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 PM2.5 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 PM10 (particulate matter with an aerodynamic diameter of less than 10 micrometers) the 

courts have determined that PM2.5 (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 PM2.5

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 98th percentile PM2.5 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. 

Sincerely, 

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.

Extension Request: Request for a 1-Year Extension for Oakridge, Oregon, a Moderate PM2.5

Nonattainment Area. 

Attachments 

Attachment 1: Oakridge PM2.5 Attainment Plan: December 2012 Submittal as a revision to the 

State Implementation Plan.

Attachment 2: LRAPA 2014 Ambient Air Monitoring Network Plan. 

Attachment 3: LRAPA Dashboard Report, October 2015. 

Attachment 4: Lane Electric Cooperative, Enhanced Incentive Program for Oakridge Heat 

Pumps, August 28, 2015. 

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

Attachment 6: Supplemental Strategies Overview – Southern Willamette Forest Collaborative, 

October 2015. 

Attachment 7: Lane Electric Ruralite Magazine – LRAPA Oakridge Winter Wood Heating 

Article, November 2015. 

Attachment 8: Supplemental 2015-2016 Oakridge SIP Development Plan, September 2015. 
LRAPA Cover Letter

Extension forwarding request from LRAPA to Oregon DEQ 
December 10, 2015

Dick Pedersen

Director

Oregon Department of Environmental Quality

811 SW Sixth Avenue

Portland OR 97204

Dear Dick: 

The Lane Regional Air Protection Agency has prepared a request for a one-year extension to the 

attainment date for the Oakridge PM2.5 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. 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. 

Clean Air Act section 188(d) provides criteria for granting an extension. While section 188 specifically 

applies to PM10 (particulate matter with an aerodynamic diameter of less than 10 micrometers) the 

courts have determined that PM2.5 (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 

PM2.5 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 98th percentile PM2.5 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 assistance on this important matter.

Sincerely,

Merlyn L. Hough, P.E., BCEE

Director

Lane Regional Air Protection Agency

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

Enclosure

1010 Main Street

Springfield, OR 97477

Phone: (541) 736-1056

Fax (541) 726-1205

1-877-285-7272

www.lrapa.org

E-mail: lrapa@lrapa.org
Extension Request

Request for a 1-Year Extension for Oakridge, Oregon, a Moderate 

PM2.5 Nonattainment Area 
Oakridge Attainment Date Extension Request Page 1

Request for a 1-Year Extension for Oakridge, Oregon, 

a Moderate PM2.5 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. Section 

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 PM2.5 (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 PM2.5 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 98th percentile PM2.5 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 Date for the Oakridge, Oregon Moderate 

PM2.5 Nonattainment Area:

The statutory attainment date for the Oakridge Moderate PM2.5 Area is December 31, 2015. 

The Oakridge area will most likely not attain the PM2.5 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 PM2.5 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 summit 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 PM2.5 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 

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 
Oakridge 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 point.

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 monitoring studies in 1991 and 1994 (PM10) and 2002-2003 (PM2.5) demonstrated

the monitor is located in the area of maximum emissions and PM2.5 concentrations. 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 PM2.5 is the filter-based Federal Reference Method (FRM) 

operating on an every-3rd-day schedule. Other parameters measured at the WAC station 

include:

• PM10 (filter-based FRM on an every-6th-day operating schedule), 

• PM2.5 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 qualityassured PM2.5 data for the first three quarters (January-September) of 2015 has been below 35 

micrograms per cubic meter (μg/m3

) and submitted to DEQ and EPA. Preliminary data from 

October 2015 to the date of this extension request has also been below 35 μg/m3. LRAPA 

commits to providing the EPA a full calendar year of certified data no later than February 28, 

2016 along with the 98th percentile value for that data. LRAPA anticipates 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 that 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 PM2.5 attainment plan or new control strategy since it already met the 

1997 and 2006 PM2.5 standards.] 

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 representativeness of any one year or even any 3-year period. But comparing the 
Oakridge 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 during 2001-

2014. To illustrate, the 3-year 98th percentile averages for 2011-2013 and 2012-2014 at both 

the Oakridge and Eugene-Amazon stations indicate worse periods than average, and 2009-2011 

and 2010-2012 indicate better than average. 

Figure 5: PM2.5 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 PM10 and PM2.5 air pollution concentrations 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 PM10 and PM2.5.]

Several particulate matter SIP revisions were developed, submitted and approved by the EPA. 

Some of these measures were contained in previous nonattainment area SIPs, while others 

were adopted as general SIP strengthening measures. Most of the control measures in those 

SIP actions either remain part of the applicable SIP, or have been revised, updated and in the 

0

10

20

30

40

50

60

70

PM2.5 (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 PM10 and classified 

as moderate by EPA on January 20, 1994. LRAPA submitted a draft Oakridge PM10 attainment 

plan to EPA Region 10 for stringency review during early 1996. The Oakridge PM10 attainment 

plan was adopted by the LRAPA Board of Directors at a hearing on August 13, 1996. The 

Oakridge PM10 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 relied on control strategies needed to assure 

attainment of the PM10 National Ambient Air Quality Standards (NAAQS). The strategy focused

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 PM10 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 PM10 strategies were successful in achieving the PM10 standards on schedule. On 

July 26, 2001, EPA published a finding of attainment for the Oakridge PM10 area (66 FR 38947). 

The Oakridge PM10 data for 1988-2014 is outlined in Figure 6.
Oakridge Attainment Date Extension Request Page 7

Figure 6: PM10 Trend at the Oakridge WAC Monitoring Station.

The 1996 Oakridge PM10 attainment plan was successful in not only meeting the PM10

standards on schedule, but also meeting the initial national PM2.5 standards (65 μg/m3) adopted 

by EPA in 1997 as shown previously in Figure 5. The long-term PM2.5 trend, using surrogate 

monitoring methods to estimate pre-1999 PM2.5, is outlined in Figure 7.

0

50

100

150

200

250

1988 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010 2012 2014

Highest Day PM10 Concentrations (24-hr, ug/m3)

Inhalable Particulate Matter (PM10) Trend in Oakridge

Standard

Highest Day

Second Highest Day
Oakridge Attainment Date Extension Request Page 8

Figure 7: Long-Term PM2.5 Trends at the Oakridge and Eugene-Amazon Monitoring Stations.

Subsequent national health studies supported a more protective 24-hour national PM2.5 health 

standard, and EPA adopted the 35 μg/m3 standard in December 2006. Between 2006 and 2011, 

PM2.5 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 PM2.5 SIP submittal. The dominant source of PM2.5 in Oakridge on the problem winter 

days was clearly residential wood combustion (RWC) in woodstoves and fireplaces, based on 

PM2.5 emission inventories, chemical speciation of particulate filter samples, and diurnal PM2.5

concentration fluctuations. Therefore, the new strategies in the 2012 PM2.5 SIP submittal

focused primarily 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 reading for opacity enforcement; and

• Transportation and fuel-related emission reduction programs.

0

50

100

150

200

250

PM2.5 (24-hr, ug/m3, 98%ile, 3-yr avg)

Respirable Particulate Matter (PM2.5) 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 Program: The Warm Homes wood stove change-out program 

continued into 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 changeouts 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 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 substantial reductions in PM2.5 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 change-outs, 75% of the participants qualified as low-income. The poor economy in 

Oakridge makes it essential any future change-out incentives include grants to cover all of the 

cost of replacement for low income individuals and substantial (at least 50%) incentives to 

residents who are not “low income”. 
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 that 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 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: 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 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. 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 Affairs 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 fuel economy
Oakridge 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: 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. The City of Oakridge 

has enforcement authority of the ordinance. LRAPA is working with the Oakridge Police 

Department to strengthen enforcement on Red advisory days. LRAPA has provided a series of 

door hangers that can be left at a residence with an excessively smoky chimney. The door 

hangers include language from the City Ordinance, including potential fines for a violation.

Contingency Strategies: The following are contingency strategies to fully meet the air quality 

standards, if it becomes clear that the strengthened ongoing strategies described above would

not be sufficient to attain the PM2.5 standards by 2014 and or to maintain compliance with the 

standards through 2024 and beyond:

• Stricter opacity limit on all green or yellow advisory days, revising the previous 40% 

opacity limit in the city ordinance to a more restrictive 20% limit, as has been done 

in some other northwest communities. A 20% opacity limit on green and yellow 

advisory days will help reduce emissions with the goal of avoiding red advisories 

when no visible emissions are allowed.

• Stricter green-yellow-red advisory program, with more yellow and red advisory days 

each winter.

• Further restrictions on city woodstove curtailment exemptions (for sole source, 

economic hardship).

The 2012 PM2.5 SIP submittal projected attaining the standards by December 2014. Oakridge 

failed to attain the PM2.5 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 City 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 on 

supplemental strategies since October 2014. 

The following supplemental strategies are currently being implemented in addition to those 

included in the 2012 Oakridge PM2.5 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 woodstoves, prohibits unseasoned

(>20% moisture) firewood, and clarifies other requirements.

2. The City of Oakridge, with LRAPA financial assistance, hired a code enforcement officer

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 assistance 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 28 - 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 Index (AQI) reporting:

3. The City 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 extended 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 submittal of the 2012 Oakridge Attainment Plan: 15 installations in

2012, 15 in 2013, 22 in 2014, and 31 in 2015 (as of 12/10/2015). 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 Program 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 has
Oakridge 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 assistance 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 PM2.5 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 submittal 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 PM2.5 Attainment Deadline:

Clean Air Act section 188(d) provides criteria for granting an extension. 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 98th percentile PM2.5 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 

attainment 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 PM2.5 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 (12/09/2015)
Attachment 1 

Oakridge PM2.5 Attainment Plan: December 2012 Submittal as a revision to 

the State Implementation Plan 
Oakridge Fine Particulate Matter (PM2.5) Attainment Plan 

1010 Main Street 

Springfield, Oregon 97477 

November 15, 2012 Final with changes from 

Board of Director’s Adoption October 18, 2012 and 

November 15, 2012 
November 15, 2012 – Final

2

Intentionally Blank
November 15, 2012 – Final

3

Table of Contents

EXECUTIVE SUMMARY................................................................................................................7

THE OAKRIDGE PM2.5 ATTAINMENT PLAN..........................................................................................7

ATTAINMENT OF STANDARDS...........................................................................................................8

STRATEGIES AND CONTINGENCY PLAN................................................................................................9

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

Other Strategies.....................................................................................................10

Contingency Plan Elements....................................................................................11

INTRODUCTION ........................................................................................................................12

BACKGROUND............................................................................................................................12

WHAT IS PM2.5?........................................................................................................................12

NATIONAL AMBIENT AIR QUALITY STANDARDS FOR PM2.5 ...................................................................12

PURPOSE OF ATTAINMENT PLAN ....................................................................................................12

OAKRIDGE AREA DESCRIPTION.......................................................................................................13

HISTORY OF EFFORTS TO ADDRESS PARTICULATE MATTER IN OAKRIDGE...................................................15

WHAT IS IN THIS ATTAINMENT PLAN?..............................................................................................16

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

Attainment Demonstration....................................................................................17

Implementation .....................................................................................................18

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

NONATTAINMENT AREA...........................................................................................................19

AMBIENT AIR QUALITY MONITORING IN OAKRIDGE ............................................................................19

NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS)....................................................................20

Annual PM2.5 standard...........................................................................................20

24-hour PM2.5 standard..........................................................................................20

Additional Monitoring ...........................................................................................21

VERIFICATION OF MONITORING LOCATION........................................................................................22

ATTAINMENT PLAN AND DEMONSTRATION ............................................................................24

EMISSION INVENTORY ..................................................................................................................24

BASE YEAR EMISSION INVENTORY (2008) ........................................................................................24

Residential Wood Combustion ...............................................................................25

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

Industrial Point Sources..........................................................................................25

ATTAINMENT YEAR EMISSION INVENTORY (2014)..............................................................................26

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

Growth Rates.........................................................................................................27

COMPARISON OF 2008 TO 2014 EMISSIONS ....................................................................................27
November 15, 2012 – Final

4

ATTAINMENT STRATEGIES – EMISSION REDUCTION ANALYSIS ................................................................27

PARTICULATE MATTER REDUCTION STRATEGIES (1989 -2008).............................................................28

The Oakridge Air Pollution Control Ordinance #889 ..............................................28

LRAPA Advisory Programs......................................................................................29

Open Burning Ordinance........................................................................................30

Woodstove Change-out Programs.........................................................................30

