Department of Environmental Quality
Agency Headquarters

811 SW Sixth Avenue
Kate Brown, Governor Portland, OR 97204-1390 (503) 229-5696 FAX (503) 229-6124

TTY 711 December 14, 2015

Dennis McLerran Regional Administrator U.S. Environmental Protection Agency, Region X
1200 Sixth Avenue
Seattle WA 98101

Dear Dennis:

The Oregon Department of Environmental Quality, Lane Regional Air Protection Agency, and City of Oakridge request a one-year extension to the attainment date for the Oakridge PM 2.5 Moderate Nonattainment Area. The Administrator of the Environmental Protection Agency has discretionary authority under section 188(d) of the federal Clean Air Act to grant a 1-year extension to the attainment
date for Moderate Areas.

Clean Air Act section 188(d) provides criteria for granting an extension. While section 188 specifically applies to PM 10 (particulate matter with an aerodynamic diameter of less than 10 micrometers) the
courts have determined that PM 2.5 (particulate matter with an aerodynamic diameter of less than 2.5 micrometers) nonattainment area planning must also follow the requirements of section 188. The EPA has published a proposed rule (Implementation Rule) interpreting the application of section 188 to PM 2.5 planning and this request is based on that proposed rule. As proposed in the Implementation Rule, two criteria are required to be met in consideration of the EPA’s granting the request: 1) the state has complied with all requirements and commitments pertaining to the area in the applicable implementation plan, and 2) the 98 th percentile PM 2.5 concentration in the area in the year preceding the extension year is less than or equal to the standard level. The enclosed request for a one-year extension demonstrates that Oakridge meets these two criteria.

The extension would allow the City of Oakridge and LRAPA to determine the adequacy of the new aggressive control measures implemented since October 2014 to achieve attainment of standards. We greatly appreciate your attention to this important matter.

Sin cerely,

Dick Pedersen

Director

Cc: Mayor James Coey, City of Oakridge Louis Gomez, City Administrator

, City of Oakridge Merlyn Hough, Director, Lane Regional Air Protection Agency

Enclosure

### LRAPA Cover Letter: Extension forwarding request from LRAPA to Oregon DEQ.

E xtension Request : Request for a 1 -Year Extension for Oakridge, Oregon, a Moderate PM 2.5 

### Nonattainment Area

.



## Attachments

A ttachment 1: Oakridge PM 2.5 

### Attainment Plan: December 2012 Submittal as a revision to the State Implementation Plan.

A ttachment 2: LRAPA 2014 Ambient Air Monitoring Network Plan.

A ttachment 3: LRAPA Dashboard Report, October 2015.

A ttachment 4: Lane Electric Cooperative, Enhanced Incentive Program for Oakridge Heat Pumps, August 28, 2015.

A ttachment 5: City of Oakridge Air Pollution Control Ordinance #914, October 15, 2015.

A tta chment 6: Supplemental Strategies Overview
– Southern Willamette Forest Collaborative,
October 2015.

A ttachment 7: Lane Electric Ruralite Magazine
– LRAPA Oakridge Winter Wood Heating Article, November 2015.

A ttachment 8: Supplemental 2015-2016 Oakridge SIP Development Plan, September 2015.

## L RAPA Cover Letter

Exten sion f

o rwarding request

f rom LRAPA to Or ego n DEQ

### Dec ember 10 , 2015

D ick Pedersen

Director Oregon Department of Environmental Quality
811 SW Sixth Avenue
Portland OR 97204

D ear D ick :

T he Lane Regional Air Protection Agency has prepared a request for a one

- year extension to the attainment date for the Oakridge PM 2.5 

### Moderate N onattainment A rea. The Administrator of the Environmental Protection Agency has discretionary authority under s ection 188(d) of the federal Clean Air Act to grant a 1

- year extension to the attainment date for Moderate Areas. LRAPA asks that the Oregon Department of Environmental Quality forward this request to EPA Region 10 on behalf of the City of Oakridge

, LRAPA and the State of Oregon

.

C lean Air Act s ection 188(d) provide s criteria for granting an extension. While section 188 specifically applies to PM 10 

### (particulate matter with an aerodynamic diameter of less than 10 micrometers) the
courts have determined that PM 2.5 

### (particulate matter with an aerodynamic diameter of less than 2.5 micrometers) nonattainment area planning must also follow the requirements of section 188. T he EPA has published a proposed rule (Implementation Rule) interpreting the application of section 188 to

PM 2.5 

### planning and this request is based on that proposed rule. As proposed in the Implementation Rule, two criteria are required to be met in consid eration of the EPA’s granting the request: 1) the state has complied with all requirements and commitments pertaining to the area in the applicable implementation plan, and 2) the 98 th 

### percentile PM 2.5 

### concentration in the area in the year preceding the extension year is less than or equal to the standard level.
The enclos ed request for a one

- year extension demonstrates that Oakridge meets these two criteria.

T he extension would allow the City of Oakridge and LRAPA to determine the adequacy of the new

aggress ive control measures implemented since October 2014 to achieve attainment of standards. We greatly appreciate your assistance on this important matter.

Sin cerely,

Me rlyn L. Hough, P .E.

, BC EE
Director Lane Regional Air Protection Agency

Cc: Ci ty of Oakridge Mayor James Coey and City Administrator Louis Gomez

E nclosure 1010 Main Street Springfield, OR 97477

P hone: (541) 736

- 1056 Fax (541) 726

- 1205
1- 877

- 285

- 7272

www.lrapa.org E- mail: lrapa@lrapa.org

## E xtension Request

Request for a 1 -Y ear Extension for O akridge, O regon , a M o derate

P M 2

. 5 N onattainment AreaOakridge Attainment Date Extension Request Page 1 

## Request for a 1

- Year Extension for Oakridge, Oregon,
a Moderate PM 2.5 

## Nonattainment Area

Lane Regional Air Protection Agency City of Oakridge, Oregon Oregon Department of Environmental Quality

Clean Air Act Authorization :

Section 188(d) of the federal Clean Air Act (CAA) gives the Administrator of the Environmental Protection Agency (EPA) discretionary authority to grant a 1

- year extension to the attainment
date for Moderate Areas. No more than two 1

- year extensions may be granted. Sect ion 188(d)(1) and 188(d)(2) provide criteria for granting an extension. While section 188 specifically applies to PM

- 10 (particulate matter with an aerodynamic diameter of less than 10 micrometers) the courts have determined that PM 2.5 

### (particulate matter with an aerodynamic diameter of less than 2.5 micrometers) nonattainment area planning must also follow the requirements of section 188. The EPA has published a proposed rule (Implementation Rule) interpreting the application of section 188 to PM 2. 5 

### planning and this request is based on that proposed rule. As proposed in the Implementation Rule, two criteria are required to be met in consideration of the EPA’s granting the request : 1) the state has complied with all requirements and commitments per taining to the area in the applicable implementation plan, and 2) the 98 th 

### percentile PM 2.5 

### concentration in the area in the year preceding the extension

year is less than or equal to the standard level

.

Request for a 1

- Year Extension of the Attainment Da te for the Oakridge, Oregon Moderate

PM 2.5 

### Nonattainment Area:

The statutory attainment date for the Oakridge Moderate PM 2.5 

### Area is December 31, 2015. The Oakridge area will most likely not attain the PM 2.5 

### National Ambient Air Quality Standard ( NAAQS ) by that date. By the following demonstration, Oakridge will meet the two criteria provided in the CAA section 188(d) . The Lane Regional Air Protection Agency ( LRAPA ), the City of Oakridge, and the Oregon Department of Environmental Quality ( ODEQ ) request a 1

- year attainment date extension to December 31, 2016. This will allow additional time to collect ambient air quality data to demonstrate the effectiveness of the Oakridge PM 2.5 

### State Implementation Plan ( SIP ) control strategy.

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 su mmit of the Cascade Mountain Range. The city limits of present

- day Oakridge includes the historic City of Oakridge and, directly west,Oakridge Attainment Date Extension Request Page 2 

### the area formerly known as Willamette City. Figure 1 shows the location of Oakridge in Lane
County.

Figure 1: Oakridge Location

The area of applicability for the 

### PM 2.5 attainment plan includes an area that contains the City of Oakridge and the small town of Westfir. Figure 2 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

th e 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, respec tively.

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 hig h mountains. Westfir and Oakridge are in separate steepOakridge Attainment Date Extension Request Page 3 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 p oint.

Figure 2 : Nonattainment Area



### Air Quality data:

The Oakridge air monitoring station (Site Code WAC, AQS # 410392013) has been located at the Willamette Activity Center in the southwest portion of the city of Oakridge since 1989.

Saturation monitor ing studies in 1991 and 1994 ( PM 10 

### ) and 2002

- 2003 ( PM 2.5 

### ) demonstrate d
the monitor is located in the area of maximum emissions and PM 2.5 

### concentration s

. The WAC

station is part of the SLAMS (State and Local Air Monitoring Stations) network and meets all siting requirements and criteria for the monitoring objective of maximum population exposure at the neighborhood spatial scale.

The WAC sampling method for PM 2.5 

### is the filter

- based Federal Reference Method (FRM) operating on an every

- 3 rd



### - d ay schedule. Other parameters measured at the WAC station
include :

• PM 10 

### (filter

- based FRM on an every

- 6 th



### - day operating schedule),

• PM 2.5 

### with Federal Equivalent Method (continuous beta attenuation),Oakridge Attainment Date Extension Request Page 4 

### • Nephelometer (continuous optical backscatter)

,

• Wind Speed and Direction (continuous propeller/vane),

• Temperature (continuous thermistor at 2 meters and 10 meters height),

• Barometric Pressure (continuous electronic barometer), and

• Solar Radiation (continuous pyranometer).

Additional details, photos and maps are included in the annual LRAPA Ambient Air Monitoring
Network Plan ; Figures 3 and 4 are taken from that Network Plan.

Figure 3: Oakridge WAC Air Monitoring Station. Figure 4: WAC Station Location.



### Quality

- assured data is submitted quarterly to Oregon DEQ and U.S. EPA. All of the quality

assured PM 2.5 

### data for the first three quarters (January

- September) of 2015 has been below 35 micrograms per cubic meter ( μg/m 3 

### ) and submitted to DEQ and EPA. Preliminary data from
October 2015 to the date of this extension request has also been below 35 μg/m 3



### . LRAPA commits to providing the EPA a full calendar year of certified data no later than February 28, 2016 along with the 98 th 

### percentile value for that data. LRAPA anticipate s the data will meet the air quality criteria for granting a 1

- year extension because of implementation of the control strategies in the applicable SIP as well as recent revisions to control measures th at have not yet, but are to be submitted to the EPA in December 2016, along with other provisions to meet the requirements of subpart 4 of the CAA

.

The 2001

- 2014 trends at Oakridge and the Eugene

- Amazon monitoring stations in Lane County
are indicated in Figure 5. [Eugene

- Amazon is the key indicator site for the Eugene

- Springfield

area , located about 40 miles from Oakridge ; in contrast to Oakridge, the Eugene

- Springfield area has not required a PM 2.5 

### attainment plan or new control strategy since it alread y met the
1997 and 2006 PM 2.5 

### standard s .]

Based on significant year

- to

- year fluctuations in weather and meteorology (e.g., temperature, heating degree days, wind speed and direction, ventilation, vertical mixing, etc.), it is difficult to
evaluate the re presentativeness of any one year or even any 3

- year period. But comparing theOakridge Attainment Date Extension Request Page 5 

### 3

- year design values to the overall trend lines at both stations, it appears that 2011

- 2013 and

2012

- 2014 were more adverse and challenging 3

- year periods than typical periods du ring 2001

- 2014. To illustrate, the 3

- year 98 th 

### percentile averages for 2011

- 2013 and 2012

- 2014 at both
the Oakridge and Eugene

- Amazon stations i ndicate worse periods than average, and 2009

- 2011
and 2010

- 2012 indicate better than average.

Figure 5: PM 2.5 Trends at the Oakridge and Eugene

- Amazon Monitoring Stations.



### The LRAPA and the State have complied with all requirements and commitments pertaining to the area in the applicable implementation plan:

The highest PM 10 

### and PM 2.5 

### air pollution concen trations in Oakridge occur during the winter months, especially on cold days during periods of air stagnation. [ Annual average
concentrations have been well within the annual health standards for both PM 10 

### and PM 2.5



### . ]

Several particulate matter SIP revisions were developed, submitted and approved by the EPA. Some of these measures were contained in previous nonattainment area S IPs, while others were adopted a s general SIP strengthening measures. Most of the control measures in those
SIP actions eith er remain part of the applicable SIP, or have been revised, updated and in the 0 10 20 30 40 50 60 70PM2.5 (24-hr, ug/m3, 98%ile, 3-yr avg) Old Standard (1997) Oakridge Eugene Amazon New Standard (2006) Linear (Oakridge) Linear (Eugene Amazon)Oakridge Attainment Date Extension Request Page 6 

### process of being submitted to the EPA. These revisions are to meet the changing needs of the

area.

The Oakridge Urban Growth Boundary was designated nonattainment for PM 10 

### and classified
as moderate by EPA on January 20, 1994. LRAPA submitted a draft Oakridge PM 10 

### attainment plan to EPA Region 10 for stringency review during early 1996. The Oakridge PM 10 

### attainment plan was adopted by the LRAPA Board of Directors at a hearin g on August 13, 1996. The Oakridge PM 10 

### attainment plan was subsequently adopted by the Oregon Environmental Quality Commission on December 9, 1996, and submitted to EPA. EPA approved the plan on March 15, 1999 ( 64 FR 12751 ). The plan relie d on control strategies needed to assure
attainment of the PM 10 

### National Ambient Air Quality Standards (NAAQS). The strateg y focuse d on control of residential wood combustion, and road dust. Additional reductions were provided by statewide efforts to reduce slash burning smoke.

These control measures were approved by EPA , effective May 14, 1999 :

• Accelerated Woodstove Replacement Program through grants and loans (1993

- 1994); Aggressive Voluntary Residential Wood Burning Curtailment (1996);

• Letter of Agreement from ODOT , July 29, 1996 , Use of Anti

- icing Chemicals in the City of Oakridge; and

• Road Paving Program (1991

- 1995).

EPA also approved these contingency measures on March 15, 1999 ( 64 FR 12751 ) , but the Oakridge area achieved the PM 10 

### standards on schedule without triggering the contingency

measures:

• City Ordinance 815 , Mandatory Wood Heating Curtailment Program, adopted August 15, 1996 ; and

• OAR 340

- 262

- 0310 Removal and Destruction of Uncertified stove upon Sale of Home

.

The Oakridge PM 10 

### strategies were successful in ac hieving the PM 10 

### standards on schedule. On July 26, 2001, EPA published a finding of attainment for the Oakridge PM 10 

### area ( 66 FR 38947 ). The Oakridge PM 10 

### data for 1988

- 2014 is outlined in Figure 6

.Oakridge Attainment Date Extension Request Page 7 Figure 6 : PM 10 Trend at the Oakridge WAC Monitoring Station.



