 53.7 54.2 -0.5 

Figure 2. MiniVol precision: 

Regression Line: 

0

10

20

30

40

50

60

70

Colocated sampler (ug/m3)

0 10 20 30 40 50 60 70

Primary sampler (ug/m3)

MiniVol Precision

Primary vs. Colocated y = 1.0021x – 0.1684 

r

2

 = 0.9958

Precision Statistics: 

n = 64 

Standard deviation: 0.79 

Maximum difference: 2.3 

Average difference: 0.1 

6

Attachment 3.3a1, page 8
IV. DISCUSSION AND CONCLUSIONS 

The most straightforward conclusion to be drawn from the data presented here is that Oakridge 

experienced high PM2.5 levels during this study. Several annual averages for samplers within 

two kilometers of WAC were approaching the 15 μg/m3 annual standard. During the study the 

FRM sampler located at the WAC measured three daily exceedances of the 65 μg/m3

 standard. 

Each of these three days, however, was not on the study’s survey sampler schedule. 

Analysis of FRM data collected at WAC during the 2002 and 2003 calendar years gives 348 

days with valid PM10 and PM2.5 samples. The average of the daily ratios of PM2.5 to PM10

reveals that about 77% of PM10 is PM2.5. This ratio suggests that it is reasonable to compare 

results of this study with those of previous Oakridge PM10 studies, in general terms. 

PM10 studies were performed in the Oakridge area in 1991 and 1994. The 1991 study included, 

as did this study, sites in both the eastern half and western half of Oakridge. The 1991 study 

agreed with the findings here, that eastern Oakridge has significantly lower particulate levels. 

“The highest PM10 concentrations collected during the study were located at Sites ... which are 

in western Oakridge. Most of these sites are south of the railroad tracks ... eastern Oakridge 

recorded the lowest concentrations.” 1. The 1994 study included only sites in the western half of 

Oakridge, and determined “Like the 1991 study, the highest concentrations are observed in the 

western- and southern-most sites.”2

The small geographic size of the Oakridge community, along with the representative population 

density of southwestern Oakridge indicates the particulate levels of interest occur in this 

southwestern portion of the community. This further limited geographic area that comprises 

southwestern Oakridge leaves few options for relocating the FRM PM2.5 site according to EPA 

site criteria. 

These facts lead to the conclusion that the WAC is the best available site to monitor the 

particulate problem in Oakridge. 

Further study of Oakridge, especially of the southwestern area, is planned using both survey 

samplers and a mobile nephelometer. 

 

1 Jacqueline Fern, et al, Lane Regional Air Pollution Authority, “OAKRIDGE PM10 SATURATION STUDY 

February 8, 1991 – February 28, 1991”, September 1991. 

2 Monitoring & Data Analysis Section, Lane Regional Air Pollution Authority, “Oakridge, Oregon 1994 PM10 

Saturation Monitoring Study”, July, 1995. 

8

Attachment 3.3a1, page 10
Appendix B 

Appendix B – Meteorology 

Common Meteorological Conditions During High Particulate Events 

PM2.5 standard exceedances in Oakridge generally occur on winter days when winds are light 

and mixing is poor. During these air stagnation events, concentrations can build over several 

days until weather fronts of sufficient strength to scour the valley occur. The following graphs 

detail conditions of high PM2.5 levels; periods of calm winds (< 2.0 mph) with stable 

atmospheric conditions generally marked by strong surface based temperature inversions. 

Figure 1: This figure plots over 26,000 values of 1-hour average Nephelometer and Wind Speed. The 

Nephelometer correlation to PM2.5 for this site places the daily standard of 35 μg/m3 at 1.7 (x 10-4) Bscat. This 

graph demonstrates that significant levels of PM2.5 occur with calm winds (≤ 2.0 mph).

Attachment 3.3b, page 1
Appendix B 

Figure 2: A typical winter period of stagnation is displayed above. Each of these six days had measured PM2.5

values between 36 and 58 μg/m3. A positive ‘Del T’ value indicates a temperature inversion between 2 and 10 

meters above the surface. There is a clear diurnal pattern with high PM2.5 occurring at night under low wind 

speed, temperature inversion conditions. 

Representativeness of Base Year Meteorological Conditions 

The base year for this attainment demonstration was chosen to be 2008 for a variety of 

reasons, mostly related to emissions inventory. The meteorology of 2008 is assessed here to 

ensure that 2008 conditions are generally representative of average conditions over the period 

2006-2011. The Oakridge PM2.5 problem is with the 24-hour standard, and no exceedance of 

the Annual standard has occurred. Because of this, and the argument above regarding 

conditions that cause PM problems, only winter months of January, February, November, and 

December were used in this analysis. 

The parameters used for this comparison are ambient temperature at two meters above the 

surface, wind speed at 10 meters, stability as determined by temperature difference between 2 

and 10 meters above the surface, and heating degree days. The table below shows these 

values for the Oakridge monitoring site for the period 2006-2011. 

2006 2007 2008 2009 2010 2011 2006-2011 Avg

Average Temp (degrees F) 40.6 38.6 38.4 37.8 42.1 38.3 39.3

Average Wind Speed (mph) 2.3 2.1 2.1 1.9 2.0 1.6 2.0

# hrs Wind Speed < 2 mph 1635 1744 1702 1874 2024 2100 1847

# stable hrs 774 849 901 1179 997 995 949

Heating Degree Days 24.4 26.4 26.7 27.3 22.9 26.7 25.7

Attachment 3.3b, page 2
Appendix B 

The following plots show values for these parameters over 2006-2011, along the period 

average. For this purpose winter is defined as January, February, November, and December of 

the indicated year. 

Attachment 3.3b, page 3

.s::. 

c. 

36 

35 

3.0 

2.5 

E 2.0 ._. 

... 

::J 

~ 1.5 ... 

<II 

c. 

lfl 1.0 

~ 

0.5 

0.0 

Oakridge Average Winter Temperature, 2006-2011 

2006 2007 2008 2009 2010 2011 

Ave rage Temp - 2006-2011 Avg 

Oakridge Average Winter Wind Speed, 2006-2011 

2006 2007 2008 2009 2010 2011 

- Average Wind Speed - 2006-2011 Avg 
Appendix B 

Using these parameters, the meteorology in Oakridge for the 2008 calendar year is 

representative of the larger time period of 2006-2011. 

Attachment 3.3b, page 4