Statewide Certification of Woodstoves..................................................................30

Highway Road Sanding ..........................................................................................31

Smoke Management..............................................................................................31

Road Paving ...........................................................................................................31

Industrial Requirements.........................................................................................31

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

Additional Strategies .............................................................................................32

CURRENT STRATEGIES 2009-2011.................................................................................................32

Wood Stove Change-out program..........................................................................32

Heat Smart: Stove Removal upon Sale of Home ....................................................32

Public Education.....................................................................................................33

Transportation and Fuel-Related Emissions...........................................................33

STRENGTHENED ONGOING STRATEGIES IN 2012-2014 .......................................................................33

Oakridge Air Quality Advisory Committee Strategy Recommendations ................34

Woodstove Change-outs........................................................................................34

Enforcement of Oakridge Ordinance......................................................................34

Enhancements to Key Ongoing Strategies .............................................................34

Contingency Strategies ..........................................................................................35

Industrial Emission Reductions...............................................................................35

ESTIMATED REDUCTIONS AND CREDITS FOR FUTURE STRATEGIES............................................................36

ATTAINMENT DEMONSTRATION .....................................................................................................36

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

Background on Precursors......................................................................................37

Speciated Filter Sample Analysis............................................................................38

Minor PM2.5 Components .......................................................................................39

Rollback Model ......................................................................................................40

Modeled Air Quality Improvements of the Key RWC Strategies.............................41

Unmonitored Area Analysis ...................................................................................41

Application of Future Strategies ............................................................................42

Contingency Plan ...................................................................................................42

ACKNOWLEDGEMENTS.............................................................................................................45

OAKRIDGE ADVISORY COMMITTEE ..................................................................................................45

PRINCIPAL AUTHORS....................................................................................................................45

CONTRIBUTORS ..........................................................................................................................45
November 15, 2012 – Final

5

TABLE OF TABLES

TABLE 1: PM2.5 ATTAINMENT DEMONSTRATION.....................................................................................9

TABLE 2: 2002-2003 OAKRIDGE MONITORING SURVEY RESULTS .............................................................23

TABLE 3: 2008 ESTIMATED TYPICAL SEASON DAY AND WORST-CASE DAY PM2.5 EMISSIONS..........................24

TABLE 4: 2014 ESTIMATED TYPICAL SEASON DAY AND WORST-CASE DAY PM2.5 EMISSIONS..........................27

TABLE 5: OAKRIDGE WOOD CHANGE-OUT PROGRAMS (1993-96/2006-07) .............................................30

TABLE 6: OAKRIDGE WOOD CHANGE-OUT PROGRAMS (2009/2010-11) ..................................................32

TABLE 7: ANNUAL PM2.5 VALUES USED TO CALCULATE BASELINE DESIGN VALUE.............................................37

TABLE 8: CONTRIBUTION BY SPECIATED COMPONENTS. RESULTS OF SANDWICH ANALYSIS FOR THE TOP 25% HIGH

CONCENTRATION WINTER (OCT-MAR) DAYS. ................................................................................39

TABLE 9: BASELINE AND FUTURE PROJECTED DESIGN VALUES ....................................................................40

TABLE 10: ALLOCATION OF EMISSIONS AND MODELED CONCENTRATIONS FOR BASE AND FUTURE YEARS. .............42

Table of Figures

FIGURE 1: OAKRIDGE NONATTAINMENT AREA 2008 WORST CASE DAY EMISSIONS.........................................8

FIGURE 2: SPECIAL PROTECTION ZONE SURROUNDING OAKRIDGE..............................................................10

FIGURE 3: OAKRIDGE LOCATION........................................................................................................14

FIGURE 4: NONATTAINMENT AREA.....................................................................................................15

FIGURE 5: PM2.5 ANNUAL STANDARD COMPARISON CONCENTRATIONS FROM THE OAKRIDGE MONITOR. ............20

FIGURE 6: PM2.5 24-HOUR STANDARD COMPARISON CONCENTRATIONS FROM THE OAKRIDGE MONITOR............21

FIGURE 7: NEPHELOMETER ESTIMATED PM2.5 FOR OAKRIDGE AND WESTFIR DURING WINTER 2009-2010. ........22

FIGURE 8: 2002-2003 OAKRIDGE MONITORING SURVEY SITE MAP..........................................................22

FIGURE 9: OAKRIDGE PM2.5 EMISSION INVENTORY FOR 2008 WORST WINTER DAYS ...................................25

FIGURE 10: SPECIATED COMPONENTS OF PM2.5 (USING SANDWICH ANALYSIS) .........................................38

Image

IMAGE 1: SMOKE INVERSION OVER OAKRIDGE, WHERE THE WILLAMETTE ACTIVITY CENTER IS LOCATED. THE 

PARTICULATE MATTER TRAPPED NEAR THE SURFACE BY A TEMPERATURE INVERSION IS CLEARLY VISIBLE.........19
November 15, 2012 – Final

6

Table of Appendices

A) Unmonitored Area Analysis (UMAA)

1) Saturation Survey

B) Meteorological conditions

C) Growth projections

1) Population & household (census 2010)

2) Employment

3) Vehicle Miles Traveled (VMT) from Lane Council of Governments (LCOG)

D) Emission inventory

E) Speciation studies

1) SANDWICH (Sulfate, Adjusted Nitrate, Derived Water, Inferred 

Carbonaceous Material Balance Approach)

2) Positive Matrix Factorization (PMF) model

F) Strategies

1) Oakridge ordinance

2) Smoke Management Directive

3) Title 38 – Major New Source Review

4) Woodstove Changeout list

5) Oakridge Advisory Committee Report

6) Oakridge Title IX – General Regulations (see p.25)

G) Design Value

H) Rollback Modeling

I) Transportation Analysis

J) RACT/RACM Analysis

K) Transportation Conformity Analysis
November 15, 2012 – Final

7

EXECUTIVE SUMMARY

The U.S. Environmental Protection Agency (EPA) adopted revisions to the National Ambient Air 

Quality Standards (NAAQS) for PM2.5 in September 2006. PM2.5 is fine particulate matter two 

and a half microns and less in diameter, or about 1/28th the diameter of a human hair. Also 

referred to as respirable particulate matter, these tiny particles are inhaled deep into the lungs 

where they accumulate and aggravate respiratory conditions, particularly asthma. Fine 

particulate (PM2.5 microns and smaller) are associated with heart and lung disease, increased 

respiratory symptoms and disease, decreased lung function, and premature death. Chronic 

exposure to fine particulate has also been implicated in increased risk for cardiac events. 

Populations especially at risk include children, the elderly, and those with existing health 

problems.

On October 8, 2009, the Environmental Protection Agency (EPA) issued final area nonattainment designations for the 24-hour national air quality standards for fine particulate 

matter (PM2.5). Oakridge was designated a non-attainment area in Oregon. Under the Clean 

Air Act, an area that violates the federal standards is designated as “nonattainment” and must 

adopt a plan with emission reduction measures to bring the area back into compliance. The 

area designated as non-attainment for PM2.5 contains Oakridge, the small town of Westfir and 

surrounding area. 

The Oakridge PM2.5 Attainment Plan

The City of Oakridge has struggled to meet air quality standards. Oakridge was proposed a PM10

“non-attainment” area in September 1992, and designated on January 20, 1994. The City last 

exceeded that standard in 1993. Voluntary measures to reduce wood smoke emissions 

adopted in 1999 have reduced measured particulate levels. Progress in reducing wood smoke 

emissions made it possible for the City of Oakridge to meet the 1997 PM2.5 standard of 65

μg/m

3

. Despite progress in improving air quality, the tightening of the PM2.5 standard in 2006 

presented yet another challenge.

Local climate and topography make Oakridge prone to wintertime temperature inversions, low 

wind speeds and poor atmospheric dispersion. During the winter months, Oakridge air quality 

is often threatened due to high concentrations of smoke from woodstoves settling on the valley 

floor of the city. Figure 1 shows the worst case day1contribution of each of these source 

categories in the Oakridge nonattainment area. 

 

1

A worst case day is defined as a design value corresponding to the 98th percentile of the data collected for a given 

year or an average of the 98th percentile of three years.
November 15, 2012 – Final

8

Figure 1: Oakridge Nonattainment Area 2008 Worst Case Day Emissions

Attainment of Standards 

Despite significant progress in reducing particle pollution, the Oakridge area exceeded and 

consequently violated the federal 24-hour fine particulate (PM2.5) 2006 standard of 35 μg/m

3

but complied with the annual PM2.5 standard of 15 μg/m3in the 2001-2011 period. PM2.5 

concentrations above the 24-hour standard during this period are linked to wintertime 

inversions and high emissions.

The main purpose of the Oakridge PM2.5 attainment plan is to return the Oakridge area back to 

compliance with the 2006 24-hour standard by 2014 as required by federal law. Oakridge does 

not violate the annual PM2.5 standard. This attainment plan fulfills federal requirements 

regarding EPA designated nonattainment areas.

The City of Oakridge has taken steps to address pollution from woodstoves. On February 20, 

2003, the Oakridge City Council adopted a home wood heating ordinance that:

Changed previous voluntary woodburning curtailment measures to mandatory,

Prohibited burning garbage in woodstoves and fireplaces, 

Incorporated a 40% opacity limit on chimneys,

Incorporated the PM2.5 standard into the program, and

Required the removal of uncertified woodstoves from property to be sold or rented. 

Industry

0.2%

Open Fireplaces

7.7%

Non-Certified 

Woodstoves

31.7%

Certified 

Woodstoves

45.4%

Pellet Stoves

1.3%

Other Area 

Sources

0.9%

On-Road Cars & 

Trucks

6.8%

Re-entrained 

Road Dust

5.0%

Railroads

1.1%

Oakridge PM2.5 Emission Inventory for 

2008 Worst Winter Days
November 15, 2012 – Final

9

In December 2008, the Oakridge City Council passed an ordinance prohibiting the use of an 

uncertified solid fuel heating device in a residence. The Lane Regional Air Protection Agency 

(LRAPA) has also worked closely with the City of Oakridge and other partners to help residents 

replace old, uncertified wood stove with new, cleaner burning and energy efficient heating 

systems. LRAPA also issues daily home wood heating advisories November 1 through the last 

day of February. When air quality is forecast to be in the unhealthy for sensitive groups range, 

LRAPA activates an automatic “callware” system to alert residents by telephone about burning 

restrictions.

The use of these strategies and others identified by an advisory committee should further 

reduce ambient concentration of PM2.5 below the national health-based standard by 2014. The 

estimated ambient concentrations for both the annual and the worst case day are predicted to 

decrease based on a ratio of the 2008 ambient concentration to the projected emission 

inventory for the year 2014.

The base year Design Value concentration confirms that additional strategies, beyond those 

implemented by 2008, are needed to bring the area into attainment. The future year 

concentration in Table 1 is based on implementation of the additional strategies and confirms 

that these strategies will be sufficient to meet the federal 24-hour standard by 2014.

Base Year Future Year

Worst Case Day 

Concentration 39.5 μg/m3

28.2 μg/m3

Federal Standard 35 μg/ m3

35 μg/ m3

Table 1: PM2.5 Attainment Demonstration

Strategies and Contingency Plan

Woodstove Curtailment and other Woodstove Strategies 

Oakridge has been proactive in adopting a number of strategies to reduce emissions from home 

wood heating. These strategies include:

City ordinances to curtail burning during stagnant weather periods.

City ordinance requiring the removal of an uncertified wood stove upon sale of a 

home.

City ordinance prohibiting the use of a noncertified wood stove in a residence.

Partnering in additional change-out programs to encourage removal of noncertified 

stoves.
November 15, 2012 – Final

10

A new stove certification program by EPA and the woodstove replacement programs continue 

to result in a significant emissions reduction in Oakridge. The continued replacement of older 

woodstoves coupled with better enforcement of daily advisories is expected to continue to 

decrease emissions through 2014 even with a moderate growth in households. 

Other Strategies

Curtailing open burning has been identified as a way to reduce PM emissions. The Oakridge 

City Ordinance prohibits burning within the City limits on days with high concentrations of 

particulate matter in the month of October and March 1 – June 15. All open burning is 

prohibited between November 1 and February 28 inside the City limits. 

Oregon Department of Forestry (ODF) requires federal land managers to follow strict smoke 

management instructions and avoid smoke impacts to Oakridge. ODF has designated Oakridge 

as a Special Protection Zone (SPZ) shown in Figure 2. During the November 15 through 

February 15 period, prescribed burning in the SPZ is allowed only when the ODF smoke 

management meteorologist believes there will be no measurable smoke impacts within the 

nonattainment area. The SPZ prohibits any prescribed burning on red advisory days.