### The 1996 Oakridge PM 10 

### attainment plan was successful in not only meeting the PM 10 

### standards on schedule, but also meeting the initial national PM 2.5 

### standards ( 6 5 μg/m 3 

### ) adopted by EPA in 1997 as shown previously in Figure 5 . The long

- term PM 2.5 

### trend, using surrogate monitoring methods to estimate pre

- 1999 PM 2.5 

### , is outlined in Figure 7

. 0 50 100 150 200 250

1988 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010 2012 2014Highest Day PM10 Concentrations (24-hr, ug/m3) 

### Inhalable Particulate Matter (PM10) Trend in Oakridge

Standard
Highest Day
Second Highest DayOakridge Attainment Date Extension Request Page 8 Figure 7 : Long

- Term PM 2.5 Trends at the Oakridge and Eugene

- Amazon Monitoring Stations.



### Subsequent national health studies supported a more protective 24

- hour national PM 2.5 

### health standard, and EPA adopted the 3 5 μg/m 3 

### standard in December 2006. Between 2006 and 2011,

PM 2.5 

### concentrations in Oakridge on worst winter days violated the new 24

- hour national
health standard . The city of Oakridge, LRAPA and Oregon developed and submitted to the EPA a

2012 PM 2.5 

### SIP submittal. The dominant source of PM 2.5 

### in Oakridge on the problem winter days was clearly residential wood combustion (RWC) in wo odstoves and fireplaces, based on

PM 2.5 

### emission inventories, chemical speciation of particulate filter samples, and diurnal PM 2.5 

### concentration fluctuations. Therefore, the new strategies in the 2012 PM 2.5 

### SIP submittal focused prima rily on RWC emission reductions:

• Woodstove change

- out programs;

• Woodstove removal upon sale of home;

• Expanded public education programs;

• Mandatory curtailment program for residential wood burning during periods of air stagnation;

• Enhanced training of police officers on smoke r eading for opacity enforcement; and

• Transportation and fuel

- related emission reduction programs. 0 50 100 150 200 250PM2.5 (24-hr, ug/m3, 98%ile, 3-yr avg) 

## Respirable Particulate Matter (PM 2.5 

## ) in Lane County

Old Standard (1997)

Oakridge

Eugene Amazon

New Standard (2006)Oakridge Attainment Date Extension Request Page 9 

### These programs are all currently being implemented as outlined below. [In some cases, the programs are being further strengthened, as discussed further below under Supplemental Strategies .]

Wood Stove Change

- out P rogram : The Warm Homes wood stove change

- out program
continued in to 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 re ceived 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 1 : Oakridge Wood Change

- out Programs (2009/2010

- 11)



### 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 substantia l reductions in PM 2.5 

### in the future. LRAPA did not apply 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 c hange

- 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”.Oakridge Attainment Date Extension Request Page 10 

### 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 tha t are on the property being sold (including residences, shops, garages, and outbuildings) must be removed at the time of home sale. The Oregon Heat Smart law requires DEQ to confirm residences where owners removed or changed

- out uncertified woodstoves upo n 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 ed ucation or

follow

- up. DEQ has established in rules, penalties for noncompliance and hopes to conduct periodic enforcement sweeps throughout the state.

Public Education : 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 all stations are available in Oakridge.

Articles in the weekly newspaper, the Dead Mo untain 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. People have also received fliers and articles from LRAPA through the city’s water bill mailing list and Lane Electric Co

- op’s Ruralite magazine.

Every spring, the US Forest Service hosts outdoor school in Oakridge for middle school students. LRAPA attends annually with educational material, presentations, and experiments centered on air quality problems specific to Oakridge.

LRAPA’s Public Affair s department has also done several targeted presentations in Oakridge in recent years to publicize the Warm Home Program, elaborate on attainment goals at town hall meetings, and information sessions at the Oakridge Public Library.

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 f uel economyOakridge Attainment Date Extension Request Page 11 

### • 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

Enforcement of Oakridge Ordinance : Oakrid ge 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. Th e 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 hang ers include language from the City Ordinance, including potential fines for a violation.

Contingency Strategies : The following are contingency strategies to fully meet the air quality standards, if it becomes clear that the strengthened ongoing strategie s described above w o uld

not be sufficient to attain the PM 2.5 

### 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 previous 40% opacity limit i n 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).

Th e 2012 PM 2.5 

### SIP submittal projected attaining the standards by December 2014. Oakridge
failed to attain the PM 2.5 

### NAAQS by that date thus triggering the contingency measures in the
2012 SIP submittal. Thus the implementation of the contingency measures began in October

2014.

Supplemental Strategies Currently Underway : The C ity of Oakridge, LRAPA Lane Electric Cooperative (LEC), St. Vincent De Paul of Oakridge (SVDP), the Southern Willamette Forest Collaborative, various elected officials , and other stakeholders have been meeting monthly o n supplemental strategies since October 2014.

The following supplemental strategies are currently being implemented in addition to those included in the 2012 Oakridge PM 2.5 

### attainment plan :Oakridge Attainment Date Extension Request Page 12 

### 1. An expanded city ordinance (#914) was adopted on October 15, 2015, which tightens the exemption process , reaffirms the 20% opacity limits on woodstove s , prohibits unseasoned (>20% moisture) firewood, and clarifies other requirements.

2. 

### The C ity of Oakridge, with LRAPA financial assistance, hired a code enforcement off icer effective November 2015, to focus on air pollution control under Ordinance #914 during the

winter months. The new Oakridge code enforcement officer has been trained and is currently implementing Oakridge air pollution control ordinances with the assis tance of an LRAPA field compliance officer. The Oakridge code enforcement officer and LRAPA field compliance officer teamed up for 56 visitations to residences with visible smoke during a severe air stagnation episode on November 2 8 - December 1, 2015; detailed results have been distributed under separate cover, but this combined field enforcement clearly helped keep particulate levels from worsening during the stagnant air episode as summarized by

the real

- time 24

- hour Air Quality I ndex (AQI) reporting:

3. T he C ity of Oakridge, with LRAPA financial assistance, sponsored a smoke school in
November 2015 on location in Oakridge for police, fire and public works staff in order to be certified to document stack opacity readings.

4. LRAPA exte nded the home wood heating advisory from four months (November

- February)

to eight months (October

- May), effective October 1, 2015

. 5. Lane Electric has continued to provide financial assistance for heat pump installations in the Oakridge area since the submit tal of the 2012 Oakridge Attainment Plan: 15 installations in 2012, 15 in 2013, 22 in 2014, and 31 in 2015 (as of 1 2/10 /2015). Lane Electric enhanced its financial assistance and incentives for ductless heat pumps effective October 20, 2015. The November 2015 Lane Electric Ruralite Magazine included a Winter Wood Heating article for Oakridge prepared by LRAPA.

6. Firewood seasoning programs and other strategies continue to be pursued under the
stakeholder collaborative. The Community Firewood Pr ogram was developed by the Southern Willamette Forest Collaborative to provide affordable seasoned firewood ( consistent with the requirements of Oakridge City Ordinance #914 described above ) to Oakridge and Westfir residents, especially elderly, disabled, and low

- income participants in the Oakridge home wood heating exemption program. The initial 50 cords of firewood hasOakridge Attainment Date Extension Request Page 13 

### been delivered to a covered storage area, split, moisture tested, and made available for sale beginning December 11, 2015, with the assist ance of Inbound LLC. Details and updates on this program and the Collaborative are available from:

Web: http://southwillamette.wix.com/swfc , and

Facebook: https://www.facebook.com/swfcollaborative

. 

### A more detailed review of the supplemental strategies being pursued, prepared by the Southern Willamette Forest Collaborative, is attached.

Planned December 2016 submittal update of the PM 2.5 

### SIP:

LRAPA and ODEQ will develop and submit to the EPA in December 2016, a SIP revision that will include the updated City Ordinances to replace obsolete Ordinances and any new measures applicable to the area. Since the contingency measures in the 2012 SIP subm ittal have been triggered, they become in part, applicable control measures and new contingency measures need to be developed and submitted. A copy of the Supplemental Oakridge SIP Development
Plan for 2015

- 2016 is attached.

Summary of this Request for Extension of the Oakridge PM 2.5 

### Attainment Deadline :

Clean Air Act section 188(d) provides criteria for granting an extension. T wo criteria are required to be met in consideration of the EPA’s granting the request:

1) the state has compli ed with all requirements and commitments pertaining to the area in the applicable implementation plan, and 2) the 98 th 

### percentile PM 2.5 

### concentration in the area in the year preceding the extension year is less than or equal to the standard level.

The above request for a one

- year extension demonstrates that Oakridge meets these two

criteria. The extension would allow the City of Oakridge and LRAPA to determine the adequacy of the new aggressive control measures implemented since October 2014 to achieve

attai nment of standards , and to complete the Supplemental 2015

- 2016 Oakridge SIP Development Plan developed in September 2015.Oakridge Attainment Date Extension Request Page 14 

### Attachments :

1. Oakridge PM 2.5 

### Attainment Plan : December 2012 Submittal as a revision to the State Implementation Plan.

2. LRAPA 2014 Ambient Air Monitoring Network Plan.

3. LRAPA Dashboard Report, October 2015.

4. Lane Electric Cooperative, Enhanced Incentive Program for Oakridge Heat Pumps, August 28, 2015.

5. City of Oakridge Air Pollution Control Ordinance # 914, October 15, 2015.

6. Supplemental Strategies Overview

– Southern Willamette Forest Collaborative, October

2015.

7. Lane Electric Ruralite Magazine

– LRAPA Oakridge Winter Wood Heating Article, November

2015.

8. Supplemental 2015

- 2016 Oakridge SIP Development Plan, September 2015.

MLH:mlh (12/ 0 9 /2015)

## A ttachment 1

Oakridge P M 2

. 5 

## Attainment Plan: December 2 01 2 Submittal as a r ev isio n to

the State I mplementation P lan

# Oakridge Fine Particulate Matter (PM 2.5 

# ) 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

### November 15 , 2012

– Final 2



# Intentionally Blank

### November 15 , 2012

– Final 3 

## Table of Contents

EXECUTIVE SUMMARY

................................ ................................ ................................ ................ 7

T HE 

### O AKRIDGE 

### PM 2.5 

### A TTAINMENT 

### P LAN



### ................................ ................................ .......................... 7

A TTAINMENT OF 

### S TANDARDS



### ................................ ................................ ................................ ........... 8

S TRATEGIES AND 

### C ONTINGENCY 

### P LAN



### ................................ ................................ ................................ 9 Woodstove Curtailment and other Woodstove Strategies

................................ ....... 9 Other Strategies

................................ ................................ ................................ ..... 10 Contingency Plan Elements

................................ ................................ .................... 11

INTROD UCTION

................................ ................................ ................................ ........................ 12

B ACKGROUND



### ................................ ................................ ................................ ............................ 12

W HAT IS 

### PM 2.5 

### ?

................................ ................................ ................................ ........................ 12

N ATIONAL 

### A MBIENT 

### A IR 

### Q UALITY 

### S TANDARDS FOR 

### PM 2.5


### ................................ ................................ ... 12

P URPOSE OF 

### A TTAINMENT 

### P LAN



### ................................ ................................ ................................ .... 12

O AKRIDGE 

### A REA 

### D ESCRIPTION



### ................................ ................................ ................................ ....... 13

H ISTORY OF 

### E FFORTS TO 

### A DDRESS 

### P ARTICULATE 

### M ATTER IN 

### O AKRIDGE



### ................................ ................... 15

W HAT IS IN THIS 

### A TTAINMENT 

### P LAN 

### ?

................................ ................................ .............................. 16
Nonattainment Area

................................ ................................ .............................. 16
Attainment Demonstration

................................ ................................ .................... 17 Implemen tation

................................ ................................ ................................ ..... 18 Attainment Plan Development Process

................................ ................................ .. 18

NONATTAINMENT AREA

................................ ................................ ................................ ........... 19

A MBIENT 

### A IR 

### Q UALITY 

### M ONITORING IN 

### O AKRIDGE



### ................................ ................................ ............ 19

N ATIONAL 

### A MBIENT 

### A IR 

### Q UALITY 

### S TANDARDS 

### (NAAQS)

................................ ................................ .... 20
Annual PM 2.5 

### standard

................................ ................................ ........................... 20

24

- hour PM 2.5 

### standard

................................ ................................ .......................... 20 Additional Monitoring

................................ ................................ ........................... 21

V ERIFICATI ON OF 

### M ONITORING 

### L OCATION



### ................................ ................................ ........................ 22

ATTAINMENT PLAN AND DEMONSTRATION

................................ ................................ ............ 24

E MISSION 

### I NVENTORY



### ................................ ................................ ................................ .................. 24

B ASE 

### Y EAR 

### E MIS SION 

### I NVENTORY 

### (2008)

................................ ................................ ........................ 24
Residential Wood Combustion

................................ ................................ ............... 25
Mobile and Nonroad Sources

................................ ................................ ................. 25
Indust rial Point Sources

................................ ................................ .......................... 25

A TTAINMENT 

### Y EAR 

### E MISSION 

### I NVENTORY 

### (2014)

................................ ................................ .............. 26
Economic Factors

................................ ................................ ................................ ... 26
Growth Rates

................................ ................................ ................................ ......... 27

C OMPARISON OF 

### 2008 T O 

### 2014 E MISSIONS



### ................................ ................................ .................... 27

### November 15 , 2012

– Final 4 

### A TTAINMENT 

### S TRATEGIES



### – E MISSION 

### R EDUCTION 

### A NALYSIS



### ................................ ................................ 27

P ARTICULATE 

### M ATTER 

### R EDUCTION 

### S TRATEGIES 

### (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 Requireme nts

................................ ................................ ......................... 31
Public Education

................................ ................................ ................................ ..... 31 Additional Strategies

................................ ................................ ............................. 32

C URRENT 

### S TRATEGIES 

### 2009

- 2011

................................ ................................ ................................ . 32 Wood Stove Change

- out program

................................ ................................ .......... 32

He at Smart: Stove Removal upon Sale of Home

................................ .................... 32
Public Education

................................ ................................ ................................ ..... 33 Transportation and Fuel

- Related Emissions

................................ ........................... 33

S TRENGTHENED 

### O NGOING 

### S TRATEGIES 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

E STIMATED 

### R EDUCTIONS AND 

### C REDITS FOR 

### F UTURE 

### S TRATEGIES



### ................................ ............................ 36

A TTAINMENT 

### D EMONSTRATION



### ................................ ................................ ................................ ..... 36
Baseline Design Value

................................ ................................ ............................ 36 Background on Precursors

................................ ................................ ...................... 37 Speciated Filter Sample Analysis

................................ ................................ ............ 38
Minor PM 2.5 

### 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

O AKRIDGE 

### A DVISORY 

### C OMMITTEE



### ................................ ................................ ................................ .. 45

P RINCIPAL 

### A UTHORS



### ................................ ................................ ................................ .................... 45

C ONTRIBUTORS



### ................................ ................................ ................................ .......................... 45

### November 15 , 2012

– Final 5 

### T ABLE OF 

### T ABLES


### T ABLE 

### 1: PM 2.5 

### A TTAINMENT 

### D EMONSTRATION



### ................................ ................................ ..................... 9

T ABLE 

### 2: 2002

- 2003 O AKRIDGE 

### M ONITORING 

### S URVEY 

### R ESULTS



### ................................ ............................. 23

T ABLE 

### 3 : 2008 E STIMATED 

### T YPICAL 

### S EASON 

### D AY AND 

### W ORST



### - C ASE 

### D AY 

### PM 2.5 

### E MISSIONS



### . ......................... 24

T ABLE 

### 4 : 2014 E STIMATED 

### T YPICAL 

### S EASON 

### D AY AND 

### W ORST



### - C ASE 

### D AY 

### PM 2.5 

### E MISSIONS



### . ......................... 27

T ABLE 

### 5: O AKRIDGE 

### W OOD 

### C HANGE



### - OUT 

### P ROGRAMS 

### (1993

- 96/2006

- 07)

................................ ............. 30

T ABLE 

### 6: O AKRIDGE 

### W OOD 

### C HANGE



### - OUT 

### P ROGRAMS 

### (2009/2010

- 11)

................................ .................. 32

T ABLE 

### 7 : A NNUAL 

### PM 2.5 VALUES USED TO CALCULATE BASELINE D ESIGN VALUE



### . ................................ ............ 37

T ABLE 

### 8 : C ONTRIBUTION BY SPECI ATED COMPONENTS



### . R ESULTS OF 

### SANDWICH ANALYSIS FOR THE TOP 

### 25% HIGH

CONCENTRATION WINTER 

### (O CT



### - M AR 

### ) DAYS



### . ................................ ................................ ................ 39

T ABLE 

### 9 : B ASELINE AND 

### F UTURE PROJECTED DESI GN VALUES



### ................................ ................................ .... 40

T ABLE 

### 10 : A LLOCATION OF EMISSIO NS AND MODELED CONCE NTRATIONS FOR BASE A ND FUTURE YEARS



### . ............. 42

Table of Figures

F IGURE 

### 1: O AKRIDGE 

### N ONATTAINMENT 

### A REA 

### 2008 W ORST 

### C ASE 

### D AY 

### E MISSIONS



### ................................ ......... 8

F IGURE 

### 2: S PECIAL 

### P ROTECTION 

### Z ONE 

### S URROUNDING 

### O AKRIDGE



### ................................ .............................. 10

F IGURE 

### 3: O AKRIDGE 

### L OCATION



### ................................ ................................ ................................ ........ 14

F IGURE 

### 4: N ONATTAINMENT 

### A REA



### ................................ ................................ ................................ ..... 15

F IGURE 

### 5: PM 2.5 

### A NNUAL 

### S TANDARD COMPARISON CONCENTRATIONS FROM THE 

### O AKRIDGE MONITOR



### . ............ 20

F IGURE 

### 6: PM 2.5 

### 24

- HOUR 

### S TANDARD COMPARISON CONCENTRATIONS FROM THE 

### O AKRIDGE MONITOR



### . ........... 21

F IGURE 

### 7: N EPHELOMETER ESTIMATE D 

### PM 2.5 FOR 

### O AKRIDGE AND 

### W ESTFIR DURING WINTER 

### 2009

- 2010.

........ 22

F IGURE 

### 8: 2002

- 2003 O AKRIDGE 

### M ONITORING 

### S URVEY 

### S ITE 

### M AP



### ................................ .......................... 22

F IGURE 

### 9 : O AKRIDGE 

### PM 2.5 

### E MISSION 

### I NVENTORY FOR 

### 2008 W ORST 

### W INTER 

### D AYS



### ................................ ... 25

F IGURE 

### 10 : S PECIATED 

### C OMPONENTS OF 

### PM 2.5 

### ( USING 

### SANDWICH ANALYSIS 

### )

................................ ......... 38

Image

I MAGE 

### 1: S MOKE INVERSION OVER 

### O AKRIDGE 

### , WHERE THE 

### W ILLAMETTE 

### A CTIVITY 

### C ENTER IS LOCATED



### . T HE

PARTICULATE MATTER T RAPPED NEAR THE SURF ACE BY A TEMPERATURE INVERSION IS CLEARLY VISIBLE



### . ........ 19

### 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 Wat er, Inferred Carbonaceous Material Balance Approach ) 2) Positive Matrix F actorization ( 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

### 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 PM 2.5 

### in September 2006. PM 2.5 

### is fine particulate matter two and a half microns and less in diameter, or about 1/28 th 

### the diameter of a human hair. Also referred to as respirable particulate matter, these tiny p articles are inhaled deep into the lungs where they accumulate and aggravate respiratory conditions, particularly asthma. Fine particulate (PM 2.5 

### 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 O ctober 8, 2009, the Environmental Protection Agency (EPA) issued final area non

attainment designations for the 24

- hour national air quality standards for fine particulate matter (PM 2.5 

### ). 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 PM 2.5 

### contains Oakridge, the small town of Westfir and surrounding area.

The Oakridge PM 2.5 

### Attainment Plan The City of Oakridge has struggled to meet air quality standards. Oakridge was proposed a PM 10 

### “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 PM 2.5 

### standard of 65

μg / m 3



### . Despite progress in improving air quality, the tightening of the PM 2.5 

### standard in 2006 presented yet another challenge.

Local climate and topogra phy 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
fl oor of the city. Figure 1 shows the worst case day 1 

### 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 98 th percentile of the data collected for a given year or an average of the 98 th percentile of three years.

### 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 (PM 2.5 

### ) 2006 standard of 35 μg / m 3


### but complied with the annual PM 2.5 

### standard of 15 μg/m 3 

### in the 2001

- 2011 period. PM 2.5 

### concentrations above the 24

- hour standard during this period are linked to wintertime inversions and high emissions.

The main purpose of the Oakridge PM 2.5 

### 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 PM 2.5 

### standard. This attainment plan fulfills fe deral 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 volun tary woodburning curtailment measures to mandatory, Prohibited burning garbage in woodstoves and fireplaces, Incorporated a 40 % opacity limit on chimneys, Incorporated the PM 2.5 

### standard into the program, and Required the removal of uncertified woodstove s 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

### 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 da ily 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

rest rictions.

The use of these strategies and others identified by an advisory committee should further
reduce ambient concentration of PM 2.5 

### below the national health

- based standard by 2014. The
estimated ambient concentrations for both the annual and the w orst 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 200 8, 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/m 3 

### 28. 2 μg/m 3



### Federal Standard 35 μg/ m 3 

### 35 μg/ m 3

Table 1 : PM 2.5 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 ordi nances 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 chang e

- out programs to encourage removal of noncertified

stoves

.

### 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 h as 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

### November 15 , 2012

– Final 11 Contingency Plan Elements


### Th e 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 PM 2.5 

### standards by 2014 and or to maintain compl iance 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 restrictio ns 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 p roposed standard, LRAPA estimates that Oakridge will meet a tightened annual standard of 12 μ g/m3.

### November 15 , 2012

– Final 12 

## INTRODUCTION

Background This plan addresses the 24

- hour and the annual ambient air quality standards for PM 2.5 

### as defined in the federal Clean Air Act. In September 2006, the U.S. Environmental Protection Agency (EPA) strengthened the daily (24

- hr) PM 2.5 

### (fine particulate) standard by lowering the
level from 65 g/m 3 

### to 35 g/m 3 

### and retained the annual PM 2.5 

### standard of 15 g/m 3



### . Areas in
violation of the PM 2.5 

### 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 PM 2.5 

### standard. The Lane Regional Air

Prot ection 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 PM 2.5 

### ? 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 micr oscope. 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 (PM 2.5 

### ) generally re sult from fuel combustion from residential fireplaces and woodstoves, pile and forest burning, industrial facilities, and motor vehicles. Coarse particles (PM 10 

### ) are generally emitted from sources such as vehicles traveling on paved and unpaved roads, mat erials 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 c ardiopulmonary disease such as asthma, and children.

National Ambient Air Quality Standards for PM 2.5 

### EPA has established National Ambient Air Quality Standards (NAAQS) for PM 2.5 

### at 35 micrograms per cubic meter (μg/m 3 

### ) for a daily (24

- hour) standard and 15 μg/m 3 

### as an annual
standard . Any value monitored above these levels, as defined by federal rules and guidance, is
considered an exceedance. EPA uses the 98 th 

### percentile of the 24

- hr PM 2.5 

### within any given year and averages it over three calendar year s. An exceedance of the average 98 th 

### percentile over three years greater than 35 μg/m 3 

### 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 standa rd, 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 re turn the Oakridge Nonattainment Area (NA) to attainment for PM 2.5 

### (state

### 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 PM 2.5 

### and maintains the annual standard for PM 2.5 

### . This document complies with the applicable 1990 Federal Clean Air Act (CAA) requirements and Environmental Protection Agency (EPA) guidance and policies. The at tainment plan provides strategies to meet the PM 2.5 

### 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 i nstruments 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 f or 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 Willamett e 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 Wi llamette City. Figure 3 shows the location of Oakridge in Lane County.

### November 15 , 2012

– Final 14 Figure 3 : Oakridge Location

### 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 si tuated 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 i ts 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 da ys during periods of air stagnation. Oakridge was proposed a PM 10 

### non

- attainment

area in December 1993

, effective on January 9 , 1994. PM 10 

### is defined as particulate matter with an aerodynamic diameter less than or equal to a nominal 10 micrometers as meas ured by

### 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 forma l PM 10 

### 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 ci ty 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
residentia l wood burning advisory program, further reduced winter time PM 10 

### 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 PM 10 

### standards from 1994 to present.

EPA revised the particulate standard in 1997 to include PM 2.5 

### and established a daily st andard
of 65 μ g/m 3



### . LRAPA began monitoring fine particulate matter (PM 2.5 

### ) concentrations in 1998. The original PM 10 

### strategies included in the 1996 attainment plan were so successful in maintaining clean air that Oakridge also met the fine particulate (P M 2.5 

### ) standard.

In 2006, EPA modified the PM 2.5 

### standard, cutting the threshold for the 24

- hour exceedance day roughly in half to 35 μg/m 3



### . Oakridge has not yet been able to meet this new daily PM 2.5 

### standard, so continued progress is need to further reduce particulate emissions. LRAPA has
measured PM 2.5 

### at the same location in the Oakridge (Willamette Activity Center) since 1998
and PM 10 

### since 1989. LRAPA has also operated a nephelometer in Oakridge since 1989 which makes it possible to estimate PM 2 .5 

### during 1989

- 1998. Many of the same pollutant sources for

PM 10 

### are the same for PM 2.5


### .

Between 2006 and 2011, PM 2.5 

### 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 PM 2.5 

### 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 gro wth. If the community
fail s 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.

### 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 ea ch 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 qual ity 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 PM 2.5 

### air quality health standards by 2014:

• W oodstove change

- out program s

. A model is in place to replace non

- certified woodstoves with heat pumps, pellet sto ves, or high

- efficiency certified woodstoves

. T he current funding has been committed, and th e 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 qual ity and meteorological forecasts during November

- F ebruary.

• 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 Octob er; 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 ga rbage 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 PM 2.5 

### standards by 2014 and the community
will continue to meet the standard into the future.

### November 15 , 2012

– Final 18 

### The primary source of PM 2.5 

### in Oakridge is residential wood heating. The most serious PM 2.5 

### 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 evenin g 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 PM 2.5 

### 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 PM 2.5 

### 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.

### 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 PM 10 

### emissio ns, when EPA revised the PM standard in 1997 to include PM 2.5 

### , Oakridge was in compliance. Despite the se aggressive efforts , in 2006 when the PM 2.5 

### standard was revised Oakridge found itself in violation of the 24

- hour PM 2.5 

### standard.

Ambient Air Qualit y Monitoring in Oakridge The Oakridge area has one particulate (PM 2.5 

### ) 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 PM 10 

### and since 1998 for PM 2.5 

### . 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 nonatt ainment 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 inv ersion is clearly visible.

### November 15 , 2012

– Final 20 

### National Ambient Air Quality Standards (NAAQS) As mentioned previously, in 2006 the EPA revised the PM 2.5 

### standard to more accurately reflect
the latest health information. EPA revised the 24

- hour standard from 65 μg/m 3 

### to 35 μg/m 3



### , and kept the annual standard at 15.0 μg/m 3 

### . EPA determines compliance with the PM 2.5 

### standards based on averaging air quality measurements both annually and on a 24

- hour basis.

Annual PM 2.5 standard 

### The annual standard for PM 2.5 

### is met whene ver the three year average of the annual mean

PM 2.5 

### concentrations for a designated monitor is less than or equal to 15.0 μg/m 3 

### . Oakridge has met this standard since monitoring started at Willamette Activity Center ( Figure 5 ).

Figure 5 : PM 2.5 Annual Standard comparison concentrations from the Oakridge monitor.

24

- hour PM 2.5 standard 

### The 24

- hour standard for PM 2.5 

### is met whenever the three year average of the annual 98 th 

### percentile of values at a monitoring site is less than or equal to 35 μg/m 3 

### . The 98 th 

### percentile is
a concentration below which 98% of observations fall. This value is used for the 24

- hour
standard inste ad 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 PM 2.5 

### standard of 65 μg/m 3



### . However in 2006, when EPA revised the standard to 35 μg/m 3 

### , Oakridge violated the 24

- hour standard. The three year average 98 th 

### 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/m 3 

## Oakridge PM 2.5 

## : 3

- year Average of Annual Means

Willamette Activity Center Annual PM2.5 Standard

### November 15 , 2012

– Final 21 Figure 6 : PM 2.5 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 PM 2.5 

### concentrations there, and relative difference from the Willamette Activity Center monitor. Several saturation samplers and a Nephelomete r were used for this purpose. Figure 7 shows
the relative PM 2.5 

### concentrations, as a function of Nephelometer light scattering, of Westfir and Oakridg e. 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/m 3 

## Oakridge PM 2.5 

## : 3

- year Average of Annual 98 th 

## Percentile

Willamette Activity Center 24

- Hour Standard

### November 15 , 2012

– Final 22 Figure 7 : Nephelometer estimated PM 2.5 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 PM 2.5 

### monitoring site generally represents peak level PM 2.5 

### concentrations within Oakridge, and is the most appropriate location for a PM 2.5 

### monitor. The one year, six site m onitoring survey was
conducted in 2002

- 2003, and is attached in Appendix A. Results are summarized in Figure 8
and Table 2

.