Figure 2: Special Protection Zone Surrounding Oakridge
November 15, 2012 – Final

11

Contingency Plan Elements

The following strategies will be implemented as contingency strategies to fully meet the air 

quality standards, if it becomes clear that the strengthened ongoing strategies will not be 

sufficient to attain the PM2.5 standards by 2014 and or to maintain compliance with the 

standards through 2024 and beyond:

• Stricter opacity limit on all green or yellow advisory days, revising the current 40% 

opacity limit to a more restrictive 20% limit, as has been done in some other 

northwest communities. A 20% opacity limit on green and yellow advisory days will 

help reduce emissions with the goal of avoiding red advisories when no visible 

emissions are allowed.

Stricter green-yellow-red advisory program, with more yellow and red advisory days 

each winter.

Further restrictions on the city woodstove curtailment exemptions (for sole source, 

economic hardship).

If Oakridge meets the EPA Clean Air Act deadline for meeting the standard, the contingency 

plan will not be implemented. While this plan is not intended to attain any proposed standard, 

LRAPA estimates that Oakridge will meet a tightened annual standard of 12 μg/m3.
November 15, 2012 – Final

12

INTRODUCTION

Background

This plan addresses the 24-hour and the annual ambient air quality standards for PM2.5 as 

defined in the federal Clean Air Act. In September 2006, the U.S. Environmental Protection 

Agency (EPA) strengthened the daily (24-hr) PM2.5 (fine particulate) standard by lowering the 

level from 65 g/m3to 35 g/m3and retained the annual PM2.5 standard of 15 g/m3. Areas in 

violation of the PM2.5 standard (based on the most recent three years of federal reference 

monitoring data) are designated as a “nonattainment area” by the EPA. Oakridge, Oregon has 

been designated as nonattainment for the daily PM2.5 standard. The Lane Regional Air 

Protection Agency (LRAPA) must develop an attainment plan that will bring air quality into 

compliance with the standard as soon as possible, and submit this plan to EPA.

What is PM2.5?

Particulate matter (PM) is the general term used for a mixture of solid particles or liquid 

droplets found in the air. Some particles are large or dark enough to be seen as soot or smoke. 

Others are so small they can be detected only with an electron microscope. These particles 

come in a wide range of sizes (“fine” particles are less than 2.5 micrometers in diameter and 

coarser-sized particles are larger than 2.5 micrometers), and originate from many different 

sources. Fine particles (PM2.5) generally result from fuel combustion from residential fireplaces 

and woodstoves, pile and forest burning, industrial facilities, and motor vehicles. Coarse 

particles (PM10) are generally emitted from sources such as vehicles traveling on paved and 

unpaved roads, materials handling, and wood products operations, as well as wind-blown dust. 

These particles can accumulate in the respiratory system and are associated with numerous 

health effects. Fine particles are most closely associated with such health effects as increased 

hospital admissions and emergency room visits for heart and lung disease, increased 

respiratory symptoms and disease, decreased lung function and premature death. Sensitive 

groups that are at greatest risk include the elderly, individuals with cardiopulmonary disease 

such as asthma, and children. 

National Ambient Air Quality Standards for PM2.5

EPA has established National Ambient Air Quality Standards (NAAQS) for PM2.5 at 35 

micrograms per cubic meter (μg/m3) for a daily (24-hour) standard and 15 μg/m3as an annual 

standard. Any value monitored above these levels, as defined by federal rules and guidance, is 

considered an exceedance. EPA uses the 98th percentile of the 24-hr PM2.5 within any given 

year and averages it over three calendar years. An exceedance of the average 98th percentile 

over three years greater than 35 μg/m3is considered a violation. An exceedance of the annual 

standard averaged over three years becomes a violation of the annual standard. If an area 

violates either standard, EPA designates it as a nonattainment area. This plan includes a 

demonstration of continuing attainment with both standards.

Purpose of Attainment Plan

This document provides a pathway for continued improvement to reduce particulate emissions 

and to return the Oakridge Nonattainment Area (NA) to attainment for PM2.5 (state 
November 15, 2012 – Final

13

classification will be “maintenance”) by achieving the more protective national health standards 

adopted in 2006. It is a plan to ensure Oakridge meets the 24-hour and annual National 

Ambient Air Quality Standards for PM2.5 and maintains the annual standard for PM2.5. This 

document complies with the applicable 1990 Federal Clean Air Act (CAA) requirements and 

Environmental Protection Agency (EPA) guidance and policies. The attainment plan provides 

strategies to meet the PM2.5 standards by 2014 and provides contingency measures should 

Oakridge not meet the deadline. To demonstrate "attainment" requires the collection of 

representative monitoring data using approved measuring instruments and procedures, with 

adequate quality assurance. EPA will review the plan to determine if it is approvable and 

publish its findings in the Federal Register. Redesignation back to attainment is possible only 

after Oakridge meets the standards for three consecutive years and a maintenance plan is 

drafted, adopted by the LRAPA Board of Directors, the Environmental Quality Commission 

(EQC) and approved by EPA. EPA will then formally redesignate Oakridge back into attainment 

in the Federal Register.

Oakridge Area Description

Oakridge, Oregon lies in an alluvial plain in the foothills at the southern end of the Willamette 

River valley. The city is in Lane County, Oregon, approximately 45 miles east-southeast of 

Eugene, and 28 miles west of Willamette Pass, the summit of the Cascade Mountain Range. 

The city limits of present-day Oakridge includes the historic City of Oakridge and, directly west, 

the area formerly known as Willamette City. Figure 3 shows the location of Oakridge in Lane 

County.
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 situated in a valley oriented east-west, through which flows the middle 

fork of the Willamette River. Elevation of the area ranges from 1100 feet at the lower (west) 

end to 1600 feet with areas of densest population situated between 1100 feet and 1200 feet. 

Mountains rise on the north and south sides to 1700 feet and 1600 feet, respectively. 

Westfir is a very small (population 335) isolated rural mountain community that is located along 

the north fork of the Willamette River about 1 mile NW of Oakridge. Its elevation is about the 

same as Oakridge and it is surrounded by the same high mountains. Westfir and Oakridge are 

in separate steep sided river valleys separated by a 400-foot ridge. The Westfir valley is very 

narrow, only about 1/4 mile across at its widest point, while the Oakridge valley is about 1 mile 

across at its widest point.

History of Efforts to Address Particulate Matter in Oakridge 

Oakridge has historically struggled with air quality issues during the winter months, especially 

on cold days during periods of air stagnation. Oakridge was proposed a PM10 non-attainment 

area in December 1993, effective on January 9, 1994. PM10 is defined as particulate matter 

with an aerodynamic diameter less than or equal to a nominal 10 micrometers as measured by 
November 15, 2012 – Final

16

an approved method listed in 40 CFR 53. Initial efforts to curtail wood smoke were developed 

for the Oakridge Urban Growth Boundary (UGB) by 1991, however, at that time the area still 

had not met the standard. LRAPA subsequently submitted a formal PM10 plan to EPA in 1996. 

EPA approved the attainment plan on May 14, 1999. One of the key strategies in the plan 

included a mandatory woodstove curtailment program and a woodstove change-out program. 

On March 19, 1992, the Oakridge City Council amended its open burning ordinance #689 to 

allow open backyard burning only during the months of October, March, April, and May and 

bans the use of burn barrels. Oakridge City Code 92.04.A.2 currently regulates open backyard 

burning inside the Oakridge city limits. This eliminated burning during wintertime periods of 

maximum atmospheric stagnation when burning is more likely to contribute to exceedances of 

the 24-hour standard. An aggressive wood stove change-out project, along with a voluntary 

residential wood burning advisory program, further reduced winter time PM10 emissions. In a 

letter of agreement with the Oregon Department of Transportation (ODOT), dated July 29, 

1996, ODOT agreed to use a chemical de-icing compound on Highway 58 as an alternative to 

sanding roads during the winter season. As a result of these strategies, the area was able to 

meet and continue to meet the PM10 standards from 1994 to present. 

EPA revised the particulate standard in 1997 to include PM2.5 and established a daily standard 

of 65 μg/m3. LRAPA began monitoring fine particulate matter (PM2.5) concentrations in 1998.

The original PM10 strategies included in the 1996 attainment plan were so successful in 

maintaining clean air that Oakridge also met the fine particulate (PM2.5) standard. 

In 2006, EPA modified the PM2.5 standard, cutting the threshold for the 24-hour exceedance 

day roughly in half to 35 μg/m3. Oakridge has not yet been able to meet this new daily PM2.5 

standard, so continued progress is need to further reduce particulate emissions. LRAPA has 

measured PM2.5 at the same location in the Oakridge (Willamette Activity Center) since 1998 

and PM10 since 1989. LRAPA has also operated a nephelometer in Oakridge since 1989 which 

makes it possible to estimate PM2.5 during 1989-1998. Many of the same pollutant sources for 

PM10 are the same for PM2.5. 

Between 2006 and 2011, PM2.5 concentrations in Oakridge on worst winter days violated the 

more protective 24-hour national health standard adopted in 2006. There were no 

exceedances of the annual PM2.5 standard. EPA’s deadline for meeting the standards is 

December 2014. Emission reduction strategies included in this plan should provide compliance 

with the Clean Air Act Amendments even with a modest population growth. If the community 

fails to meet the standard by 2014, automatic contingency measures will be implemented and 

are clearly identified in this plan.

What is in this Attainment Plan?

Nonattainment Area

The plan provides an analysis of the existing nonattainment area situation. It describes the past 

and the current state of air quality. It identifies and quantifies the current nature of the air 

quality problem.
November 15, 2012 – Final

17

Attainment Demonstration

The key component of the plan is in the attainment demonstration analysis where emissions 

are predicted into the future but strategies are identified to reduce emissions. There is also an 

explanation of the past and current economic situation and past and current meteorological 

situation. It predicts air quality into the future based on a growth analysis to show how much 

worse the air quality can become. It tells how the air quality can improve by implementing 

these various approaches or tactics to reduce emissions enough to meet the standards. Credit 

is given to each strategy or tactic and emission reductions are estimated into the future. It 

provides for a commitment by the community to return Oakridge to attainment status and 

explains and quantifies those commitments. The commitment shows how to improve air 

quality by using these strategies and promises to watch for changes to assure the commitment 

is met. If the commitment is not met, it identifies what future additional strategies will be 

necessary to implement immediately, should the initial commitments fail to meet the standard 

by 2014.

The following strategies are in place and critical for meeting the PM2.5 air quality health 

standards by 2014:

• Woodstove change-out programs. A model is in place to replace non-certified 

woodstoves with heat pumps, pellet stoves, or high-efficiency certified woodstoves.

The current funding has been committed, and the most recent phase of this

program was completed during December 2011.

• Continue woodstove-fireplace curtailment program (green-yellow-red advisories, 

with curtailment required during air stagnation pollution episodes); the city 

ordinance requires curtailment on red days; LRAPA provides the daily air quality and 

meteorological forecasts during November-February.

• Continue program prohibiting backyard/open burning: Burning of garbage is 

prohibited at all times; city ordinance prohibits open burning of yard debris during 

November-February; LRAPA provides daily open burning advisory during March-May 

and October; and open burning is prohibited in June-September during the fire 

season established by fire departments.

• Maintain the Special Protection Zone for Oakridge as required in the ODF smoke 

Management Plan. 

• Continue outdoor recreational fire (chimineas and other patio heaters) program; 

LRAPA rules prohibit outdoor recreational fires on yellow-red advisory days during 

November-February.

• Continue Oregon Heat Smart program; requires removal of non-certified 

woodstoves upon home sale, and prohibits burning of garbage in woodstoves and 

fireplaces.

• Prohibit the use of uncertified woodstoves

The plan proposes strengthening existing strategies and introduces new strategies to be 

implemented in the community. The plan demonstrates that new and continued permanent 

and voluntary strategies are sufficient to meet the PM2.5 standards by 2014 and the community 

will continue to meet the standard into the future. 
November 15, 2012 – Final

18

The primary source of PM2.5 in Oakridge is residential wood heating. The most serious PM2.5

problems occur during the winter in the urban area of Oakridge, when cooler temperatures 

trap particles near the ground by atmospheric inversions. Monitoring data clearly shows the 

high particulate levels occurring during the nighttime periods with light winds and strong 

temperature inversion. The levels drop significantly after sunrise. These diurnal high and low 

concentration periods also correspond to the general use of woodstoves as home heating 

devices. The emissions are greatest during the evening and nighttime periods.

Implementation

The plan describes final commitments by Oregon and the Oakridge community to make the 

plan work. It outlines the commitment for LRAPA to work with the local community to find 

solutions to the air quality problem. 

Attainment Plan Development Process

LRAPA used the 2008 PM2.5 emission inventory and the feedback of the Oakridge Advisory 

Committee, the Lane Council of Governments (LCOG), and the Oregon Department of 

Transportation (ODOT) to develop the PM2.5 attainment plan. The Advisory Committee 

prepared a list of strategies that was submitted to LRAPA for inclusion in the plan. 

Additional strategies recommended by the committee are included in the Attainment Plan and 

Demonstration section of this document. The LRAPA Advisory Committee and the Oregon

Department of Transportation also reviewed and made recommendations on the plan.
November 15, 2012 – Final

19

NONATTAINMENT AREA 

Since the 1990s, Oakridge has undertaken many efforts to manage or control particulate 

emissions. For example, efforts have been made on several occasions to improve air quality by

implementing very stringent controls such as a clean air ordinance to regulate both burning in 

woodstoves and open burning. Due to the success of these programs to address PM10

emissions, when EPA revised the PM standard in 1997 to include PM2.5, Oakridge was in 

compliance. Despite these aggressive efforts, in 2006 when the PM2.5 standard was revised 

Oakridge found itself in violation of the 24-hour PM2.5 standard. 

Ambient Air Quality Monitoring in Oakridge

The Oakridge area has one particulate (PM2.5) monitoring site with the sampler located at 

47674 School Street, also known as the Willamette Activity Center. LRAPA has monitored at 

the Willamette Activity Center site since 1987 for PM10 and since 1998 for PM2.5. After rigorous 

quality assurance, the data from the Willamette Activity Center site is transferred to ODEQ and 

on to EPA’s database. The data from the Willamette Activity Center monitor was used as the 

basis for the nonattainment determination and for determining compliance with the standard. 

Image 1: Smoke inversion over Oakridge, where the Willamette Activity Center is located. The particulate matter 

trapped near the surface by a temperature inversion is clearly visible.
November 15, 2012 – Final

20

National Ambient Air Quality Standards (NAAQS)

As mentioned previously, in 2006 the EPA revised the PM2.5 standard to more accurately reflect 

the latest health information. EPA revised the 24-hour standard from 65 μg/m3to 35 μg/m3, 

and kept the annual standard at 15.0 μg/m3. EPA determines compliance with the PM2.5 

standards based on averaging air quality measurements both annually and on a 24-hour basis.

Annual PM2.5 standard

The annual standard for PM2.5 is met whenever the three year average of the annual mean 

PM2.5 concentrations for a designated monitor is less than or equal to 15.0 μg/m3. Oakridge has 

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

Figure 5: PM2.5 Annual Standard comparison concentrations from the Oakridge monitor.

24-hour PM2.5 standard

The 24-hour standard for PM2.5 is met whenever the three year average of the annual 98th

percentile of values at a monitoring site is less than or equal to 35 μg/m3. The 98th percentile is 

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

standard instead of the maximum observation for any given year. By doing so, EPA ensures 

infrequent peaks are ignored and a more robust value is used for comparison. 

From 2001 through 2005, Oakridge was in compliance with the PM2.5 standard of 65 μg/m3. 

However in 2006, when EPA revised the standard to 35 μg/m3, Oakridge violated the 24-hour 

standard. The three year average 98th percentile for the Oakridge monitoring site has 

continued to violate the 24-hour standard each year since the standard tightened in 2006, but 

has decreased significantly over the period 2006 - 2011.

13.2 13.7 13.4 12.8 12.4 12.0 11.5 11.0 11.0 10.5

8.9

0

2

4

6

8

10

12

14

16

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

μg/m3

Oakridge PM2.5: 3-year Average of Annual Means

Willamette Activity Center Annual PM2.5 Standard
November 15, 2012 – Final

21

Figure 6: PM2.5 24-hour Standard comparison concentrations from the Oakridge monitor.

Additional Monitoring

In addition to the Oakridge Federal Reference Method (FRM) monitor, between October 2009 

and March 2010, investigative monitoring was done in the Westfir area to determine PM2.5

concentrations there, and relative difference from the Willamette Activity Center monitor. 

Several saturation samplers and a Nephelometer were used for this purpose. Figure 7 shows 

the relative PM2.5 concentrations, as a function of Nephelometer light scattering, of Westfir and 

Oakridge. More information regarding the methods and results of this monitoring is available 

in Appendix A.1.

56.2 55.6 56.1 51.6 52.6 47.7 46.6

40.0 40.9 37.7 38.8

0

10

20

30

40

50

60

70

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

μg/m3

Oakridge PM2.5 : 3-year Average of Annual 98th Percentile

Willamette Activity Center 24-Hour Standard
November 15, 2012 – Final

22

Figure 7: Nephelometer estimated PM2.5 for Oakridge and Westfir during winter 2009-2010.

Verification of Monitoring Location

LRAPA has conducted a field study to verify that the Willamette Activity Center PM2.5

monitoring site generally represents peak level PM2.5 concentrations within Oakridge, and is the 

most appropriate location for a PM2.5 monitor. The one year, six site monitoring survey was 

conducted in 2002-2003, and is attached in Appendix A. Results are summarized in Figure 8

and Table 2.

Figure 8: 2002-2003 Oakridge Monitoring Survey Site Map
November 15, 2012 – Final

23

n

(max 

103)

Capture 

rate

Annual 

mean

μg/m3

Maximum 

value 

μg/m3

n > 15 

μg/m3

Difference 

from 

primary 

(MV401)

(%)

WAC FRM 100 96% 12.8 56.8 28 -

MV401 (primary) 99 95% 13.6 58.1 29 -

MV402 (duplicate) 96 92% 13.5 57.1 28 -

MV403 95 91% 10.9 53.3 18 -19.9

MV404 100 96% 11.4 41.0 23 -16.2

MV405 94 90% 8.3 42.3 8 -39.0

MV406 96 92% 8.6 36.7 14 -36.8

MV407 98 94% 13.0 47.6 26 -4.4

Table 2: 2002-2003 Oakridge Monitoring Survey Results

Findings of this survey agreed with those of PM10 saturation studies from 1991 and 1994. 

Within Oakridge the highest levels were found in the southwestern portion of the town. 

Therefore, it was confirmed that this site represents peak levels of PM2.5 concentrations in 

Oakridge. In addition, the Willamette Activity Center monitor also represents an area where 

people live, work, and play, reconfirming the monitor location is the most appropriate for 

Oakridge.
November 15, 2012 – Final

24

ATTAINMENT PLAN AND DEMONSTRATION

Emission Inventory

An emission inventory consists of emission estimates from sources that emit PM2.5 within the 

Oakridge nonattainment area boundary. The emissions inventory data is essential in 

developing the attainment demonstration, as it helps identify the sources contributing to the 

air quality problem and the emission reduction strategies, once implemented, that reduce 

pollution levels below the standard. Sources of PM2.5 in Oakridge include minor industry, onroad mobile sources (e.g., car and truck exhaust, road dust), railroads, and area sources (e.g., 

outdoor burning, woodstoves, and fireplaces). 

Base Year Emission Inventory (2008)

The base year emission inventory is used as the starting point for the attainment 

demonstration. This inventory includes sources in the nonattainment area during the 2008 

baseline year. 

The 2008 emission inventory is summarized in Table 3 and Figure 9. The calculation procedures 

are included in Appendix D.

-- lbs/per day -- Percent of Total NAA Emissions

Typical Season Day Worst-Case Day Typical Season Day Worst-Case Day

Permitted Point Sources(1)

Oakridge Sand & Gravel: Rock crushing operation 0.4 0.8 0.1% 0.1%

Oakridge Sand & Gravel: Cement plant 0.1 0.1 0.0% 0.0%

Stationary Area Sources

Residential Wood Combustion: Fireplace(2) 38.5 42.3 7% 8%

Residential Wood Combustion: Non-Certified 

Woodstove/Insert(2) 158.9 174.8 30% 32%

Residential Wood Combustion: Certified 

Woodstove/Insert(2) 228.0 250.8 43% 45%

Pellet Stoves 6.7 7.4 1% 1%

All Other Stationary Area Sources 47.4 4.7 9% 1%

On-Road Sources

On-Road: Exhaust, Brake, Tire 26.6 37.3 5% 7%

Re-Entrained Road Dust 12.1 27.8 2% 5%

Nonroad Sources

Union Pacific Railroad 6.0 6.0 1% 1%

Total, All Sources, lbs/day 525 552

(1) Worst-case day = Peak month production/20 workdays. 

(2) Worst-case day = Peak Heating Degree Day

Table 3: 2008 Estimated Typical Season Day and Worst-Case Day PM2.5 Emissions.

The emissions inventory on worst winter days is of most interest since the PM2.5 concentrations 

measured in Oakridge do not meet the current 24-hour PM2.5 standard and the peak PM2.5

concentrations occur on cold, stagnant days during the November-February wood-heating 

season. Residential wood-heating emissions (from certified and non-certified woodstoves, 

fireplaces, and pellet stoves) account for about 86% of the emissions on worst winter days, as 

illustrated in Figure 9.
November 15, 2012 – Final

25

Figure 9: Oakridge PM2.5 Emission Inventory for 2008 Worst Winter Days

Residential Wood Combustion

Residential wood combustion is a common way to heat homes in Oregon. To estimate 

emissions from wood burning, LRAPA conducted a survey for the 2009-2010 heating season in 

Oakridge-Westfir. The survey provided LRAPA with information on how many homes use 

various types of wood-heating devices, the amount of wood burned, and other information on 

wood-heating practices. 

Mobile and Nonroad Sources

Road dust and tailpipe emissions of PM2.5 from motor vehicles were calculated by Lane Council 

of Governments (LCOG) transportation staff by applying emission factors from the EPA MOVES 

computer program to total vehicle miles traveled in the nonattainment area. Estimated vehicle 

miles traveled are from previous transportation modeling by LCOG for the Oregon Department 

of Transportation. Emissions from railroads were provided by Union Pacific Railroad staff using 

the EPA NONROAD2008a emissions protocol. 

Industrial Point Sources

LRAPA maintains data on industrial point source emissions in Lane County. The only operating 

industrial point sources within Oakridge-Westfir area are two minor aggregate industry sources 

operated by Oakridge Sand & Gravel. 

Industry

0.2%

Open Fireplaces

7.7%

Non-Certified 

Woodstoves

31.7%

Certified 

Woodstoves

45.4%

Pellet 

Stoves

1.3%

Other Area 

Sources

0.9%

On-Road Cars & 

Trucks

6.8%

Re-entrained 

Road Dust

5.0%

Railroads

1.1%

Oakridge PM2.5 Emission Inventory for 

2008 Worst Winter Days
November 15, 2012 – Final

26

Attainment Year Emission Inventory (2014) 

The attainment year inventory is an estimation of emissions for the year that the area is 

expected to have attained the PM2.5 standard. It includes projected emissions for the 

attainment year based on a number of different factors. Growth rates for population, 

employment, and VMT through 2014 were used to estimate 2014 emissions. LRAPA took credit 

for emissions reductions as a result of the woodstove replacement project implemented during 

2009-2012 that reduced the number of non-certified woodstoves accounted for in the 2008 

emission inventory. 

The attainment year emission inventory is based on 2008 emissions inventory, estimated 

growth rates and the emission reduction strategies that have recently been put into effect. The 

emission reduction strategies primarily include the continued implementation (with specific 

strengthening revisions in some cases) of the existing control measures that have been 

effective in achieving the PM10 standards and the initial (1997) PM2.5 standards on schedule. 

The key ongoing control strategies, which were in place prior to 2008, include: 

• City ordinance to curtail burning during stagnant weather periods;

• City ordinance requiring the removal of a non-certified wood stoves upon sale of a 

home;

• City ordinance prohibiting the use of a non-certified wood stove in a residence; and

• Partnering in additional change-out programs to encourage removal of non-certified 

woodstoves.

Details of the ongoing control strategies, strengthened control strategies, and contingency

measures are described in the subsequent section on the Oakridge Advisory Committee 

recommendations. 