Figure 8 : 2 002

- 2003 Oakridge Monitoring Survey Site Map

### November 15 , 2012

– Final 23

n (max 103) Capture

rate Annual

mean μg/m 3 Maximum
value μg/m 3 n > 15 μg/m 3 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 PM 10 

### 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 PM 2.5 

### concentrations in Oakridge. In addition, the Willam ette Activity Center monitor also represents an area where people live, work, and play, reconfirming the monitor location is the most appropriate for Oakridge.

### November 15 , 2012

– Final 24 

## ATTAINMENT PLAN AND DEMONSTRATION

Emission Inventory An emission inventory consists of emission estimates from sources that emit PM 2.5 

### 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 PM 2.5 

### in Oakridge include minor industry, on

road 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 2 008 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 PM 2.5 Emissions.



### The emissions inventory on worst winter days is of most interest since the PM 2.5 

### concentrations measured in Oakridge do not meet the current 24

- hour PM 2.5 

### standard and the peak PM 2.5 

### 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 w inter days, as
illustrated in Figure 9

.

### November 15 , 2012

– Final 25 Figure 9 : Oakridge PM 2.5 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 inform ation 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 PM 2.5 

### from motor vehicles were calculated by Lan e 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

### November 15 , 2012

– Final 26 

### Attainment Year Emission Inven tory (2014) The attainment year inventory is an estimation of emissions for the year that the area is expected to have attain ed the PM 2.5 

### standard. It includes projected emissions for the attainment year based on a number of different factors. Growth ra tes 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 wo odstoves 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 reduc tion 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 PM 10 

### standards and the initial (1997) PM 2.5 

### standards on schedul e. 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 p rohibiting 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 recreation

oriented model. The decline in the harvesting a nd 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% b etween 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 jo bs 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 Oakri dge Industrial Park.

### 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 model ing 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 PM 2.5 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 inc reases 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 ca tegory 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 PM 2.5 

### standard. These strategies are expected to improve air quality and meet the PM 2.5 

### standard by the required 2014 attainment date. These strategies

### 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 app licable 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 precurso rs 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 no t 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 attainme nt 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

- 20 08 ) The strategies and regulations implemented between 1989 and 20 08 resulted in a reduc tion of

PM 2.5 

### 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 updat ed to
address the current PM 2.5 

### 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 e missions.

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 Ordinanc e #8 89 

### LRAPA and t he City of Oakridge initiated a voluntary home wood heating advisory program in 1989 after air quality data showed Oakridge exceeded the federal PM 10 

### standard on numerous occasions. Five years later, on January 20, 1994, EPA officially decla red Oakridge a PM 10 

### non

attainment 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 14 th 

### 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,

### November 15 , 2012

– Final 29 

### • Prohibited burning garbage in woodstoves and fireplaces,

• Incorporated a 40% opacity limit on chimneys,

• Incorporated the PM 2.5 

### 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 woo d heating ordinance to reflect the tightened PM 2.5 

### standard of 35 μ g/m 3



### . 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 o r 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 emission s 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 Novemb er 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 automati c phone “callware” system is activated when a ir quality is deteriorating and long periods of stagnant conditions are
forecast. The phone system calls all number s 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 PM 2.5 

### levels are forecast by LRAPA to be less than 25 g/m 3 

### , and good smoke dispersion
conditions are forecast. "Yellow" advisories are posted when PM 2.5 

### levels are forecast by LRAPA to be equal to or greater than 25 g/m 3 

### , but less than 30 g/m 3 

### , 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" advisor y is posted when PM 2.5 

### levels are forecast to be equal to or greater than 30 g/m 3 

### , and the forecast is for marginal or poor smoke dispersion conditions. During a R ed a dvisory

, 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. Resident s with exemptions may use any solid fuel heating dev ice

. Exemptions are based on sole source of heat or economic need

. During Stage II Red II advisory, when PM 2.5 

### 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 op erated a solid fuel burning device unless: t he person has been granted an exemption to use the device by the City

### November 15 , 2012

– Final 30 

### Administrator; or t he 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 Cod e 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 PM 2.5 

### standar d. The open burning restrictions provide a more protective measure to avoid additional contributions to the particulate levels.

Woodstove C hange

- out P rograms 

### Since 1993, LRAPA has administered woodstove change

- out programs to help residents replace old, u ncertified 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 w as 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
h ome 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,

### 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 PM 10 

### emissions from road sanding during winter months, t he Oregon Department of Transportation (ODOT ) signed a letter of agreement regarding using anti

- icing agents as an alternative to sand on Highway 58 runn ing 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

PM 2.5 

### reductions.

Smoke Man agement 

### 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 w ithin the

nonattainment area. Between December 1 and February 15, no presc ribed 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 parkin g lots.

Industrial Requirements 

### Within the designated Oakridge PM 2.5 

### nonattainment area, new major sources and major modifications of a nonattainment pollutant, including PM 2.5 

### precursors SO 2 

### or NO X 

### , are required to meet LAER control technology. Industri al 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 pe rformance 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

### 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 affair s 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, conduct s 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

- 201 1

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 th e 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

### November 15 , 2012

– Final 33 

### sale. The Oregon Heat Smart law req uires 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 p romote 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 station s 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 fu el standard for biodiesel

– 5% Local programs :

 I mplementing 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 PM 2.5 

### 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 Ca se Day NOx Emissions of 562.3 pounds per day.

### November 15 , 2012

– Final 34 

### Strengthened Ongoing Strategies in 20 12

- 2014 While the current strategies in place indicate Oakridge will reach attainment with the PM 2.5 

### standard by 2014, to ensure compliance, a number of future strategies were identified by a local advisory committee

. The advisory committee evaluate d 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 stra tegies 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

PM 2.5 

### 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 regu lations) 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

.

Woodst ove C hange

- out s 

### 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. I mplementation of this strategy may provide substantial reductions in PM 2 .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% o f 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 d ays. LRA P A has provided a s eries of door hangers that can be left at a residence with an excessively smoky chimney. The door hangers include language from the C ity O rdinance, including potential fines for a violation.

Enhancements to Key Ongoing Strategies 

### The Oakridge Advi s o ry 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 a nd outreach, including multiple versions of educational door

hangers that can be distributed to all homes in Oakridge.

• Training and certification of police on smoke reading and opacity limits
enforcement.

### November 15 , 2012

– Final 35 

### • Enforcement with citations as appropriate for viola tions 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 a ll 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 PM 2.5 

### standards by 2014 and or to maintain compliance with the standards through 2024 and beyond:

• Stricter opacity limit on all green or yellow a dvisory 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 emission s 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 Oakridge

Westfir area are minor industrial sources of PM 2.5 

### emi ssions. 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 PM 2.5 

### emissions and contribute less than 1% to the base ye ar emission inventory. These two minor sources are well below the LRAPA significant emission rate (SER) for PM 2.5 

### 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 PM 2.5 

### standard . For example, the worst

- day PM 2.5 

### concentrations need to be reduced by about one microgram per cubic meter ( μg/m 3 

### ) per year in order to meet the

PM 2.5 

### standard by 2014 (i.e., reduced from 39.5 μg/m 3 

### in the 2006

- 2010 baseline period to 35

### November 15 , 2012

– Final 36 

### μg/m 3 

### 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/m 3 

### , 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 PM 2.5 

### concentrations are a problem.

Estimated Reductions and Credits for Future Strategies The emission changes between 2008 and 2014 are due to the combination of incr eases 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

- ce rtified 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 actu al 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 ca pacity 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 PM 2.5 

### standard by 2014 through the implementati on 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

Acti vity 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 PM 2.5 

### . The baseline design value is a statistic , expressed as a concentration that describes
the PM 2.5 

### 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 O 3 

### , PM 2.5 

### , and Regional Haze”. PM 2.5 

### measurements fr om 2006 to 2010 are used to calculate the design

### November 15 , 2012

– Final 37 

### value of 39.5 μg/m 3 

### (see Table 7 ). Detailed methods on the baseline design value calculation

are in Appendix G

.

Year PM 2.5 (μg/m 3 )

2006 38.6

2007 42.7

2008 38.7

2009 41.3

2010 33.0
Baseline DV 39.5

Table 7 : Annual PM 2.5 values used to calculate baseline design value.

Background on Precursors 

### Speciated PM 2.5 

### 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 PM 2.5


### . 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 PM 2.5


### . In consultation with EPA, LRAPA chose to adopt these pe rcent contributions as a conservative assumption for the Oakridge NAA demonstration. Because all secondary aerosols were determined to be minor contributors to
total PM 2.5 

### , these components and their concentrations are held constant in the rollback model and assigned a Relative R e sponse F actor (RRF) of 1.0 , assuming future year precursor concentrations are constant or declining

. The precursor emissions to secondary aerosols, including NO X 

### , SO 2 

### , 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 Cente r was conducted by EPA Region 10 to identify likely sources of speciated PM 2.5


### . 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 formu lation, 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 contri bute to PM 2.5 

### 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 secon dary inorganic aerosols, such as sulfate (1%) and nitrate (0.4%). The SANDWICH analysis, and the

### 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 i n Oakridge are
considered to be those that emit direct emissions of PM 2.5


### . As a result, LRAPA has focused its strategies for the attainment demonstration on these sources.

Figure 10 : Speciated Components of PM 2.5 (using SANDWICH analysis)

Speciated Filter Sample Analysis



### PM 2.5 

### 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 PM 2.5 

### speciation monitoring at the Willamette Activity Center location. Total PM 2.5 

### 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 c o

- locate a speciation sampler that allows the breakdown of the total mass into different chemical species.

The total mass of PM 2.5 

### 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 PM 2.5 

# Composition

Sulfate

Nitrate

Organic Carbon

Elemental Carbon

Ammonium

Other

### 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 PM 2.5 

### . The SANDWICH approach uses a combination of speciation measurements and modeled estimates to represent FRM PM 2.5 

### measurements. The goal is to recon struct the measured speciated components so that they add up to the
measured FRM PM 2.5 

### mass. Table 8 shows the results as percent contribution by a speciated

componen t (sulfates, nitrates, organic carbon (OC), elemental carbon (EC), ammonia (NH 3 

### ), 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 PM 2.5 C omponents 

### 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 PM 2.5 

### 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 s ulfate, 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 S PECIATE 4.2 and 4.3 databases . The following source categories are included in the analysis:

### November 15 , 2012

– Final 40 Rollback Model 

### In evaluat ing the appropriate modeling analysis of PM 2.5 

### 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 intens ive 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 o ccur.

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 p articulates 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 conce ntration. 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 i n 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/m 3



### .

Year Baseline DV

PM 2.5 (μg/m 3 ) Future DV

PM 2.5 (μg/m 3 )

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/m 3 

### ) 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.

### 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 woodst ove 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 PM 2.5 

### 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 PM 2.5 

### concentrations by 2.1 μg/m 3 

### 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/m 3 

### PM 2.5 

### during 2005

- 2011). This will reduce RWC emissions by
131 lb /day and reduce future PM 2.5 

### concentrations by 8.7 μg/m 3 

### 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 Combu stion 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 fo r 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 dispersi on 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 loc ations

### 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, a nd 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

st andard. 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 t hese 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 concentra tions for b ase 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 PM 2.5 

### standards and be implemented immediately. EPA requires that any contingency measures must equal one year equivalent of reasonable further progress (RFP).

### November 15 , 2012

– Final 43 

### In Oakridge, the worst

- day PM 2.5 

### conce ntrations need to be reduced by about one microgram per cubic meter ( μg/m 3 

### ) per year in order to meet the PM 2.5 

### standard by 2014 (i.e., reduced
from 39.5 μg/m 3 

### in the 2006

- 2010 baseline period to 35 μg/m 3 

### by the 2014 attainment date).
Therefore the RFP req uirement in Oakridge would equal about one μg/m 3 

### of further reduction.

The Oakridge PM 2.5 

### 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 PM 2.5 

### 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 t o 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 enforcemen t 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 nu mber of days above 25 μg/m 3 

### PM 2.5 

### 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/m 3 

### in 2014. If the mandatory cu rtailment program is increased from an average of 20 days per year (based on 30 μg/m 3 

### PM 2.5 

### ) to 30 days per year (based on

25 μg/m 3 

### PM 2.5 

### in the contingency plan) this will further ensure that the full 8.7 μg/m 3 

### is achieved. The contingency measures for s tronger 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 emission s by 44 lb/day and reduce PM 2.5 

### concent rations by

an additional 2.9 μg/m 3 

### on worst case days. Using these contingency strategies to increase curtailment effectiveness to 50% is expected to reduce RWC emission s by 87 lb/day and reduce PM 2.5 

### concentrations by

5.8 μg/m 3 

### on worst case days.

### November 15 , 2012

– Final 44 

### Either of these contingency measures would more than achieve the one μg/m 3 

### target needed
to meet the EPA RFP test.

If Oakridge meets the PM 2.5 

### standard by the EPA Clean Air Act 2014 deadline, the contingency plan will not be enacted. If Oakridge does n ot meet the PM 2.5 

### 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 PM 2.5 

### concentration was determined to be an Exceptional Eve nt based on EPA's Exceptional Events Rule, as flagged by ODEQ and concurred by EPA, no further action may be
needed.

### 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 C itizen James Coey Private C itizen Rob DeHarpport Private C itizen
Herb Hilton Private C itizen
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

Princi pal 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

## A ttachment 2

LRAPA 201 4 Ambient Air M on itoring Netwo rk Plan

# Monitoring and Data Analysis Section

201 4 Ambient Air Monitoring Network Plan

Ju ly 2014

Lane Regional Air Protection Agency

1010 Main Street Springfield, OR 97477 Attachment 2 Oakridge Extension Request 2015[ 1 ]

Introduction

In accordance with federal Environmental Protection Agency (EPA) regulation, 40 CFR Part 58, Subpart B §58.10, t he Oregon Department of Environmental Quality (ODEQ ) is required to

annu a lly submit to EPA by July 1, a S tatewide Air Monitoring N etwork P lan. This document is prepared by the Lane Regional Air Protection Agency (LRAPA) and submitted to Oregon DEQ for comment and inclusion in the Statewide Air Monitoring Network Plan. The plan s are used to determine if the air monitoring network meets EPA, state and local m onitoring objectives as defined in CFR Part 58, Appendix D and to propose modifications to the network for the following year. The regulation requires that the statewide plan be posted for public comment 30 days prior to submis sion. The current LRAPA air monitoring network plan will be made available to the public on LRAPA’s website http://mdas.lrapa.org and the statewide plan will be available
at: http://www.oregon.gov/deq/aq C omments regarding the LRAPA Air Monitoring Network Plan can be sent to :

Jerry Boyum Technical Services Manager Lane Regional Air Protection Agency 1010 Main Street Springfield, OR 97477 jboyum@lrapa.org

A detailed air quality data summary is produced annually as part of the LRAPA Annual Report which is also available at: http://www.lrapa.org and the Orego n Department of Environmental Quality (ODEQ) Annual Air Quality Data Summary, available at: http://www.deq.state.or.us/aq/forms/annrpt.htm

.
Monitoring Network Overview

The Lane Regional Air Protection Agency (LRAPA) monitors air quality to help protect public health and the environment. Air monitoring is required by regulation and is used to determi ne compliance with the EPA National Ambient Air Quality Standards (NAAQS )

. Other important uses of the air monitoring data includes the production of a daily Air Quality Index (AQI) report, daily air quality forecast reports, support of open burning, woodstove and agricultural field burning management programs. The data is als o used in support of local Air Quality Maintenance and Non

- Attainment Plans and for short and long

- term health risk assessments, and tracking long

- term trends in air quality.