Economic Factors

The economy in Oakridge has shifted from logging-based industries to a more recreationoriented model. The decline in the harvesting and processing of timber has left Oakridge with 

no industrial employer or businesses that support the lumber industry. In the 1990’s, the 

population in Oakridge declined sharply as jobs disappeared. Current census figures show only 

modest growth of 1.8% between 2000 and 2010, with the current population at 3,205. Within 

the civilian labor force, 16% were unemployed in 2010 and 21.7% of all families had incomes 

below the poverty level. The low cost of living has attracted low-income and unemployed 

people to Oakridge.

The recreation industry has picked up in Oakridge, with mountain biking being very popular. A 

hostel, brew pub, and other small businesses have opened to support the visitors attracted to 

the area. Despite the recent business growth, few jobs have been created. Population and 

employment in Oakridge are expected to increase only modestly over the next 20 years. The 

population estimate for the year 2025 is 4,000. Any new employment has been assigned to the 

potential development of the Oakridge Industrial Park.
November 15, 2012 – Final

27

Growth Rates

Growth is expected to be low to moderate in the Oakridge-Westfir area through 2014. 

Population, housing, and employment forecasts are expected to increase gradually. VMT 

growth is based on the previous transportation modeling by LCOG in the Highway 58 corridor.

The 2014 emission inventory is summarized in Table 4. The calculation procedures are included 

in Appendix D.

Percent of Total

-- lbs/per day -- NAA Emissions

Typical Season 

Day

Worst-Case 

Day

Typical Season 

Day

Worst-Case 

Day

Permitted Point Sources(1)

Oakridge Sand & Gravel: Rock crushing operation 1.7 4.0 0.4% 1.1%

Oakridge Sand & Gravel: Cement plant 4.3 14.0 0.9% 3.7%

Stationary Area Sources

Residential Wood Combustion: Fireplace(2) 38.5 29.6 8% 8%

Residential Wood Combustion: Non-Certified Woodstove/Insert(2) 106.1 81.7 22% 21%

Residential Wood Combustion: Certified Woodstove/Insert(2) 252.4 194.4 52% 51%

Pellet Stoves 7.3 8.0 1% 2%

All Other Stationary Area Sources 47.4 4.7 10% 1%

On-Road Sources

On-Road: Exhaust, Brake, Tire 15.7 22.2 3% 6%

Re-Entrained Road Dust 7.1 16.3 1% 4%

Nonroad Sources

Union Pacific Railroad 6.0 6.0 1% 2%

Total, All Sources, lbs/day 486 381

(1) Worst-case day = Permitted hourly (x24) operating capacity 

(2) Worst-case day = Peak Heating Degree Day

Table 4: 2014 Estimated Typical Season Day and Worst-Case Day PM2.5 Emissions.

Comparison of 2008 to 2014 Emissions

The emission inventory shows an overall decrease in emissions for the attainment year (2014) 

based on the effectiveness of the emission control strategies.

The differences in the 2008 and 2014 emission inventories are the combination of increases 

due growth factors and decreases due to emission control strategies. For example, motor 

vehicle emissions decreased overall due to progressively cleaner gasoline and diesel fuels and 

motor vehicles, but part of the emissions decrease was offset by gradual growth in traffic 

volumes. Industry emissions were conservatively increased to reflect operation at maximum 

capacity in 2014, but both industrial sources are minor so this did not have a major effect on 

the 2014 inventory. The most significant category is residential wood-heating; emissions were 

increased to reflect population growth during 2008-2014, decreased due to non-certified 

woodstove replacements with cleaner burning units during 2009-2012, and decreased due to 

improvements in the programs for curtailment during stagnant air episodes.

Attainment Strategies – Emission Reduction Analysis

This section describes strategies currently in place or those to be implemented to achieve 

compliance with the 24 hour PM2.5 standard. These strategies are expected to improve air 

quality and meet the PM2.5 standard by the required 2014 attainment date. These strategies 
November 15, 2012 – Final

28

are also known as Reasonably Available Control Measures (RACM). For large industrial 

emission sources they are called Reasonably Available Control Technologies (RACT) but 

currently there are not any large industrial facilities located in the Oakridge-Westfir area. For 

the Oakridge nonattainment area, the main source of emissions is wood smoke from residential 

wood combustion, and RACM is applicable to this emission category. The current and proposed 

emission control strategies are consistent with the RACM requirements for residential wood 

combustion (EPA-450/2-89-015).

The RACT / RACM analysis took into account direct PM2.5 and the precursors NOx and SO2 as 

required by the 2007 implementation rule. Preliminary analysis of the airshed found very little 

contribution of local sources to secondary sulfate and nitrate relative to direct PM2.5. Since the 

total local emissions of NOx and SO2 are not a major factor in ambient PM2.5 at the violating 

monitor, it was a reasonable hypothesis that small changes in that total NOx and SO2 emission 

budget would be a very minor factor in PM2.5 in Oakridge relative to primary PM2.5 emissions. 

Thus the attainment model was simplified to not take attainment credit for emission changes in 

PM2.5 nitrate and sulfate precursors. LRAPA is confident that direct PM2.5 is the cause of (and 

solution to) PM2.5 nonattainment and that there is little opportunity for reducing PM2.5 

through emission reductions of NOx and SO2.

Particulate Matter Reduction Strategies (1989 -2008)

The strategies and regulations implemented between 1989 and 2008 resulted in a reduction of

PM2.5 emissions. Projections show implementing and strengthening ongoing strategies will 

make it possible for the Oakridge area to achieve the standard by 2014. Future strategies are a 

continuum of past strategies developed over the years that have been adjusted and updated to 

address the current PM2.5 standard. Local efforts include revisions to the existing Oakridge 

clean air ordinance, public education, and woodstove change-outs. State and federal 

regulations recently implemented affect woodstoves and transportation emissions.

These strategies are permanent and enforceable; they are currently implemented and enacted 

by city ordinance, state, or federal rules. There are penalties for violating these ordinances or 

rules. 

The Oakridge Air Pollution Control Ordinance #889

LRAPA and the City of Oakridge initiated a voluntary home wood heating advisory program in 

1989 after air quality data showed Oakridge exceeded the federal PM10 standard on numerous 

occasions. Five years later, on January 20, 1994, EPA officially declared Oakridge a PM10 nonattainment area. In August of 1996, the City of Oakridge adopted a wood heating curtailment 

program. A plan to get the area back into attainment with the standards was adopted by EPA in 

March 1999, and became effective on May 14th of that year. The Oakridge plan included 

voluntary measures.

On February 20, 2003, the Oakridge City Council revised the home wood heating ordinance 

that:

• Changed their voluntary curtailment measures to mandatory,
November 15, 2012 – Final

29

• Prohibited burning garbage in woodstoves and fireplaces,

• Incorporated a 40% opacity limit on chimneys,

• Incorporated the PM2.5 standard into the program, and

• Required the removal of uncertified woodstoves from property to be sold or rented.

In fall 2007, the City of Oakridge revised its home wood heating ordinance to reflect the 

tightened PM 2.5 standard of 35 μg/m3. The revision changed the concentration levels that 

trigger the green/yellow/red advisories. A revision to the ordinance in December 2008 

included a provision that stated a person or persons may not install or use any solid fuel heating 

device in any structure within the City except for certified wood stoves or certified pellet stoves 

with emissions that do not exceed 1.0 grams/hour weighted average tested in conformance 

with the EPA method, or a fireplace that is not a sole source of heat. 

LRAPA Advisory Programs

Since initiated in 1989, the LRAPA advisory program has provided a daily wood burning advisory 

for Oakridge. The program is operated by LRAPA in cooperation with the City of Oakridge and 

local news media. The advisory, issued daily by LRAPA staff during the months of November 

through February, is determined by comparing current pollution levels to meteorological

conditions and weather forecasts. The advisories are displayed daily on the LRAPA website and 

can be obtained via telephone at a dedicated hotline number. Advisories are broadcast on 

radio and television and daily in the regional newspaper. An automatic phone “callware” 

system is activated when air quality is deteriorating and long periods of stagnant conditions are 

forecast. The phone system calls all numbers with the 782 prefix in the Oakridge/Westfir area 

and leaves a recorded message.

(a) The advisory operates using a "green-yellow-red" system as described in the 

Oakridge City ordinance. A "green" advisory is issued when PM2.5 levels are 

forecast by LRAPA to be less than 25 g/m3, and good smoke dispersion 

conditions are forecast. "Yellow" advisories are posted when PM2.5 levels are 

forecast by LRAPA to be equal to or greater than 25 g/m3, but less than 30 

g/m3, and the forecast is for marginal smoke dispersion conditions. Under this 

advisory, residents are advised to burn wood sparingly, and only if alternatives 

are unavailable. A "Red" advisory is posted when PM2.5 levels are forecast to be 

equal to or greater than 30 g/m3, and the forecast is for marginal or poor 

smoke dispersion conditions. During a Red advisory, no person in charge of a 

property shall operate or allow to be operated a solid fuel heating device which 

emits visible emissions unless the person has been granted an exemption by the 

Oakridge City Administrator. Residents with exemptions may use any solid fuel 

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

During Stage II Red II advisory, when PM2.5 levels are forecast to be equal to or 

greater than 35 micrograms per cubic meter no person in charge of property 

shall operate or allow to be operated a solid fuel burning device unless: the 

person has been granted an exemption to use the device by the City 
November 15, 2012 – Final

30

Administrator; or the person is operating a pellet stove which emits no visible 

emissions into the air outside of the building housing the device.

Open Burning Ordinance

On March 19, 1992, the Oakridge City Council amended its open burning ordinance #689 to 

allow open backyard burning only during the months of October, March, April, and May and

bans the use of burn barrels. Oakridge City Code 92.04.A.2 currently regulates open backyard 

burning inside the Oakridge city limits. This eliminates burning during wintertime periods of 

maximum atmospheric stagnation when burning is more likely to contribute to exceedances of 

the 24-hour PM2.5 standard. The open burning restrictions provide a more protective measure 

to avoid additional contributions to the particulate levels.

Woodstove Change-out Programs

Since 1993, LRAPA has administered woodstove change-out programs to help residents replace 

old, uncertified wood stoves with cleaner burning, more efficient heating systems. This control 

measure is central to achieving attainment, and will enhance both long- and short-term 

compliance. The first program conducted in 1993 provided economic incentives for residents 

to replace old, high polluting woodstoves with alternative heating systems with lower emission 

rates. These include electric furnaces and heat pumps, oil, gas, pellet stoves, or EPA certified 

low-emission woodstoves. 

The initial program was funded by the U.S. EPA, together with support from the Oregon 

Department of Environmental Quality and LRAPA. The program provided up to $2,500.00 per 

low- or moderate- income household for installation of approved alternative heat sources, 

either as no-interest loans or outright grants. Participants were required to certify, in writing, 

that they disposed of their old stoves, and would not utilize non-approved alternatives in the 

future. A total of 130 stoves were replaced.

In 2005, LRAPA developed the Warm Homes, Clean Air Program for Oakridge. The program is 

ongoing as funding becomes available. Warm Homes matches Oakridge and Westfir residents 

with funding from nine partner agencies to help with heating upgrades, weatherization, and 

home repairs. As part of the program, LRAPA has provided funding for woodstove 

replacements. During a change-out conducted between 2006 and 2008, 59 uncertified 

woodstoves were replaced. Table 5 shows a historical view of the Oakridge Wood Stove 

Change-outs.

Oakridge Wood Stove Change-out Programs

Years 1993-96 2006-07

# of Stoves 130 59

Table 5: Oakridge Wood Change-out Programs (1993-96/2006-07)

Statewide Certification of Woodstoves

In 1986, the Oregon Legislature required the certification of any woodstove sold in Oregon. 

This requirement was subsequently adopted by EPA on a national basis in 1990. Additionally, 
November 15, 2012 – Final

31

the State Building Code Agency prohibits the installation of uncertified woodstoves. The dual 

effect of this certification and installation requirement resulted in reducing the amount of 

wood smoke pollution that used to be emitted from the uncertified stoves. 

Highway Road Sanding

In an effort to reduce PM10 emissions from road sanding during winter months, the Oregon 

Department of Transportation (ODOT) signed a letter of agreement regarding using anti-icing 

agents as an alternative to sand on Highway 58 running through Oakridge. The use of the 

chemical de-icing compound, calcium magnesium acetate, inhibits ice formation. The practice 

has resulted in a significant reduction of particulate, however it is not likely to contribute to 

PM2.5 reductions.