LRAPA / Oregon DEQ Relationship

- LRAPA’s monitoring effort is a subset of the ODEQ statewide air monitoring network. EPA considers both agencies a single Primary Quality Assurance Organization (PQA O ), and thus, ODEQ is responsible for overall Quality Assurance and transmittal of data to EPA ’s AQS database

. ODEQ is also responsible for submitting an Annual Air Monitoring Certification Letter to EPA for all data collected including those sites operated by LRAPA. The Air Monitoring programs of both agencies have a long hi story of cooperative involvement, and routinely cooperate on p rojects, and share information and

resources. LRAPA works closely with ODEQ to tailor the LRAPA air monitoring network to meet national, state and local monitoring needs. Statewide uniformity of sites and data quality is achieved by both agencies correct ly following EPA criteria in 40 CFR Part 58 and operating under a common set of procedures. A system of common Quality Control checks and independent audits measures and assures uniform statewide data quality. LRAPA is presently[ 2 ]

following all pertinent ODEQ Quality Assurance Project Plans and Standard Operating Procedures (QAPP s /SOPs).

Program Goals

- The Clean Air Act requires the U.S. EPA to set standards for “criteria pollutants”

- six commonly occurring air pollutants. These s tandards, known as the National Ambient Air Quality Standards (NAAQS), are national targets for acceptable concentrations of each of the criteria pollutants. The criteria pollutants are:

 Carbon Monoxide

 Lead

 Nitrogen Dioxide

 Particulate Matter (PM 10 , and P M 2.5 )

 Ozone

 Sulfur Dioxide

SLAMS

- The Clean Air Act also requires each state to develop State Implementation Plans (SIPs). SIPs describe the programs a state will use to maintain good air quality and to meet the NAAQS in areas of poor air quality. One o f the required elements of a SIP is a carefully planned network of fixed monitoring stations that measure ambient concentrations of the criteria pollutants. The primary mission is to measure the short

- term and long

- term exposures of people where they live, work and play.

The Clean Air Act places the responsibility on states to establish and operate these monitoring networks following strict guidelines and to report the data to EPA. Sites that make up t hese networks are called SLAMS (State and Local Air Monitoring Stations). LRAPA operates five of these sites in Lane County.

LRAPA is not required to monitor for several of the criteria pollutants because past studies and a lack of significant sources assure compliance with the NAAQS. In Lane County we operate a SLAMS network that monitors t wo of the criteria pollutants:

 Particulate Matter (PM 10 , and PM 2.5 )

 Ozone

The goals of the SLAMS monitoring network are to collect information for a number of purposes:

 To determine if an area is in compliance with the NAAQS

 For use in models and strategies that are used to control pollutant levels

 To provide information to the public about local air quality

EPA gives states and localities flexibility in determining the size of their monitoring networks bas ed on their data needs and available resources. The main objectives of the network are to determine:

 The highest concentration expected to occur in the area covered by the network

 Representative concentrations in a reas of high population density

 Public information and Air Quality Index (AQI) reporting

 The impact of significant sources or source categor ies on ambient pollution levels

 General background concentration levels

 The extent of regional pollutant transport among populated areas and i mpacts in mor e rural and remote areas (such as visibility impairment and effects on vegetation)[ 3 ]

Due to budget constraints and program priorities all monitoring objectives are not always met. In practice the most common site selection is a compromise between highest c oncentration and representative concentration in areas of high population density. We call these sites maximum population exposure sites.

SPMs

- To supplement the SLAMS network and meet specific needs of agency programs, LRAPA opera tes equipment designate d as SPM s (Special Purpose Monitors). These monitors may be deployed for short or ongoing terms, and operate for various reasons:

 Supporting emission reduction strategies such as woo d stove curtailment and open burning advisories

 Providing real

- time partic ulate data

 Investigating citizen complaints or impacts from a unique source

 Collecting meteorological data for air shed and point source modeling, complaint response and enforcement

 Confirm and collect information on existing and proposed fixed site locati ons

 Maintaining long term data trends

An example of this type of monitoring is the array of nephelometers and meteorological sites we operate. Nephelometers are optical instruments capable of providing real

- time indications of particulate matter. Meteor ological stations also support program activities, and in addition to wind speed and direction may measure parameters such as atmosphere stability, solar radiation, barometric pressure and rainfall.
Data Processing

- To view, process, and store aerometric data LRAPA operates a comprehensive data acquisition system. The system retrieves data from the fixed

- site monitoring network on a near real

- time basis. The data is immediately available to help make program decisi ons, and is also made available to the public on the LRAPA, Oregon DEQ, and EPA websites. As mentioned above, ODEQ is the delegated reporting agency for all Oregon aerometric data . LRAPA submits all validated data to ODEQ in less than 30 days after each quarterly reporting period. ODEQ performs final QA and transmittal to EPA ’s AQS database

. Quality Assurance and Quality Control (QA /QC )

– To make sure all data collected is of the highest quality, network operation and data handling are conducted under a rigorous quality assurance program (QAP). LRAPA has fully implemented all pertinent Quality Assurance requirements documented in EPA approved ODEQ Quality Assurance Project Plans (QAPPs). The system of rigid procedures, control checks, and audits assures data of the highest precision and accuracy, and assures data gathered statewide is of equal and known quality. As mentioned above, ODEQ has ultimate responsibility for overall Quality Assurance of the collected data statewide, and receives direct funding to routinely perform QA audits on all sites including the LRAPA network. The QA section of the ODEQ Laboratory performs these important in dependent audits. This group operates under separate management from the ODEQ Air Quality section, and has their own procedures, audit equipment, and transfer standards. The ODEQ QA staff also is responsi ble for traceability of this equipment to the Lab’s NIST standards. Additional routine QC checks and audits as outlined in QA project plans and standard operating procedures are performed by LRAPA personnel. LRAPA also participates with ODEQ in the EPA funded Performance Evaluation Program audits when available.
Additionally , all dat a collected is checked for accuracy, reviewed for operational flags, data completeness, and other problems prior to submittal to ODEQ. Results of the QA/QC audits and checks are used to assess data completeness , precision, and accuracy, and if necessary i mplement corrective actions. These quality measurements show no significant difference[ 4 ]

between sites operated by ODEQ and LRAPA, which assures consistent data quality statewide. Typically 20

- 25% of monitoring resources is expended on QA.

Air Toxics

- The potential impacts of airborne toxics is of increasing concern. Air toxics present the greatest monitoring challenge due to the great number of potential substances, sampling difficulties, testing expense, and the lack of promulgated standards. For e xample, a single day (24hr) toxics measurement utilizes several collection and analytical methods resulting in concentrations for as many as 150 substances including volatile, semi

- volatile, and metallic compounds. The cost per sample can exceed $1500, wh ich translates to over $9 0,000 per year to operate a single site on an every sixth day schedule . By comparison collecting a year of PM 2.5 data costs $20,000.
Thus far, most air toxics monitoring in Lane County has been funded by grants. Using grant funds secured by Oregon DEQ, LRAPA was able to conduct toxics sampling at the Eugene

– Amazon Park Site for 3

- years beginning in 2002. In FY 2005

- 06 and 2006

- 07 LR APA was able
to re

- program some unused EPA grant funds to continue the sampling on a limited basis ( 1 sample every 12 th day with partial analysis ). On June 30, 2007 LRAPA resumed 1 sample every sixth day sampling with local funding. In 2008 ODEQ funded the analysis work due to a local dues shortfall. During 2010 local and supplemental funding from EPA Region 10 allowed LRAPA to operate a year long two

- site air toxics study through April 2011

. Due to funding issues no air toxics sampling taken place since April of 2011. Funding has been set aside for possible air toxics samplin g in 2015.

Network Description by Pollutant
Carbon Monoxide, CO (EPA parameter #42101)
LRAPA has monitored CO in support of the State Implementation Plan and EPA approved local CO Maintenance Plan for decades. Current CO l evels are well below the NAAQS and have been for many years . Because of the low CO levels and the pending loss of access to the monitoring location the last remaining CO monitoring site was shut down at the end o f 2010.
Ozone, O3 (EPA parameter #44201)

L RAPA’s ozone monitoring network meets the monitoring objectives outlined in 40 CFR Part 58 Appendix D by monitoring at two locations. One site is located to measure the maximum downwind concentration, and the ot her is positioned for determination of the concentration in an area of high population density.

Particul ate Matter, PM 10 (EPA parameter #81102)

LRAPA monitors PM 10 at two locations as required by State Implementation and Maintenance Plans for Eugene and Oakridge.

Particula te Matter, PM 2.5 (EPA parameter #88101)

L RAPA measures PM 2.5 with Federal Reference Method (FRM) samplers at 5 loca tions. Operation of two sites are funded directly by EPA through a statewide PM 2.5 monitoring allocation. These sites ar e used for determination of compliance with NAAQS. LRAPA continues to operate one site in Springfield that was originally funded by EPA, to maintain a record of the Springfield urban levels. Tw o Special Purpose Monitors (SPM s) are operated for informatio nal purposes. One in northwest Eugene is at a PM 10 monitoring site (HWY99) and is being used to collect PM

- “coarse” data. The second SPM site is located in Cottage Grove to assess wintertime wood stove impacts.[ 5 ]

Particulate Matter, PM 2.5 Speciation

In an effort to better understand PM 2.5 emission sources, LRAPA has operated a PM 2.5 Speciation sampler in Lane C ounty since 2001. This activity has been funded directly by EPA,

an d was moved from Amazon Park to Oakridge (Willame tte Activity Center) in the s ummer of 2009 to provide valuable information for control strategy development in the Oakridge non

attainment area. At the end of 2012 LRAPA moved the speciation monitors to the PM 10 SLAM site, HWY99, in west Eugene.

Particulate Matter, Real Time PM 2.5 (EPA Parameter 11203)

At five particulate monitoring sites LRAPA operates optical opacity (visibility) measuring devices known as nephelometers to provide real time estimates of PM 2.5 . Correlation with Federal Reference Method (FRM) particulate samplers is established for each site, and equations are used to convert nephelometer outputs into PM 2.5 estimates. These estimates are used to calculate local Air Quality Index (AQI) values and are also transmitted to EPA’ s AIRNow website. This real

- time informat ion is also used to support other program activities such as woodstove and open burning curtailment, and field burning and wildfire impact assessments.

L RAPA has operated two Federal Equivalen t Method (FEM) Beta Attenuation PM 2.5 Particulate monitors (BA M) to test for acceptability as replacements for filter based FRM samplers since 2009 . One unit is installed at the WAC site in Oakridge and the other unit is at Amazon Park in Eugene. At the beginning of 2013 LRAPA began full time operation of another B AM at the HWY99 site. LRAPA is not comfortable using the FEM samplers as replacement for the FRM samplers at this time . The FRM vs. FEM data continues to be inconsistent , at times the data meets the E PA guidelines for an F EM sampler but at other times it is well outside the acceptable limits to meet the FEM standard. LRAPA will continue to operate and compare the FEM and FRM samplers and work with the vendor to improve the data correlation.

Hazardous Air Pollutants (HAPs )

In coordination with ODEQ, LR APA operated an air toxics (HAPs) site at Eugene Amazon Park from 2002

– April 2011 . Measuring HAP s is the most expensive air monitoring activity by far, and the funding for this activity is unstable. To date most of the monitoring costs have been

covere d under a series of EPA Grants, awards and OD EQ analytical support. Over 150 compounds are analyzed for on each sample day, although not all are HAPS.
Supplemental funding from EPA Region 10 allow ed us to operate two air toxics monitoring sites in 2010. Beginning in April 2010 and running through April 2011 a site in northwest Eugene (Peterse n Park) ran on the same schedule as ou r long

- term site in Amazon Park . The data collected gave us insight in to the spatial variation of air toxics in the metropolitan area. Even though the agency lists HAP s as a program priority, HAP s monitoring is not mandated, and thus, continued operation of these site s is based on available funding. As of 201 3 there is no funding available to for HAP s sampling. All HAPs monitoring was discontinued in April of 2011.
Funding has been set aside for possible HAPs sampling in 2015. The preliminary plan is to sample for HAPS at the Amazon Park and HWY99 sites in concert with tr ace level CO monitoring for possible correlation with some of the HAPs. If a reasonable correlation is found

, trace level CO monitoring can continue after the HA Ps sampling funding has expired to provide a more cost effective way to monitor for HAPs.[ 6 ]

Major Network Modifications

No major c hanges made in 20 1 4

.

Proposed changes and continuations for 201 5 : 1) Continue the operation of three Federal Equivalent Method (FEM) Beta Attenuation PM 2.5 Particulat e monitors at the Amazon Park

, Oakridge

, and Highway 99 sites

. 2) Possible HAPs sampling at the Amazon Park and HWY99 sites.

Site Descriptions
The following map s and individual site descriptions describe the current monitoring network , and includes the site location, pollutants measured, site type, monitoring goals, objectives, corresponding spatial scales of representativeness, and data availability.

More site pictures and historical data is available at: http://mdas. lrapa.org[ 7 ][ 8 ]

Site Name : 

### Amazon Park

Site Code : 

### AMZ AQS ID : 

### 410390060 UTM Zone : 

### 10
City : 

### Eugene State LASAR ID : 

### 18524 UTM Easting : 

### 493288
County : 

### Lane Statistical Area : 

### MSA 2400 UTM Northing : 

### 4874794

Address : 

### 499 East 29 th 

### St. Year Established : 

### 1984 Elevation : 

### 440 ft

Parameters : Site Type Monitoring Objective Spatial Scale Sampling Method Operating Schedule Design Value

Ozone SLAMS Population Exposure Neighborhood UV Photometric Continuous

May 1

– Sep 30 0.0 5 7 ppm

PM 2.5 SLAMS Max Pop ulation Exp osure Neighborhood Filter based FRM 1 in 1 24

- hour

2 8 μg/m3

Annual

7.8 μg/m3

PM 2.5 collocated SLAMS Network Quality Assurance Neighborhood Filter based FRM 1 in 12

-

PM 2.5 FEM SPM Max Pop ulation Exp osure Neighborhood Beta Attenuation Continuous

- Nephelometer SPM AQI / Program Support Neighborhood Optical Backscatter Continuous

-

Site Description : The Amazon Park site is located in a predominately residential area in Southeast
Eugene. The monitoring location meets all siting requirements and criteria for the described monitoring objective and spatial scale of representativeness.