Smoke Management

By statute, the Oregon Department of Forestry (ODF) is responsible for administering a smoke 

management program. Smoke from prescribed burning has not significantly impacted the 

nonattainment area in the past, however, there have been safeguards implemented to prevent 

unintended smoke impacts to the Oakridge nonattainment area. Oakridge is protected under 

the Oregon Smoke Management Plan as a smoke sensitive area. This means that all prescribed 

burning during the year is managed in such a way as to avoid any smoke intrusions into the 

community. 

In addition, a Special Protective Zone (SPZ) surrounds Oakridge where additional restrictions 

apply to prescribed burning within the zone during the winter months (November 15 through 

February 15). During this time, prescribed burning is allowed only when the ODF smoke 

management meteorologist determines there would be no measurable smoke within the 

nonattainment area. Between December 1 and February 15, no prescribed burning is allowed 

in the SPZ on “red” woodstove days. Between November 15 and February 15, no pile burning is

allowed if ODF believes that the piles will produce significant smoke after the third day.

Road Paving

According to the emissions inventory done prior to 1991, there were about 2.4 miles of 

unpaved streets in Oakridge. Since then, based on city records, virtually all unpaved roads have 

been paved, along with numerous unpaved commercial driveways and parking lots. 

Industrial Requirements

Within the designated Oakridge PM2.5 nonattainment area, new major sources and major 

modifications of a nonattainment pollutant, including PM2.5 precursors SO2 or NOX, are required 

to meet LAER control technology. Industrial sources must also obtain emission offsets and 

demonstrate that a net air quality benefit will be achieved. These are the most stringent 

requirements for industry. In addition, existing sources will be evaluated for RACT and will be 

required to meet performance standards for certain industry. 

Public Education

LRAPA has maintained a strong presence on the Oakridge community through public education 

programs aimed to inform residents and teach school age children about air quality issues. In 

2006, LRAPA developed a school flag project for Oakridge Elementary School. LRAPA provides 
November 15, 2012 – Final

32

air quality flags that are hung at the entrance to the school, which is located on a main street 

near downtown Oakridge. The highly visible flags display the current Air Quality Index (AQI) 

reading for that day. Information on air quality is obtained by students from the LRAPA website. 

The flags have also been used during periods of bad air quality caused by wildfires. A specialized 

curriculum was developed by LRAPA public affairs staff for third –fifth grade students. An 

LRAPA staff person makes an annual visit to the school in the fall to teach a class on air quality 

and explain how to use the flags. 

For over ten years, LRAPA has taught an air quality class at outdoor school, held each May in 

Oakridge. The class focuses on the science of air pollution and the specific challenges of wood 

smoke pollution in Oakridge. An average of 75 sixth grade students attends the class each year.

Additional Strategies

Beginning in the early 90’s, LRAPA developed various strategies to reduce and track wood 

smoke emissions. LRAPA provided plastic tarps to residents for covering wood piles to keep 

wood dry. A seasonal worker, hired by LRAPA, conducts drive-by compliance surveys on green, 

yellow, and red days using pre-established survey routes. Surveys are turned in monthly 

November- February.

Current Strategies 2009-2011

Wood Stove Change-out program

The Warm Homes wood stove change-out program continued in 2009. Funding from U.S. EPA 

helped replace 11 uncertified wood stoves with new heating devices. In October 2010, LRAPA 

received funds from the American Recovery and Reinvestment Act. LRAPA used the funding to 

conduct another round of wood stove change-outs in Oakridge and Westfir. The program 

offered two-tier funding for qualified residents within the non-attainment boundary designated 

by U.S. EPA. Residents who qualified as low income based on Housing and Urban 

Development’s (HUD) income guidelines received a full rebate of up to $5,000 to pay for a 

ductless heat pump, certified wood stove or pellet stove. All other qualified applicants received 

a rebate of up to $2,000 based on emission reductions. The program ended in December 2011. 

LRAPA provided rebates to replace 79 stoves. Wood heat was most popular; 56 new wood 

stoves were installed, 10 pellet stoves, and 13 electric ductless systems. 

Oakridge Wood Stove Change-out Programs

Years 2009 2010-11

# of Stoves 11 79

Table 6: Oakridge Wood Change-out Programs (2009/2010-11)

Heat Smart: Stove Removal upon Sale of Home

In 2010, a statewide requirement mandating the removal of an uncertified stove at the time of 

home sale went into effect. This statewide rule closely mirrored the existing requirement in the 

Oakridge ordinance. Under the rule, all uncertified devices that are on the property being sold 

(including residences, shops, garages, and outbuildings) must be removed at the time of home 
November 15, 2012 – Final

33

sale. The Oregon Heat Smart law requires DEQ to confirm residences where owners removed 

or changed-out uncertified woodstoves upon home sale. DEQ currently administers the Heat 

Smart program and tracks submittals of all uncertified removals at the time of home sale. 

These submittals can be used to estimate the level of compliance in Oakridge and identify any 

need for additional education or follow-up. DEQ has established in rules, penalties for 

noncompliance and hopes to conduct periodic enforcement sweeps throughout the state.

Public Education

As mentioned earlier in this section, LRAPA has maintained a vigorous public education 

program in Oakridge. In 2009 -2011, the program was expanded to reach a wider audience. In 

2010, LRAPA produced a television commercial to promote compliance with home wood 

heating advisories and clean burning practices. The commercial has run every fall on three 

major television networks; all are available to Oakridge viewers. Radio ads targeting open 

burning and home wood heating have aired on a network of radio stations in Lane County since 

2009. Almost stations all are available in Oakridge.

Articles in the weekly newspaper, the Dead Mountain Echo, serving the Oakridge area have

been submitted by LRAPA staff periodically to keep the public informed about poor air quality, 

LRAPA programs, and other topics related to wood smoke. Display advertisements and fliers 

inserted into the paper are also used to promote high profile projects, the Warm Homes 

program being an example.

Transportation and Fuel-Related Emissions

Federal, state and local transportation regulations and programs recently implemented will 

reduce mobile and non-road emissions. These include: 

Federal regulations requiring: 

 Reduced sulfur content of gasoline and diesel

 Increased fuel economy

Oregon regulations requiring: 

 Low emissions vehicles beginning with model year 2009 and newer

 Renewable fuel standard for biodiesel – 5%

Local programs:

 Implementing diesel retrofits of school buses

The Transportation Conformity Analysis is included in Appendix K. The Motor Vehicle 

Emissions Budgets are:

 On-Road Worst Case Day PM2.5 Emissions of 38.5 pounds per day (22.2 pounds per day of 

exhaust, brake and tire wear, and 16.3 pounds per day of re-entrained road dust); and

 On-Road Worst Case Day NOx Emissions of 562.3 pounds per day.
November 15, 2012 – Final

34

Strengthened Ongoing Strategies in 2012-2014

While the current strategies in place indicate Oakridge will reach attainment with the PM2.5

standard by 2014, to ensure compliance, a number of future strategies were identified by a 

local advisory committee. The advisory committee evaluated options for how to improve air 

quality in Oakridge and suggested potential control measures. With the help of the committee, 

LRAPA developed a list of strategies to ensure Oakridge meets the 2014 attainment date. 

Oakridge Air Quality Advisory Committee Strategy Recommendations

In July 2011, LRAPA formed an advisory committee in Oakridge to discuss current air quality 

strategies and explore the feasibility of a number of new strategies identified that would reduce 

PM2.5 emissions. They also discussed contingency strategies should Oakridge fail to meet the 

standard by 2014. While the strategies in place (e.g., City ordinance, LRAPA’s advisory 

programs, federal and state regulations) indicated the area would meet the standard by 2014, 

the committee suggested strengthening the strategies to provide a cushion to ensure 

attainment by 2014. The following strategies are included as part of this plan.

Woodstove Change-outs

Due to the effectiveness of this strategy in the past, LRAPA will continue to pursue funds to 

continue offering woodstove change outs within the nonattainment area. Implementation of 

this strategy may provide substantial reductions in PM2.5 in the future. LRAPA is not applying 

any emission credit for this strategy to the 2014 inventory, as it is dependent upon the 

acquisition of funding which affects the number of stoves replaced. In the most recent round 

of wood stove change-outs, 75% of the participants qualified as low-income. The poor 

economy in Oakridge makes it essential any future change-out incentives include grants to 

cover all of the cost of replacement for low income individuals and substantial (at least 50%) 

incentives to residents who are not “low income”. 

Enforcement of Oakridge Ordinance

Oakridge Ordinance #889 allows the City to impose a penalty not greater than $500.00 upon 

anyone who violates City Code related to the use of a solid fuel heating device. Each day’s 

violation will incur additional fines. At this time, the City of Oakridge has enforcement 

authority of the ordinance. LRAPA is working with the Oakridge Police Department to 

strengthen enforcement on Red advisory days. LRAPA has provided a series of door hangers

that can be left at a residence with an excessively smoky chimney. The door hangers include 

language from the City Ordinance, including potential fines for a violation.

Enhancements to Key Ongoing Strategies

The Oakridge Advisory Committee identified several strategy enhancements that were felt to 

be key to the success of the ongoing strategies. Most of these strategies can be implemented 

without additional resources.

• Expanded education and outreach, including multiple versions of educational doorhangers that can be distributed to all homes in Oakridge.

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

enforcement.
November 15, 2012 – Final

35

• Enforcement with citations as appropriate for violations of curtailment during 

pollution episodes, excessive opacity (40%) requirements, operation of non-certified 

woodstoves, and burning of garbage.

• Ongoing improvements in the air quality forecasting and green-yellow-red advisory 

programs to ensure that all problem stagnation days are addressed appropriately, 

which may increase the number of yellow or red days.

• Alternatives to fines payment as appropriate (e.g., attend workshop on clean 

burning practices, replacement of non-certified woodstove with cleaner burning 

unit, etc.).

• Use of fines to fund ongoing woodstove replacement program or other emission 

reduction strategies.

Contingency Strategies

The following strategies are recommended as contingency strategies to fully meet the air 

quality standards, if it becomes clear that the strengthened ongoing strategies described above 

will not be sufficient to attain the PM2.5 standards by 2014 and or to maintain compliance with 

the standards through 2024 and beyond:

• Stricter opacity limit on all green or yellow advisory days, revising the current 40% 

opacity limit in the city ordinance to a more restrictive 20% limit, as has been done 

in some other northwest communities. A 20% opacity limit on green and yellow 

advisory days will help reduce emissions with the goal of avoiding red advisories 

when no visible emissions are allowed.

• Stricter green-yellow-red advisory program, with more yellow and red advisory days 

each winter.

• Further restrictions on city woodstove curtailment exemptions (for sole source, 

economic hardship).

Industrial Emission Reductions

Reasonably Available Control Technology. The two existing industrial sources in the OakridgeWestfir area are minor industrial sources of PM2.5 emissions. The facilities are a portable rock 

crusher and a ready-mix concrete plant owned and operated by Oakridge Sand & Gravel.

These two minor sources together emit less than one ton per year of PM2.5 emissions and 

contribute less than 1% to the base year emission inventory. These two minor sources are well 

below the LRAPA significant emission rate (SER) for PM2.5 of 10 tons per year.

The air pollution control technology installed on these sources are the standard for the industry 

and meet RACT requirements. The rock crusher has water-spray controls and the concrete plant 

has baghouse controls.

Even the elimination of the emissions from these two sources would not significantly affect 

progress to meet the PM2.5 standard. For example, the worst-day PM2.5 concentrations need to 

be reduced by about one microgram per cubic meter (μg/m3) per year in order to meet the 

PM2.5 standard by 2014 (i.e., reduced from 39.5 μg/m3in the 2006-2010 baseline period to 35 
November 15, 2012 – Final

36

μg/m3by the 2014 attainment date). The modeled impact of these two sources if operated at 

maximum permitted production rates in 2014 is much less than one μg/m3, or much less than 

the annual progress required by 2014. Further, both of these sources consistently operate well 

below maximum production rates, especially during the winter months when PM2.5

concentrations are a problem.

Estimated Reductions and Credits for Future Strategies

The emission changes between 2008 and 2014 are due to the combination of increases due to 

growth factors and decreases due to emission control strategies. 