Planned Changes : Possibly resume HAPS sampling and begin trace level CO sampling in 2015[ 9 ]

Site Name : 

### Wilkes Drive

Site Code : 

### WLKS AQS ID : 

### 410390101 UTM Zone : 

### 10
City : 

### Eugene State LASAR ID : 

### 31020 UTM Easting : 

### 490310
County : 

### Lane Statistical Area : 

### MSA 2400 UTM Northing : 

### 4884738

Address : 

### 943 Wilkes Drive Year Established : 

### 2001 Elevation : 

### 367 ft

Parameters : Site Type Monitoring Objective Spatial Scale Sampling Method Operating

Schedule Design Value

Wind Speed SPM Program Support Urban Propeller / Vane Continuous

-
Wind Direction SPM Program Support Urban Propeller / Vane Continuous

- 2 meter Temp SPM Program Support Urban Thermistor Continuous

- 10 meter Temp SPM Program Support Urban Thermistor Continuous

-
Barometric Pressure SPM Program Support Urban Electronic barometer Continuous

-
Solar Radiation SPM Program Support Urban Pyra nometer Continuous

-
Rainfall SPM Program Support Urban Tipping bucket Continuous

-

Site Description : This site is located i n North Eugene. The monitoring location meets all siting requirements and criteria for the described monitoring objective and spatial scale of representativeness.

P lanned Changes : None

.[ 10 ]

Site Name : 

### Willamette Activity Center

Site Code : 

### WAC AQS ID : 

### 41039 2013 UTM Zone : 

### 10
City : 

### Oakridge State LASAR ID : 

### 18733 UTM Easting : 

### 541827
County : 

### Lane Statistical Area : 

### MSA 2400 UTM Northing : 

### 4843611

Address : 

### 47674 School St. Year Established : 

### 1989 Elevation : 

### 1130 ft

Parameters : Site

Type Monitoring Objective Spatial Scale Sampling Method Operating

Schedule Design Value

PM 2.5 SLAMS Max Pop ulation Exp osure Neighborhood Filter based FRM 1 in 3 24

- hour

40 μg/m3

Annual

9.8 μg/m3

PM 10 SLAMS Max Pop ulation Exp osure Neighborhood Filter based FRM 1 in 6 56 μg/m3

PM 2.5 FEM SPM Max Pop ulation Exp osure Neighborhood Beta Attenuation Continuous

- Nephelometer SPM AQI / Program Support Neighborhood Optical Backscatter Continuous

- Wind Speed SPM Program Support Neighborhood Propeller / Vane Continuous

-
Wind Direction SPM Program Support Neighborhood Propeller / Vane Continuous

- 2 meter Temp SPM Program Support Neighborhood Thermistor Continuous

- 10 meter Temp SPM Program Support Neighborhood Thermistor Continuous

-
Barometric Pressure SPM Program Support Neighborhood Electronic barometer Continuous

-
Solar Radiation SPM Program Support Neighborhood Pyranometer Continuous

-

Site Description : The Willamette Activity Center site is located in the Southwest portion of the city of
Oakridge. The monitoring location meets all siting requirements and criteria for the described
monitoring objective and spatial scale of representativeness. The PM monitor s at this site are the primary sampler s for the both the PM 10 and PM 2.5 Oakridge no n

- attainment area s

.

Planned Changes : None[ 11 ]

Site Name : 

### Cottage Grove City Shops

Site Code : 

### CGCS AQS ID : 

### 41039 9004 UTM Zone : 

### 10
City : 

### Cottage Grove State LASAR ID : 

### 31004 UTM Easting : 

### 495697
County : 

### Lane Statistical Area : 

### MSA 2400 UTM Northing : 

### 4849613

Address : 

### 425 North 14 th 

### St. Year Established : 

### 2008 Elevation : 

### 650 ft

Parameters : Site Type Monitoring Objective Spatial Scale Sampling Method Operating

Schedule Design Value

PM 2.5 SLAMS Max Pop ulation Exp osure Neighborhood Filter based FRM 1 in 3 24

- hour

21 μg/m3

Annual

7.5 μg/m3

Nephelometer SPM Program Support Neighborhood Optical Backscatter Continuous

-

Site Description : The Cottage Grove City Shops site is located in the Northeast portion of the city of
Cottage Grove. The monitoring location meets all siting requirements and criteria for the described
monitoring objective and spatial scale of representativeness.

Planned Changes : None.[ 12 ]

Site Name : 

### Springfield City Hall

Site Code : 

### SPCH AQS ID : 

### 41039 1009 UTM Zone : 

### 10
City : 

### Springfield State LASAR ID : 

### 18538 UTM Easting : 

### 498577
County : 

### Lane Statistical Area : 

### MSA 2400 UTM Northing : 

### 4877060

Address : 

### 225 5 th 

### St. Year Established : 

### 1984 Elevation : 

### 466 ft

Parameters : Site Type Monitoring Objective Spatial Scale Sampling Method Operating

Schedule Design Value

PM 2.5 SLAMS Pop ulation Exp osure Neighborhood Filter based FRM 1 in 6 24

- hour

16 μg/m3

Annual

6.3 μg/m3

Nephelometer SPM AQI / Program Support Neighborhood Optical Backscatter Continuous

- Wind Speed SPM Program Support Neighborhood Propeller / Vane Continuous

-
Wind Direction SPM Program Support Neighborhood Propeller / Vane Continuous

-
Rainfall SPM Program Support Neighborhood Tipping bucket Continuous

-

Site Description : This site is located at the Springfield City Hall in downtown Springfield . The monitoring location meets all siting requirements and criteria for the described monitoring objective
and spatial scale of representativeness.

Planned Changes : None

.[ 13 ]

Site Name : 

### Delight V alley School

Site Code : 

### SAG AQS ID : 

### 41039 1007 UTM Zone : 

### 10
City : 

### Saginaw State LASAR ID : 

### 18315 UTM Easting : 

### 497160
County : 

### Lane Statistical Area : 

### MSA 2400 UTM Northing : 

### 4853490

Address : 

### 79980 Delight Valley

School Rd. Year Established : 

### 1982 Elevation : 

### 634 ft

Parameters : Site Type Monitoring Objective Spatial Scale Sampling Method Operating

Schedule Design Value

Ozone SLAMS Maximum Concentration Urban UV Photometric Continuous

May 1

– Sep 30 0.0 59 ppm

Site Description : The Delight Valley School site is located in Saginaw, j ust West of Interstate 5 about two miles North of Cottage Grove. The monitoring location meets all siting requirements and criteria for the
described monitoring objective and spatial scale of representativeness.

Planned Changes : None.[ 14 ]

Site Name : 

### Highway 99

Site Code : 

### HWY99 AQS ID : 

### 410390059 UTM Zone : 

### 10
City : 

### Eugene State LASAR ID : 

### 31037 UTM Easting : 

### 488680
County : 

### Lane Statistical Area : 

### MSA 2400 UTM Northing : 

### 4879349

Address : 

### 530 Pacific Hwy 99N Year Established : 

### 2011 Elevation : 

### 424 ft

Parameters : Site Type Monitoring Objective Spatial Scale Sampling Method Operating

Schedule Design Value

PM 2.5 SPM Pop ulation Exp osure Neighborhood Filter based FRM 1 in 3 24

- hour

2 8 μg/m3

Annual

8. 3 μg/m3

Nephelometer SPM AQI / Program Support Neighborhood Optical Backscatter Continuous

-

PM 10 SPM Max imum Concentration Neighborhood Filter based FRM 1 in 6 5 9 μg/m3

PM 2.5 FEM SPM Max Pop ulation Exp osure Neighborhood Beta Attenuation Continuous

-

PM 2.5 Speciation SPM Max Population Exposure Neighborhood Filter based FRM 1 in 6

-

Site Description : The Highway 99 site is located in the West portion of the city of Eugene. It replaced the “Old” Highway 99 site approximately 170 meters SE of this location at the beginning of 2 012

. The monitoring location meets all EPA siting requirements and criteria for the described monitoring objective and spatial scale of representativeness.

Planned Changes : Possibly begin HAPS sampling and begin trace level CO sampling in 2015

## A ttachment 3

LRAP A Dashboard R eport, October 2 0151



## National Ambient Air Quality Health Standards

Clean Air Act Goal Current

Status Trend Expected
Finish Comments

Maintain compliance with
the carbon monoxide (CO)

air quality health standard Ongoing Focusing on promoting battery
electric vehicles (BEV), plug

- in electric
vehicles (PEVs), and work place charging.

Maintain compliance with
the PM 10 air quality health
standard Ongoing Continuing improvement of PM 10 concentrations; Eugene/Springfield

now a maintenance area. See pages 7 and 1 0.

Maintain compliance with
the annual PM 2.5 air quality
health standard in Eugene/Springfield Ongoing Levels improving in Eugene, Springfield, and Cottage Grove. See pages 8 and 10

.

Maintain compliance with
the 24

- hour PM 2.5 air quality
health standard in Eugene/Springfield Ongoing Levels improving long-term in Eugene, Springfield, a nd Cottage Grove , but 2013-2014 worsening in Eugene is of

concern

. See pages 8 a nd 1 0.

Maintain compliance with
the annual PM 2.5 air quality
health standard in Oakridge Ongoing Levels improving. Oakridge meets the
annual federal standard. See pages 8 and 1 0.

Attain compliance with the

24

- hour PM 2.5 air quality
health standard in Oakridge Ongoing Despite long

- term improvements, Oakridge continues to violate federal
standard. See pages 8 and 1 0.

Maintain compliance with
the ozone air quality health
standard in Eugene/Springfield Ongoing Continuing improvement of ozone concentrations, 2014 levels below

range for tightened proposed by EPA.

See pages 5 and 9. 

## October 2015 Dashboard Attachment 3 Oakridge Extension Request 20152 

## Particulate Matter

Priority Current

Status Trend Expected
Finish Comments

Improve PM 2.5 air quality in Oakridge Compliance by
December 2015 Long

- term trend shows improvement,
but data shows the worst days are flat
and plateaued. See pages 8 and 1 0.

Complete work on new
PM 2.5 control strategy and

attainment plan for Oakridge

, Including
reconsideration of non

attainment area boundary Plan adopted by
December 2012. Boundary
reconsideration

in 2014- 2015. Plan submitted to Oregon
Environmental Quality Commission
and EPA, monthly check

- in meetings.

EPA considering changing NAA boundary to Oakridge UGB.

Cu rrently working with Oakridge on new moderate level SIP plan to attain by December 2015.

Maintain compliance with

PM 2.5 standard in Eugene Springfield and Cottage

Grove Ongoing Annual and wors t day PM 2.5 levels improved long

- term and meet

sta ndards. Occasional high, “Red” days during cold, sta gnant wea ther in Eugene in 2013-2014 of concern

. Ex tended HWH season implemented Oct 1 – May 31.

Strengthen Oakridge advisory program and

continue to provide timely
and accurate air quality and burning advisories February 2014 More conservative forecasts to

ensure rare missed red days. Police
enforcement in effect. Electronic
reader board being used to inform
residents of advisories.
Implement revised air quality index and home
wood heating advisories
based on new PM 2.5 standards November 2007
November 2013 The 2006 PM 2.5 standard changed the

100 level of the AQI. The 2013 PM 2.5 standard changed the AQI 50 level.

Complete PM 2.5 /GHG implementation in
industrial permitting Ongoing Incorporated upon permit renewals.3 

## Air Toxics and Ozone

Priority Current

Status Trend Expected
Finish Comments

Incorporate Maximum
Achievable Control Technology (MACT) requirements into industrial permits and ensure compliance Ongoing as EPA
finalizes new MACT standards Incorporated as permit modifications

or at permit renewal.

Continue to develop and implement programs, rule
and fee structures for area

source National Emission
Standards for Hazardous air
Pollutants (NESHAPs) Ongoing as EPA
finalizes new NESHAP
standards Boiler NESHAP implementation currently ongoing

Compare modeled air toxics

concentrations in the
National Air Toxics

Assessment (NATA) with
local air toxics monitoring
data NATA results to be updated by

EPA for 2011, 2014, and 2017 NATA 2011 results from EPA compared to LRAPA 2010

- 2011 monitoring results on page 1 2. LRAPA conducting air toxics monitoring for

2015 at two locations.

Review revised national
ambient air quality
standards for ozone ; assess the status of airsheds in Lane County, identify next steps as needed Revised ozone standard (70 ppb) adopted by

EPA on 10/1/2015. Current ozone levels at both Saginaw
and Amazon Park are well below the new 70 ppb EPA ozone standard.



## AirMetrics

Priority Current

Status Trend Expected
Finish Comments

Maintain self

- supporting operation, at break

- even or better production levels Maintain 12

- month average of 20 units sold

per month. S ee page 1 1. Maintaining or exceeding break

- even goal.4 

## Agency Administration

Goal or Initiative Current

Status Trend Expected
Finish Comments

Update LRAPA strategic
priorities annually 

### ate October 2014
October 2015 Reported recent successes and future priorities. Incorporated into dashboard beginning November 2013.

Provide timely permits, inspections and
construction reviews Ongoing permitting. Inspections to be completed by 9/30 each year

. New inspector hired August 2014 left LRAPA in July 2015; currently recruiting replacement inspector. All inspections completed by 9/30/ 15 as required. Provide clear and precise

communications to citizens
and other stakeholder through public involvement

process Ongoing Increased presence on social media with a newly renovated website strengthens technological outreach
methods.

Improve compliance inspection, reporting and tracking October 2014
October 2015 Ongoing training on EPA’s database modernization project (ICIS

- Air)

. LRAPA directly entering data to into
the new database ( ICIS

- Air ) for the
first time by 10/31/ 15 as required. Also, there are ongoing discussions with DEQ about use of their database (TRAACS) for LRAPA use.

Maintain industrial area

source LRAPA rules Spring 201 5 Major rule revisions adopted by DEQ

on April 15, 2015 . LRAPA ’s version of those rules are currently being drafted with a potential mid -2016 Board adoption date

.

Finalize personnel policy
manual January 2014. Review & update by January 2016. Working with the City of Springfield HR Office and other experts to review the compensation plan.

Improve financial stability and viability of LRAPA: develop five

- year budget projection annually January 2015 January 2016 A 5 year multi

- year projection is updated each January. Next update in January 2016.

Complete annual performance reviews on all
LRAPA staff Ongoing As of April 2015, all 15 of 15 (100%) have been completed within the last 12 months, including the initial 6

- month reviews for the new staff.