The most significant category is residential wood-heating; emissions were increased in the 2014 

inventory to reflect population growth during 2008-2014, decreased due to non-certified 

woodstove replacements with cleaner burning units during 2010-2012, and decreased due to 

2012-2013 improvements in the programs for curtailment during stagnant air episodes. The 

emission decrease due to woodstove replacements was based on the actual number of 

woodstove replacements documented after the 2008 baseline year. The emission decrease for 

the more effective woodstove curtailment program is conservatively estimated at a 30% 

emission reduction on worst winter days as a result of enforcement of the existing city 

ordinances during stagnant air episodes subsequent to the 2006-2010 baseline period; 

mandatory curtailment programs in Oregon have historically documented reductions of 50% or 

more.

Traffic volumes are projected to gradually increase in future years but motor vehicle emissions 

are calculated to decrease overall due to progressively cleaner gasoline and diesel fuels and 

motor vehicles. Industry emissions were conservatively increased in the inventory to reflect 

operation at maximum capacity in 2014, but both industrial sources are minor so this did not 

have a major effect on the 2014 emission inventory.

Attainment Demonstration

The attainment demonstration shows how Oakridge will meet the PM2.5 standard by 2014 

through the implementation of control measures listed above. LRAPA used a “proportional 

rollback/rollforward analysis” or rollback model to conduct the analysis. The goal of this 

section is to demonstrate that future concentrations are less than the NAAQS at the Willamette 

Activity Center monitor and other unmonitored parts of the designated nonattainment area. 

Baseline Design Value

The demonstration starts with estimating the baseline design value, or baseline concentration, 

for PM2.5. The baseline design value is a statistic, expressed as a concentration that describes 

the PM2.5 levels at the Willamette Activity Center monitor relative to the NAAQS. The 

procedure for its calculation is presented in Appendix N to 40 CFR 50, “Interpretation of the 

National Ambient Air Quality Standards for Particulate Matter” and “EPA Guidance on the Use 

of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for O3, PM2.5, 

and Regional Haze”. PM2.5 measurements from 2006 to 2010 are used to calculate the design 
November 15, 2012 – Final

37

value of 39.5 μg/m3 (see Table 7). Detailed methods on the baseline design value calculation 

are in Appendix G.

Year PM2.5 (μg/m3)

2006 38.6

2007 42.7

2008 38.7

2009 41.3

2010 33.0

Baseline DV 39.5

Table 7: Annual PM2.5 values used to calculate baseline design value.

Background on Precursors

Speciated PM2.5 samples were collected at Willamette Activity Center for the period July 2009-

2011. The samples showed the dominance of organic and elemental carbon, with secondary 

inorganic aerosol nitrate and sulfate comprising relatively minor concentrations of total PM2.5.

Concern had been expressed about the role of secondary organic aerosols (SOAs) as 

components of total organic carbon, and an additional analysis was conducted by a research 

scientist at Portland State University (PSU) in collaboration with ODEQ to better understand the 

magnitude of these aerosols in the Klamath Falls, Oregon air shed. The results of this analysis 

showed that the contributions from both biogenic and anthropogenic sources to be minor, less 

than 1% and 3%, respectively, of total design value PM2.5. In consultation with EPA, LRAPA 

chose to adopt these percent contributions as a conservative assumption for the Oakridge NAA 

demonstration. Because all secondary aerosols were determined to be minor contributors to 

total PM2.5, these components and their concentrations are held constant in the rollback model 

and assigned a Relative Response Factor (RRF) of 1.0, assuming future year precursor 

concentrations are constant or declining. The precursor emissions to secondary aerosols, 

including NOX, SO2, ammonia, and biogenic and anthropogenic VOCs, are not used in the 

attainment demonstration (LRAPA is utilizing a rollback analysis for the attainment 

demonstration).

In addition to the study of secondary aerosols, a positive matrix factorization (PMF) study based 

on the speciated data from Willamette Activity Center was conducted by EPA Region 10 to 

identify likely sources of speciated PM2.5. The study showed the importance of residential 

woodsmoke to the high levels of organic carbon, an estimated 70-75% of total PM 

concentrations.

The SANDWICH speciation formulation, based on adjusted and corrected Willamette Activity 

Center speciation data, is used to speciate the FRM measured design value (DV) for use in the 

rollback model. The SANDWICH is a profile of the DV with which to describe the components 

that contribute to PM2.5 exceedances. This profile is shown in Figure 10, and shows that over 

95% of total PM is from organic and elemental carbon with smaller amounts of secondary 

inorganic aerosols, such as sulfate (1%) and nitrate (0.4%). The SANDWICH analysis, and the 
November 15, 2012 – Final

38

PMF study are described in more detail in Appendix E.1 and Appendix E.2. Based on the 

evidence cited above, the major sources contributing to nonattainment in Oakridge are 

considered to be those that emit direct emissions of PM2.5. As a result, LRAPA has focused its 

strategies for the attainment demonstration on these sources. 

Figure 10: Speciated Components of PM2.5 (using SANDWICH analysis)

Speciated Filter Sample Analysis

PM2.5 is a mixture and can be divided into major components: mass associated with sulfates, 

nitrates, ammonium, organic carbon, elemental carbon, particle bound water, and other 

primary inorganic particulate matter. Percent contribution to the total mass by each of these 

major components is used to estimate relative contribution by different emission sources. 

From July 2009 to 2011, LRAPA conducted PM2.5 speciation monitoring at the Willamette

Activity Center location. Total PM2.5 mass measurements using the FRM are used mainly to 

determine attainment or nonattainment of the standard. However, to provide information 

about particular source contribution to that total mass it was necessary to co-locate a 

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

The total mass of PM2.5 using the FRM sampler is not equal to the simple sum of the measured 

components from the speciation filter, therefore it is necessary to make adjustments to 

1%

0.4%

88%

8%

0.03%

3%

Oakridge PM2.5 Composition

Sulfate

Nitrate

Organic Carbon

Elemental Carbon

Ammonium

Other
November 15, 2012 – Final

39

represent FRM mass. In order to apply the results of the speciated filter analysis to the aerosol 

mass measurements, EPA Region 10 conducted the Sulfate, Adjusted Nitrate, Derived Water, 

Inferred Carbonaceous Material Balance Approach (SANDWICH) which is the default method in 

EPA modeling guidance to define baseline PM2.5. The SANDWICH approach uses a combination 

of speciation measurements and modeled estimates to represent FRM PM2.5 measurements. 

The goal is to reconstruct the measured speciated components so that they add up to the 

measured FRM PM2.5 mass. Table 8 shows the results as percent contribution by a speciated 

component (sulfates, nitrates, organic carbon (OC), elemental carbon (EC), ammonia (NH3), and 

other primary particulate (OPP)). Detailed methods of the SANDWICH analysis are included in 

Appendix E.1.

% Sulfate % Nitrate % OC % EC % Water % NH3 % OPP

1.1 0.4 88.4 7.6 1.4 0.03 1.1

Table 8: Contribution by speciated components. Results of SANDWICH analysis for the top 25% high 

concentration winter (Oct-Mar) days.

Minor PM2.5 Components

In addition to the speciated components in Table 8, ODEQ, in partnership with Portland State 

University, examined contribution by secondary organic aerosols in Klamath Falls, Oregon and 

found it to be relatively low. Anthropogenic secondary organic aerosols contribute 3% and 

biogenic 1% to the total measured PM2.5 mass. LRAPA chose to adopt these percent 

contributions as a conservative assumption for the Oakridge NAA demonstration. Secondary 

organic aerosols and the other minor components sulfate, nitrate, and background EC and OC 

are assumed to be constant in rollback modeling. More details about this analysis are included 

in Appendix E.1.

Each source emits a different proportion of OC, EC, and OPP, the three components used to 

develop a speciated emissions inventory. This proportion, or the speciation profiles, for each 

source category are taken primarily from EPA SPECIATE 4.2 and 4.3 databases. The following 

source categories are included in the analysis:

1 Cement Production

2 Sand and gravel mining

3 Fireplace

4 Woodstove Insert Non-Cert

5 Woodstove Insert Cert (Non-Cat)

6 Pellet / Woodstove Cert

7 Ag and open burn

8 Rail

9 Passenger Vehicles - light diesel

10 Trucks - Heavy diesel

11 Passenger Vehicles - gas

12 Vehicle Road Dust
November 15, 2012 – Final

40

Rollback Model

In evaluating the appropriate modeling analysis of PM2.5 for Oakridge, LRAPA considered many 

different modeling approaches, including rollback and more sophisticated methods such as 

dispersion modeling. However, both dispersion and receptor are more resource intensive and 

do not offer substantial improvements in demonstrating attainment under conditions that exist 

in Oakridge. A rollback model can simulate worst case day conditions when stagnant conditions 

and slow emissions movement within the nonattainment area occur. 

Oakridge is particularly well suited for a rollback demonstration because of a) the relatively 

small area of the NAA, b) the bowl shape of the local airshed and the presence of inversions and 

low mixing heights during evening hours when measured particulates are highest, c) the very 

few types of emissions sources in the NAA, with home wood heating devices dominating the 

emissions. Based on these considerations, LRAPA has chosen a rollback model for the area. 

The rollback model is based on the assumption that there is a direct correlation between 

emissions of a pollutant and measured concentrations of that pollutant in the same airshed, 

and that changes in emissions will result in corresponding changes in concentration. This 

correlation is used to predict future concentrations based on future emissions. The change in 

concentrations caused by changes in emissions is represented by the Relative Response Factor 

(RRF). An RRF less than one indicates a reduction in future concentrations, RRF equal to one 

indicates no change, and RRF larger than one indicates an increase. RRFs are calculated for 

each speciated component (EC, OC, and OPP) used in the rollback model. Details of the analysis 

are presented in Appendix H. The results show a cumulative RRF = 0.696, which indicates a 

decrease in future concentrations. After the cumulative RRF is applied to the input data for the 

baseline design value, the results are used to calculate a future design value of 28.2 μg/m3.

Year Baseline DV 

PM2.5 (μg/m3)

Future DV 

PM2.5 (μg/m3)

2006 38.6 27.5

2007 42.7 30.4

2008 38.7 27.6

2009 41.3 29.6

2010 33.0 23.6

Design 

Value 39.5 28.2

Table 9: Baseline and Future projected design values

The future ambient concentration levels are below the NAAQS (35 μg/m3) for a 24-hour 

average and the attainment of the standard is demonstrated with the application of the current 

strategies in place. The current reduction strategies described earlier in this section lower the 

emissions enough to meet the NAAQS at the Willamette Activity Center monitor.
November 15, 2012 – Final

41

Modeled Air Quality Improvements of the Key RWC Strategies

The key long-term permanent residential wood combustion (RWC) strategies have been: 

the woodstove change-out programs replacing uncertified woodstoves with cleaner 

burning and more efficient home heating units; 

the Oregon and EPA woodstove certification programs requiring any new woodstoves 

installed since 1986 to be certified woodstoves; and 

the Oakridge ordinance and Oregon Heat Smart law requiring removal of uncertified 

woodstoves upon home sale.

These programs have been critical to the significant improvement in Oakridge PM2.5

concentrations during 2005-2011 as outlined in Figures 5 and 6. In addition, the combined 

emission reduction of these programs will more than offset the growth in population and 

housing between 2008 and 2014, with a net RWC emission reduction of about 28 lb/day on 

typical season days and 31 lb/day on worst-case days and reduce future PM2.5 concentrations 

by 2.1 μg/m3on 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/m3PM2.5 during 2005-2011). This will reduce RWC emissions by 

131 lb/day and reduce future PM2.5 concentrations by 8.7 μg/m3on worst-case days.

Additional details on the modeled air quality improvements due to these emission reductions 

are included in Appendix H (Rollback Analysis) and Appendix J (Residential Wood Combustion 

RACM).

Unmonitored Area Analysis

The previous section describes the demonstration of attainment at the Willamette Activity 

Center monitor. In addition, a supplemental analysis was conducted to examine future design 

values away from the Willamette Activity Center, both within Oakridge and in the neighboring 

city of Westfir. The unmonitored area analysis is based on a 2002–2003 saturation survey of 

Oakridge, and the 2009-2010 monitoring of Westfir. These monitoring efforts are described in 

greater detail in Appendix A. 

The ratio of average concentration at each of these monitors to the average concentration at 

Willamette Activity Center is applied to the baseline design value at Willamette Activity Center 

to establish a “baseline” design value for each monitor. The same ratio is then applied to the 

Willamette Activity Center future design value to estimate a future design value for each site. 

Since there is currently only one small point source in the emissions inventory for Oakridge, a 

dispersion modeling exercise to estimate source impacts was deemed unnecessary.