Keep financial reserves at 120 days minimum Report quarterly Auditors recommended 90

- 180 days. Board adopted target of 120 days

minimum. LRAPA is on target or exceeds the 120 days reserve goals.

# O ZONE 

# D ATA

EPA has designated the following National Ambient Air Quality Standards (NAAQS) for Ozone:

Level Averaging Time Description

0.075 ppm 8

- hour To attain this standard, the 3

- year average of the fourth

- highest daily maximum

8

- hour average ozone concentrations measured at each monitor within an area over each year must not exceed 0.07 0 ppm. (effective October 1, 2015 )

0.045 0.050 0.055 0.060 0.065 0.070 0.075 0.080 0.085

2006 2007 2008 2009 2010 2011 2012 2013 2014 2015Ozone Concentration (ppm) 

### Ozone: 3

- yr Average of 4th High Maximum Daily 8

- hour
Levels

Saginaw Amazon Park 8-hour NAAQS

0.000 0.020 0.040 0.060 0.080 0.100

2006 2007 2008 2009 2010 2011 2012 2013 2014 2015Ozone Concentration (ppm) 

## Ozone: Maximum Daily 8

- hour Average Levels

Saginaw Amazon Park 

### 8

- HOUR 

### A VERAGE 

### O ZONE 

### L EVELS 

### 200 6

– 201 5

(ppm)

Site Name 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

Saginaw Maximum 0.074 0.064 0.068 0.067 0.074 0.068 0.065 0.059 0.062 0.080

4th highest 0.070 0.060 0.059 0.066 0.060 0.059 0.062 0.056 0.058 0.070

3

- year 4 th high 0.069 0.067 0.063 0.061 0.061 0.061 0.060 0.059 0.058 0.061

# Exceedances 0 0 0 0 0 0 0 0 0 1

Amazon

Park Maximum 0.084 0.079 0.067 0.068 0.073 0.072 0.065 0.057 0.061 0.078

4th highest 0.076 0.059 0.059 0.063 0.056 0.059 0.059 0.053 0.058 0.069

3

- year 4 th high 0.068 0.066 0.064 0.060 0.059 0.059 0.058 0.057 0.056 0.060

# Exceedances 1 1 0 0 0 0 0 0 0 1

5

# C ARBON 

# M ONOXIDE 

# D ATA

EPA has designated the following National Ambient Air Quality Standards (NAAQS) for CO :

Level Averaging Time Description
9 ppm 8

- hour Not to be exceeded more than once per year. 35 ppm 1

- hour Not to be exceeded more than once per year.

0 0.5 1 1.5 2 2.5 3

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014CO Concentration (ppm) 

### CO: Annual 2nd High of Maximum Daily 8

- hour Average Levels

LCC Sacred Heart Hospital

0 0.5 1 1.5 2 2.5 3

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014CO Concentration (ppm) 

## CO: Maximum Daily 8

- hour Average Levels

LCC Sacred Heart Hospital 

### C ARBON 

### M ONOXIDE 

### (C O ) L EVELS 

### 200 5

- 201 4 ( ppm )

Site Name 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

LCC

- Downtown Eugene Highest 8

- hour 2.5 2.1 2.2 1.7 1.6 1.5

--- --- --- ---

2 nd high 8

- hour 2.3 2 2.1 1.7 1.6 1.3

--- --- --- --- # Exceedances 0 0 0 0 0 0

--- --- --- ---
Sacred

Heart Hospital Highest 8

- hour 2.7

--- --- --- --- --- --- --- --- ---

2 nd high 8

- hour 2.7

--- --- --- --- --- --- --- --- --- # Exceedances 0

--- --- --- --- --- --- --- --- ---

6

# P ARTICULATE 

# M ATTER 

# D ATA



# – PM 10

EPA has designated the following National Ambient Air Quality Standards (NAAQS) for PM 10 :

Level Averaging Time Description
150 μg/m 3 24

- hour Not to be exceeded more than once per year on average over 3 years.

20 30 40 50 60 70 80 90

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014PM10Concentration (μg/m3) 

### PM 10 

### : Annual Highest Daily 24

- hour Concentrations

LCC C.G. Hwy 99 Oakridge 

### 24

- HOUR 

### A VERAGE 

### PM 10 

### L EVELS 

### 200 5

- 201 4 (μg/m3)

Site Name 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

LCC

– Downtown Eugene Highest 24

- hour 41 40 65 41 36 41

--- --- --- ---

Harrison School
Cottage Grove Highest 24

- hour 35 39

--- --- --- --- --- --- --- ---

Hwy 99

- Four

Corners Highest 24

- hour 50 68 78 56 80 49 58 46 59 45

Oakridge Highest 24

- hour 78 53 59 49 47 48 49 44 56 55

7

# P ARTICULATE 

# M ATTER 

# D ATA



# – PM 2.5

EPA has designated the following National Ambient Air Quality Standards (NAAQS) for PM 2.5 :

Level Averaging Time Description

1 2 .0 μg/m 3 Annual (Arithmetic

Average) To attain this standard, the 3

- year average of the annual mean PM2.5 concentrations

from monitors must not exceed 1 2 .0 μg/m 3 (effective December 14 , 20 1 2 )

.
35 μg/m 3 24

- hour To attain this standard, the 3

- year average of the 98th percentile of 24

- hour

concentrations m ust not exceed 35 μg/m 3 (effective December 17, 2006).

0 10 20 30 40 50 60 70

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014PM2.5Concentration (μg/m3) 

### PM 2.5 

### : 3

- yr Average of the 98th Percentile of 24

- hour Concentrations

24-hour NAAQS

Amazon Park

Cottage Grove City Shops
Saginaw

Hwy 99 - Four

corners Springfield City
Hall
Oakridge 

### 24

- HOUR 

### A VERAGE 

### PM 2.5 

### L EVELS 

### 200 5

- 201 4 ( μg/m3 )

Site Name 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Amazon Park Annual mean 9.1 8.3 7.4 7.8 8.5 5.8 6.5 6.4 7.8 7.2

Highest 24

- hour 39.6 43.3 43.0 40.0 59.9 21.0 24.6 31.6 51.9 35.5
Annual 98 th %

- ile 35.6 31.8 36.3 28.7 35.9 16.5 21.2 25.4 38.6 30.7 3 year 98 th %

- ile 31 32 35 32 34 27 25 21 28 32

Cottage Grove City Shops Annual mean

--- --- --- 8.1 8.5 6.9 7.1 6.7 7. 5 7.0

Highest 24

- hour

--- --- --- 31.8 33.6 21.1 32.1 24.7 38.1 34.0
Annual 98 th %

- ile

--- --- --- 21.1 30.2 18.3 20.4 17.0 25.4 21.3 3 year 98 th %

- ile

--- --- --- --- --- 23 23 19 2 1 21

Saginaw Annual mean 6.8 5.5

--- --- --- --- --- --- --- ---

Highest 24

- hour 24.7 16.6

--- --- --- --- --- --- --- --- Annual 98 th %

- ile 17.9 16.6

--- --- --- --- --- --- --- --- 3 year 98 th %

- ile 16 16

--- --- --- --- --- --- --- ---

Hwy 99

- Four
Corners Annual mean

--- --- 8.4 8.3 8.2 6.3 10.0 6.5 8.3 7.1

Highest 24

- hour

--- --- 53.5 32.4 47.9 22.9 26.7 30.0 54.6 43.6
Annual 98 th %

- ile

--- --- 33.9 25.3 36.4 19.5 22.1 20.6 40.2 30.5 3 year 98 th %

- ile

--- --- --- --- 32 27 26 21 28 30

Springfield City
Hall Annual mean 8.0 7.4 6.8 6.9 6.8 5.8 5.6 5.5 6.3 6.4

Highest 24

- hour 32.1 30.2 38.6 32.3 21.9 17.9 18.8 18.3 18.8 35.6
Annual 98 th %

- ile 24.5 27.8 18.4 23.5 18.3 14.0 14.8 15.3 17.2 14.2 3 year 98 th %

- ile

--- 24 24 23 20 19 16 15 16 16

Oakridge Annual mean 12.8 11.1 10.5 11.5 11.0 8.9 10.0 7.6 9.8 10.1

Highest 24

- hour 73.0 47.0 52.5 43.5 44.1 43.1 47.9 49.9 54.9 46.1
Annual 98 th %

- ile 58.4 38.6 42.7 38.7 41.3 33.0 42.0 38.4 41 .0 41.1 3 year 98 th %

- ile 53 48 47 40 41 38 39 38 40 40

4 89100 10 20 30 40 50 60 70 80

D-01 D-02 D-03 D-04 D-05 D-06 D-07 D-08 D-09 D-10 D-11 D-12 D-13 D-14 D-15 D-16Units per Month 

# AirMetrics Sampler Sales Trends

3-month

6-month

12-month

8 8 10

8 8 8 8 11

### 2011 NA TA Modeled Concentration Comparison to Measured Concentrations

Modeled concentrations for the 20 11 NATA have been compared to measured values from LRAPA’s Amazon Park and Peterson Barn monitoring site s . The

Amazon Park monitor is located in c ensus t ract 48 and Peterson Barn is located in tract 43 . Modeled annual average concentrations provided in NATA for

tract 48 and 43 were compared with annual averages of monitor values measured during the monitoring year of April 2010 to March 2011

.

Com p arison of modeled and measured concentrations, all values in μg/m3

NATA Pollutant AMZ 2011 NATA
Modeled Annual Average A MZ 2010/11

Measured Annual Average PBarn 2011

NATA Modeled Annual Average PBarn 2010/11
Measured Annual Average Oregon

ABC

ACETALDEHYDE 1.776 1.530 1.641 1.707 0.45

ARSENIC COMPOUNDS (INORGANIC INCLUDING ARSINE) 0.00006 0.00068 0.00006 0.00057 0.0002

BENZENE (INCLUDING BENZENE FROM GASOLINE) 1.540 2.252 1.056 1.989 0.13

CADMIUM COMPOUNDS 0.00004 0.00007 0.00005 0.00007 0.0006

METHYL CHLORIDE (CHLOROMETHANE) 1.090 1.394 1.090 1.439 90

COBALT COMPOUNDS 0.00004 0.00006 0.00004 0.00006 0.1

FORMALDEHYDE 1.595 1.644 1.524 1.871 0.2

LEAD COMPOUNDS 0.00031 0.0 0129 0.00021 0.00158 0.15

NAPTHALENE 0.122 0.053 0.081 0.079 0.03

MANGANESE COMPOUNDS 0.00037 0.00385 0.00034 0.00461 0.09

METHYLENE CHLORIDE (DICHLOROMETHANE) 0.00762 1.32327 0.00650 1.32295 100

HEXANE 1.070 1.007 0.809 1.602 70 0

NICKEL COMPOUNDS 0.00028 0.00042 0.0023 0.00018 0.05

TOLUENE 2.933 5.840 2.758 7.132 500 0

XYLENES (MIXED ISOMERS) 1.274 3.322 1.408 3.926 700

1 2

## A ttachment 4

Lane E lectric C o operative, E nhanced Incentive P rogram for O akridge H eat Pumps, August 28, 2 0 15

# LaneEtecrriib

Your Twdt*one bngt'Cuprattve 

## *

August 28,2015

Mayor Jim Coey ATTN: City Administrator Louis Gomez City of Oakridge
P.O. Box 

### l4l0 Oakridge, Oregon 97463



### VIA 

### EMAIL: LouisGomez@ci.oakridge.or.us

jbryan522@)msn.com



## RE: Air Quality in Oakridge

Dear Ma

Lane Electric Co-op (LEC) is one element of a sustainable solution for Oakridge's air quality issue. When ''red days" occur, ductless heat pumps can be an alternative heat source 

### to buming. Our Heat Pump Program together with our Member Assistance Prograrn (MAP) offers a no/low cost immediate solution

to reducing wood buming on EPA "red days."

For decades, LEC's Heat Pump Program has offered $1,000 rebates or 070 interest loans (up to $9,000) for installing energy efficient heat pumps-ducted or 

### ductless-in homes where electric heat has been

used either as the primary heating system or as supplemental plug-in units.

For low-income LEC members that are homeowners, a ductless heat pump could be installed fbr free (up


### to $3,800). 

### An installation typically costs around $3,800. For LEC members renting their home, up to $1,900 is available to lower the improvement cost for the rental property owner.

However, to help Oakridge aggressively pursue its air quality goals, LEC is willing to apply the same free (up to $3,800) offer to both homeowners and rental property owners of low-income occupied Oakridge housing until December 31, 2015. Thereafter, our regular offer 

### will apply.

Further, we can extend our Member Assistance Program 

### to make the cost 

### of using the heat pump effectively free on declared "red days" to encourage less buming on those days.

We stand ready 

### to work 

### with the 

### City to reach oul directly 

### to residents that could benefit from our

programs. LEC staff and 

### I are available at your convenience to discuss the details and plan how best to

coordinate our efforts to help Oakridge.

Regards, 

# ,'frr,+r

Matt Michel General Manager

787 BArrEyH LLRoAD/P.O.80x21410



### . EUGENF,oREGoN 97402-0407


### . 541.484.11,57


### . (FAxi 541.484.7316

www.laneelectric.com
"Owned bv lhose we serve" 

### Attachment 4 Oakridge Extension Request 2015

## A ttachment 5

City o f O akridge A ir P ollution Co ntrol Ordinance #914

, O ctober 15, 2015

### Attachment 5 Oakridge Extension Request 2015

## A ttachment 6

Supplemental Strategies Overview
– Southern Willamette F orest

C ollaborative, October

2 0151 

## Oakridge Air Attainment Plan for Particulate Matter 2.5

Since 2009 Oakridge has been designated by the Environ mental Protection Agency (EPA)
as a nonattainment area for the 24

- hour national air quality standards for fine particulate matter. Despite the Oakridge Fine Particulate Matter (PM2.5) Attainment Plan and local ordinances, Oakridge has been unable to meet the EPA standard of 35 micrograms per cubic meter ( μ g/m3) based on an average of the most recent three years of federal reference monitoring data.

Emis sions inventory data gathered by the Lane Regional Air Pollution Agen cy ( LRAPA ) demonstrates that the main source of PM2.5 during the winter season is residential wood burning emissions. Local climate and topography make the city of Oakridge prone to wintertime temperature inversions, low wind speeds and poor atmospheric dispersion. During the winter months, Oakridge air quality is often susceptible to high concentrations of smoke from woodstoves settling on the valley floor. As a result, Oakridge will be designated by the EPA as a “serious ” non

- attainment area for wood smoke pollution if exceeds acceptable levels before December 31, 2015. A “serious” designation includes the following sanctions: a two

- to

- one offset for any new source of emissions, disqualification
for federal highway funds in the non

- attainment area, and implementation of an EPA federal plan for compliance (see addendum)

.

Since N ovember 2014 community partners have been meeting monthly to discuss options to improve Oakridge : The City of Oakridge, LRAPA, Lane Electric Cooperative (LEC) , St. Vincent De Paul of Oakridge (SVDP), the Southern Willamette Forest Collaborative, and
various elected officials. The EPA has advised the committee that if Oakridge can avoid exceeding the st andard through 2015 a one

- year extension can be granted.

The A ir Attainment partners have developed a three

- part strategy that focuses on 1) Education, 2) Enforcement, and 3) Economic Assistance. Related s hort

- term and long

- term measures for each area have been identified.



### Current short

- term measures:

**1. Education:**  a. The City, LRAPA and SVDP will work together to distribute education materials including how to comply with wood burning advisories, proper wood burning techniques, and alternatives to wood heat.
b. The City of Oakridge has contracted to produce an educational video that explains the pollution problem, best practices for wood burning, and how to comply with burning advisories.

c. The Oakridge municipal court will create a diversion program for first time offenders, offering an educational course instead of a fine.
d. The Mayor and City Council are sharing information via newsletters in the local paper, upcoming Town Hall meetings (Oct. 20 th 

### , 7PM)

, water bill, Facebook for virtual town hall meetings, and the City’s Website

. Attachment 6 Oakridge Extension Request 20152 

### 2. **Enforcement:**

a. Code enforcement

– the City is revising local wood burning codes to clarify burn ban exemptions and fines and updating the home heating exemption application based on LRAPA recommendations

. b. S moke School

– Oakridge Police Department will send staff to specialized courses to certify them to read smoke opacity. Once trained, the OPD will begin issuing tickets for wood burning violations.

c. New code enforcement officer

– LRAPA and the City of Oakridge have
combined efforts to fund a part time City of Oakridge code enforcement position . This position will focus on wood burning code enforcement from
Nov

- Feb.
**3. Economic Assistance** 

a. LEC has offered free (up to $3,800) to both homeowners and rental property owners of low

- income occupied Oakridge housing until December 31, 2015

. LEC has also ex tended it’s Member Assistance Program to make the cost of using the heat pump effectively free on declared "red days" to encourage less burn ing on those days.



### P otential long

- term measures ( with additional funding ) :

**1. Education:** 

a. H ire a full time coordinator to implement all air attainment programs and act as a coordinator between partner agencies and organization. A

c oordinator that would be extremely essential in reaching the cities established PM 2.5 goals.

i. Estimated costs are $1 0 0,000 per year for 3 years to pay for salary, benefits, and travel for a full time coordinator.
b. A designated budget for educational ma terials and videos for a three

- year period is $30,000.

i. With these funds a programs could be created that target messagin g for youth and the broader population.

ii. Create interactive presentations for school age children

iii. Talk face to face with people and provide education materials at the local food pantry

, senior meals, church luncheons, and community

events

. iv. Train volunteer community members to act as ambassadors to connect neighbors and friends to information and resources.

c. The municipal court diversio n program will be primarily an educational program. A fee will be assessed to the offender. There will be ad ditional duties added to the Municipal Court Clerk. Annual additional costs are estimated at $5,000 a year for 3 years.

**2. Enforcement:** 

d. T ra in neighborhood watch, fire depar t ment , and public works personnel on how to measure wood smoke opacity

.3 

### e. E xtend the c ode enforcement officer to a full time position. The City has identified a code enforcement officer as a top priority to enforce no

- burning and proper burning ordinances.

i. It will cost approximately $70,000 a year for a fu ll time code
enforcemen t person.

**3. Economic Assistance** 

f. Fund a pilot program that first targets the 82 wood burning exemption households for free ductless heat pump (DHP) replacements and comprehensive home weatherization.

g. E xpand the DHP program to the entire community, both home owner s and renters, while allowing homeowners to keep certified wood stoves.

i. The estimated costs for DHP replacement is $4,000 per household. A
program t arget ing 100 homes would cost approximately $400,000

. h. Replace non

- certified wood stoves . According to the 7/15 home heating

s urvey 22% of respondents use a non

- certified wood stove or fireplace for home heating. A wood stove replacement program would target these homes. The program would also include renter occupied homes and homes
loc ated outside of Oakridge, which were ineligible for past wood stove replacement programs.

i. The estimated cost for a certified wood stove replacement is $4000 per household. A program targeting 100 homes would cost approximately $400,000.

i. Red Day Home Heati ng Credit o ffer ing electric

- dependent homes

c ompensation for electric bill on no

- burnings days

. i. There are approximately 14 00 homes in Oakridge, and an estimated 30% depend solely on electric heat. Estimating $ 10

- 15 a day per household would cost $4,500 for each red day. As more homes are outfitted with DHPs and weatherization the cost for daily offsets should decrease per household. The cost to fund a credit program, for appr oximately 10 days a year, is $45,0 00. j. I ncrease H ousing and C ommunity S ervices A gency (HACSA) w eatherization efforts in Oakridge

. i. HACSA estimates it costs about $10,000 to weatherize Oakridge
homes. $ 500,000 would provide funding to properly weatherize at
least 50 homes.
k. I mplement a community firewood program to provide seasoned fire wood at
affordable rate s based on household income

. There is no funding request for this program at this time.
l. R eimburse homeowners for woodshed building materials. There is no funding request for this program at this time.

i. According to the 7/15 Home Heating Survey, 40% of those surveyed store their firewood under tarps or in the open.4 

### Projected cost for all Oakridge Air Attainment initiatives will be in the range of $2,000,000

. The city is working with its partners to find these funds through grants and other initiatives. Assistance from the state and federal government will be paramount to the success of our community.

Cost Duration Total

PROGRAMS

Education Supplies $ 10,000 3 years $ 30,000 Municipal Court

Diversion $ 5,000 3 years $ 15,000

DHP Pilot Program $ 400,000 As long as funding
lasts $ 400,000

Certified Wood Stove Replacement $ 400,000 As long as funding
lasts $ 400,000

Home Weatherization $ 500,000 As long as funding
lasts $ 500,000

Red Day Credits $ 45 ,000 3 years $ 135,000

STAFF

Air Attainment
Coordinator $ 10 0,000 3 years $ 30 0,000

Code Enforcement
Officer $ 70,000 3 years $ 210,000

TOTAL $ 1,990 ,000

Sarah Alte mus

- Pope SW Forest Collaborative ( SWFC ) swfcollaborative@gmail.com October 23, 2015

## A ttachment 7

Lan e E lectric R uralite M agazine
– LRAPA O akridge W inter Woo d

Heating Article, N ovember 20 15

# Winter Wood

Heating

The ambiance, glow, and heat from a wood stove or fireplace is commonplace in Oregon during the winter months. Often times, it is the most economical way for people to stay warm throughout our notoriously wet and cold winters.

Unfortunately, improper wood burning causes the number one source of winter pollution in Lane County. When stagnant inversions arise, smoke lingers at ground level, affecting the health of our own families and neighbors.

Follow these tips for clean burning fires that will limit the harmful smoke in the air. 

# Burn smart. Stay Warm. Breathe Easy. 1. Clean stove = clean fires Make sure your wood burning device is clean and up to date with maintenance. Annual cleaning will reduce creosote buildup and lower your chances of a house fire. If you have a stove that was manufactured before 1986, your wood stove is not federally certified. Think about upgrading to a more efficient stove to reduce your pollution
or consider alternatives. 

### 2. Dry wood for the greater good Only use dry, clean, cured wood. It should have been chopped, covered, and stored for at least six months. Your wood should be less than 20% moisture. Not sure? Check with a moisture meter, available at most hardware stores. Don’t have a moisture meter? Knock two logs together. If it creates a hollow sound, it is likely dry enough. The steaming, popping noises you get from wet wood does not put out much heat and creates excessive smoke. Get the most bang for your buck by burning dry wood. Never burn garbage.


### 3. Don’t run the red light Check Lane Regional Air Protection Agency (LRAPA)’s daily Home Wood Heating advisory. This is required if you live in Oakridge, Springfield, or Eugene. The advisory will tell you if the air quality is safe enough to burn. The advisories are posted at 2 PM daily, between October 1st and May 31st.

Green advisories show that the air quality is good and there is enough ventilation for wood burning.

Yellow advisories indicate increased pollution and less ventilation. Use alternatives if you can and only burn if you
have to do so.

Red advisories are stop lights that prohibit creating smoke. No visible emissions are allowed during red advisories because air quality has degraded to harmful levels. Use alternatives to heat your home. You wouldn’t run a red traffic light, so make sure you don’t create any smoke on a 

### Attachment 7 Oakridge Extension Request 2015Red day! The good news is, there are only a few Red days a

year. 

### 4. Small for the long haul
Build small, hotter fires. The smaller the fire, the more complete combustion you will get from each piece of wood. You will also keep from using up too much fuel all at once.


### 5. Keep dampers open The more access to oxygen the fire has, the more thoroughly it will burn. If you smother your fire by closing the damper, it will smoulder and smoke without producing much heat. There is a common misconception that dampening down will mean more heat produced in the long run, but experienced
burners know that’s not the case!


### 6. Check your smoke Once you have your fire going, step outside to make sure it is not flooding into your neighbor’s property. Check the thickness, or the “opacity,” of the smoke and make adjustments as you need. Your smoke should be barely visible as it comes out of the chimney. The best fires have invisible smoke, or “heat waves.” This indicates the fires are at their hottest and most productive state. How clean can you burn?

Depending on where you live, there are rules about how thick your smoke can be. Eugene and Springfield are limited to 40% opacity while Oakridge is limited to 20%. Exceeding these limits could get you fined! 

### 7. Protect your family and yourself Smoke inhalation is dangerous, especially when consumed over long periods of time. If your neighbor is burning improperly and affects the air you breathe, they are endangering your health.

Smoke from wood burning contains fine particulate matter, carbon monoxide, formaldehyde, sulfur dioxide, and known caricinogens such as polycyclic aromatic hydrocarbons (PAHs), and dioxin.

If you have children, seniors, or pregnant women in your home, they are more prone to develop negative health impacts from wood smoke. People with asthma or other pre-existing heart and lung conditions are also at risk of having further complications from smoke inhalation.

To report violators in Lane County, call LRAPA’s complaint line at 541-726-1930. For the Oakridge area, call the Oakridge Police at 541-782-4232.


### 8. Cozy alternatives While the glow of a warm fire is hard to beat, there are other ways to stay warm this winter that will help you save money and time.

Ductless heat pumps are not as expensive to run as
traditional baseboard heaters or other electric alternatives and can heat very efficiently.

Pellet stoves produce much less smoke and can still give you the ambiance and glow of a fire.

Propane or natural gas also provides you with the asthetics and warmth of a fire without the time and energy put into preparing wood. 

### 9. Need a helping hand?
Exemption forms are available for people who meet lowincome needs. People can apply for a form in Eugene/ Springfield at LRAPA and in Oakridge at Oakridge City Hall. The exemptions only allow people to burn wood on Red days as long as they keep their smoke under the required opacity limit.

Help keep our air clean this winter by using alternatives or making sure you are burning clean. Remember to always check the advisory before you burn and be considerate of your neighbors. Their health may depend on you!

For more information about wood burning or air quality, visit the LRAPA website at www.lrapa.org or call 541-736-1056.

## Attachment 8

Supplemental 2015 -2 0 16 Oakridge S IP D evelopment Plan, S eptember 2 0151 

# SIP Development Plan

Oakridge Attainment Plan
– 2015/2016 Supplement PM 2.5



### Purpose : Develop a SIP revision to correct deficiencies identified in the 2012 SIP submittal

LRAPA Team: Merlyn Hough

, Robbye Lanier , Jo Niehaus

EPA Team: Steve Body, Alex Fidis, Robert Elleman, Bob Kotchenruther.

Milestones and Timeline : Based on EPA proposed approval and disapproval of the various Oakridge 2012 SIP elements by December 2015.

Action Who is responsible Date

SIP development plan complete : This plan with commitments would be
between EPA and LRAPA September 2015

Identify potential policy issues to be
resolved with EPA

• Attainment Date & Model
Date

• MOVES

• Opacity and SSM

• General Conformity

• Permitted sources: deminimus
for RACT

• Attainment Date Extensions All

EPA

EPA
LRA PA
EPA
EPA

EPA & LRAPA October 2015

Control Measures : Identify the
measures to be discussed in the SIP revision. Categorize whether the

measures are already approved into a SIP (either PM -10 or other action) and provide a citation, those that are new and need to be approved, or new and
for which emission reductions are not incorporated into the attainment
demonstration and LRAPA does not
desire th em in the approved SIP. LRAPA lead with Steve
review and assistance • Contingency measures (since October 2014)

• Possible pilot program from exemption list for free ductless heat pumps (TBD)

• Code enforcement officer and smoke reading training for Oakridge Pol ice Department (October 2015)

• Wood exchange program (TBD)

• Magnets for woodstoves (TBD)

• Educational video for schools (TBD) 

### Attachment 8 Oakridge Extension Request 20152 • Additional outreach in
low-income neighborhoods with St.
Vincent De Paul staff (TBD)

• RACM/RACT Determination (after attainment
demo nstration) LRAPA: based on among other things,
attainment needs and
economics
EPA review February 2016

Emission Inventory

• Base year inventory (2008) Complete

• Determine Attainment Year LRAPA with EPA
assistance October 2015

• Develop attainment year
emissions without reduction
credits LRAPA November 2015

• Run MOVES 2014 for model year and attainment year:
Establish MVEB LRAPA /DEQ 2015/2016

• Develop attainment year
emissions with reduction
credits identified for each

measure LR APA December 2015

Precursor Analysis

• Review existing analysis EPA November 2015

• Update as necessary LRAPA January 2016

Attainment Demonstration

• Select model for
demonstration LRAPA with EPA
review Aug ust 2015: Same model as in
2012

• Identify model inputs LRAPA January 2016

• Calculate attainment year
PM 2.5 Concentrations LRAPA January 2016

RFP (reasonable further progress) and Quantitative Milestones

• Determine how to present LRAPA & EPA January 2016

Contingency Measures

• Identify measures LRAPA November 2015

• Adopt trigger mechanism LRAPA April 2016

SIP Documentation

• SIP revision Outline LRAPA with EPA
review September 20153 • Begin writing SIP revision LRAPA September 2015

• Draft SIP complete for EPA
review LRAPA February 2016

• EPA Review and comments
back to LRAPA EPA March 2016

• Advisory Committee (standing LRAPA CAC) LRAPA April 2016

• Develop list and compile supporting material to be submitted. e.g. adopted city ordinances, existing City and LRAPA measures (e.g. open burning etc) LRAPA and EPA Nov ember 2015

• Finalize SIP package LRAPA June 2016

SIP adoption and submittal

• Public hearing and adoption by LRAPA LRAPA & ODEQ September 2016

• Submit to Oregon EQC LRAPA & ODEQ October 2016

• Oregon Adopt SIP LRAPA & ODEQ December 2016

• SIP Submittal to EPA LRAPA & ODEQ December 2016