In both monitoring efforts referenced here, the Willamette Activity Center was the location of 

the highest observed concentration. Base and future design values for all monitored locations 
November 15, 2012 – Final

42

were below the NAAQS, indicating that the Willamette Activity Center concentration is the 

highest in the area. More detail of the unmonitored area analysis is available in Appendix A.

Application of Future Strategies

Including current strategies, and strengthening of these strategies, the rollback model shows 

that the Oakridge non-attainment area will achieve the standard of 35 μg/m3 by 2014. At 28.2

μg/m3, the future design value includes a buffer for potential variation while still meeting the 

standard. The Oakridge Advisory Committee developed contingency strategies that are part of 

the attainment plan and will automatically take effect, if necessary, in order to make continued 

progress should the area not achieve the standard by 2014. Using these contingency strategies 

would result in additional emission reductions and consequently could also be used to show 

further reduction in the attainment demonstration roll back model. At this time, these 

additional measures do not appear necessary. The results of the rollback at Willamette Activity 

Center show a cumulative RRF of 0.70 with current strategies and future strengthening of these 

strategies recommended by the committee. 

Table 10 shows the estimated emissions, and proportional concentrations, based on all current 

attainment strategies:

Table 10: Allocation of emissions and modeled concentrations for base and future years.

Contingency Plan

The attainment plan must contain contingency measures that would be implemented in the 

event that the Oakridge nonattainment area fails to meet the standard on or after December 

2014. The contingency measures are designed to correct the violation of the PM2.5 standards 

and be implemented immediately. EPA requires that any contingency measures must equal 

one year equivalent of reasonable further progress (RFP). 

Emissions % PM2.5 μg/m3Emissions % PM2.5 μg/m3

Residential Wood Combustion 79.6% 31.4 74.7% 21.1

Industry 0.0% 0.0 1.2% 0.3

On-road vehicles 8.4% 3.3 7.1% 2.0

Other 2.1% 0.8 2.9% 0.8

Background + secondary aerosols 9.9% 3.9 14.1% 4.0

Total 100.0% 39.5 100.0% 28.2

Base Year Future Year

Source Category

Emissions % PM2.5 μg/m3Emissions % PM2.5 μg/m3

Residential Wood Combustion 79.6% 31.4 74.7% 21.1

Industry 0.0% 0.0 1.2% 0.3

On-road vehicles 8.4% 3.3 7.1% 2.0

Other 2.1% 0.8 2.9% 0.8

Background + secondary aerosols 9.9% 3.9 14.1% 4.0

Total 100.0% 39.5 100.0% 28.2

Base Year Future Year

Source Category
November 15, 2012 – Final

43

In Oakridge, the worst-day PM2.5 concentrations need to be reduced by about one microgram 

per cubic meter (μg/m3) per year in order to meet the PM2.5 standard by 2014 (i.e., reduced 

from 39.5 μg/m3in the 2006-2010 baseline period to 35 μg/m3by the 2014 attainment date). 

Therefore the RFP requirement in Oakridge would equal about one μg/m3of further reduction. 

The Oakridge PM2.5 attainment plan includes the following strategies as contingency strategies 

to fully meet the air quality standards, if it becomes clear that the strengthened ongoing 

strategies described above will not be sufficient to attain the PM2.5 standards by 2014 and or to 

maintain compliance with the standards through 2024 and beyond:

• Stricter opacity limit, revising the current 40% opacity limit in the city ordinance to a 

more restrictive 20% limit, as has been done in some other northwest communities.

• Stricter green-yellow-red advisory program, with more yellow and red advisory days 

each winter.

• Further restrictions on city woodstove curtailment exemptions (for sole source, 

economic hardship).

The most quantifiable and most quickly implemented of these contingency measures would be 

further strengthening of the mandatory curtailment program by more consistent enforcement 

of the city curtailment ordinance and stricter criteria for expanding the number of yellow and 

red advisory days. If the standard is not met by 2014, the number of red curtailment days 

would be increased to an average of 30 days per year (based on the number of days above 25 

μg/m3PM2.5 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/m3in 2014. If the mandatory curtailment program is increased 

from an average of 20 days per year (based on 30 μg/m3PM2.5) to 30 days per year (based on 

25 μg/m3PM2.5 in the contingency plan) this will further ensure that the full 8.7 μg/m3is 

achieved. The contingency measures for stronger enforcement on more red advisory days is 

expected to increase the curtailment effectiveness. 

Using these contingency strategies to increase curtailment effectiveness to 40% is 

expected to reduce RWC emissions by 44 lb/day and reduce PM2.5 concentrations by 

an additional 2.9 μg/m3on worst case days. 

Using these contingency strategies to increase curtailment effectiveness to 50% is 

expected to reduce RWC emissions by 87 lb/day and reduce PM2.5 concentrations by 

5.8 μg/m3on worst case days. 
November 15, 2012 – Final

44

Either of these contingency measures would more than achieve the one μg/m3target needed 

to meet the EPA RFP test. 

If Oakridge meets the PM2.5 standard by the EPA Clean Air Act 2014 deadline, the contingency 

plan will not be enacted. If Oakridge does not meet the PM2.5 standard by the EPA Clean Air Act 

2014 deadline, the contingency plan will be enacted by the beginning of the immediate next 

wood-heating season, November 15, 2015. 

If the high PM2.5 concentration was determined to be an Exceptional Event based on EPA's 

Exceptional Events Rule, as flagged by ODEQ and concurred by EPA, no further action may be 

needed.
November 15, 2012 – Final

45

Acknowledgements

Oakridge Advisory Committee

LRAPA would like to thank the members of the Oakridge Advisory Committee for their efforts in 

developing the list of strategies aimed at reducing PM 2.5 emissions in the community.

Committee Members:

James Affa Private Citizen

James Coey Private Citizen

Rob DeHarpport Private Citizen

Herb Hilton Private Citizen

Glenn Fortune Oakridge City Council

Don Hampton Former Oakridge Mayor

Gordon Zimmerman Former Oakridge City Manager

John Murray Lane Electric Coop

Paul Engelking University of Oregon Chemistry Professor, LRAPA Citizens Advisory 

Committee

Brian Forge LRAPA Board Member

LRAPA Staff Support to Committee:

Merlyn Hough Director

Tim Sawyer Data Management Coordinator

Ralph Johnston Senior Scientist

Sally Markos Public Affairs Coordinator

Principal Authors

Merlyn Hough LRAPA Director

Tim Sawyer LRAPA Data Management Coordinator

Sally Markos LRAPA Public Affairs Coordinator

Robbye Lanier LRAPA Environmental Technician

Contributors

Lane Council of Governments

Oregon Department of Transportation

Oregon Department of Environmental Quality

U.S. Environmental Protection Agency
Attachment 2 

LRAPA 2014 Ambient Air Monitoring Network Plan 
Monitoring and Data Analysis Section 

2014 Ambient Air Monitoring Network Plan 

July 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, the Oregon Department of Environmental Quality (ODEQ) is required to 

annually submit to EPA by July 1, a Statewide Air Monitoring Network Plan. 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 plans are used to 

determine if the air monitoring network meets EPA, state and local monitoring 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 submission. 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 Comments 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 Oregon 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 determine

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 also 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 (PQAO), 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 history of 

cooperative involvement, and routinely cooperate on projects, 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 correctly 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 (QAPPs/SOPs).

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

pollutants”-six commonly occurring air pollutants. These standards, 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 (PM10, and PM2.5)

 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 of 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 these 

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 two of the criteria pollutants:

 Particulate Matter (PM10, and PM2.5)

 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 

based 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 areas of high population density

 Public information and Air Quality Index (AQI) reporting

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

 General background concentration levels

 The extent of regional pollutant transport among populated areas and impacts in more 

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 concentration 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 operates equipment designated as SPMs (Special Purpose Monitors). These monitors 

may be deployed for short or ongoing terms, and operate for various reasons:

 Supporting emission reduction strategies such as woodstove curtailment and open 

burning advisories

 Providing real-time particulate 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 locations

 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. Meteorological 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 decisions, 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 independent 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 responsible 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 data 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 

implement 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 example, 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, which translates to over $90,000 per year 

to operate a single site on an every sixth day schedule. By comparison collecting a year of 

PM2.5 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 LRAPA was able 

to re-program some unused EPA grant funds to continue the sampling on a limited basis ( 1 

sample every 12th 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 yearlong 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 sampling 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 levels 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 of 2010. 

Ozone, O3 (EPA parameter #44201)

LRAPA’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 other is positioned for determination of the concentration in an 

area of high population density.

Particulate Matter, PM10 (EPA parameter #81102)

LRAPA monitors PM10 at two locations as required by State Implementation and Maintenance

Plans for Eugene and Oakridge.

Particulate Matter, PM2.5 (EPA parameter #88101)

LRAPA measures PM2.5 with Federal Reference Method (FRM) samplers at 5 locations. 

Operation of two sites are funded directly by EPA through a statewide PM2.5 monitoring 

allocation. These sites are 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. Two Special Purpose Monitors (SPMs) are operated for 

informational purposes. One in northwest Eugene is at a PM10 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, PM2.5 Speciation

In an effort to better understand PM2.5 emission sources, LRAPA has operated a PM2.5

Speciation sampler in Lane County since 2001. This activity has been funded directly by EPA, 

and was moved from Amazon Park to Oakridge (Willamette Activity Center) in the summer of 

2009 to provide valuable information for control strategy development in the Oakridge nonattainment area. At the end of 2012 LRAPA moved the speciation monitors to the PM10 SLAM 

site, HWY99, in west Eugene. 

Particulate Matter, Real Time PM2.5 (EPA Parameter 11203)

At five particulate monitoring sites LRAPA operates optical opacity (visibility) measuring devices 

known as nephelometers to provide real time estimates of PM2.5. Correlation with Federal 

Reference Method (FRM) particulate samplers is established for each site, and equations are 

used to convert nephelometer outputs into PM2.5 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 information is also used to support other program activities such as 

woodstove and open burning curtailment, and field burning and wildfire impact assessments. 

LRAPA has operated two Federal Equivalent Method (FEM) Beta Attenuation PM2.5 Particulate 

monitors (BAM) 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 BAM 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 EPA guidelines for an FEM 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, LRAPA operated an air toxics (HAPs) site at Eugene Amazon Park 

from 2002 – April 2011. Measuring HAPs 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 

covered under a series of EPA Grants, awards and ODEQ analytical support. Over 150

compounds are analyzed for on each sample day, although not all are HAPS. 

Supplemental funding from EPA Region 10 allowed us to operate two air toxics monitoring sites 

in 2010. Beginning in April 2010 and running through April 2011 a site in northwest Eugene

(Petersen Park) ran on the same schedule as our long-term site in Amazon Park. The data 

collected gave us insight into the spatial variation of air toxics in the metropolitan area. Even 

though the agency lists HAPs as a program priority, HAPs monitoring is not mandated, and 

thus, continued operation of these sites is based on available funding. As of 2013 there is no 

funding available to for HAPs 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 trace 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 HAPs sampling funding has expired to provide 

a more cost effective way to monitor for HAPs.
[6]

Major Network Modifications

No major changes made in 2014.

Proposed changes and continuations for 2015:

1) Continue the operation of three Federal Equivalent Method (FEM) Beta Attenuation 

PM2.5 Particulate 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 maps 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 29th 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

0.057 ppm

PM2.5 SLAMS Max Population Exposure Neighborhood Filter based FRM 1 in 1

24-hour

28 μg/m3

Annual

7.8 μg/m3

PM2.5 collocated SLAMS Network Quality Assurance Neighborhood Filter based FRM 1 in 12 -

PM2.5 FEM SPM Max Population Exposure 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 Pyranometer Continuous -

Rainfall SPM Program Support Urban Tipping bucket Continuous -

Site Description: This site is located in North Eugene. The monitoring location meets all siting 

requirements and criteria for the described monitoring objective and spatial scale of representativeness.

Planned Changes: None.
[10]

Site Name : Willamette Activity Center

Site Code : WAC AQS ID : 410392013 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

PM2.5 SLAMS Max Population Exposure Neighborhood Filter based FRM 1 in 3

24-hour

40 μg/m3

Annual

9.8 μg/m3

PM10 SLAMS Max Population Exposure Neighborhood Filter based FRM 1 in 6 56 μg/m3

PM2.5 FEM SPM Max Population Exposure 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 monitors at this site are the 

primary samplers for the both the PM10 and PM2.5 Oakridge non-attainment areas.

Planned Changes: None
[11]

Site Name : Cottage Grove City Shops

Site Code : CGCS AQS ID : 410399004 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 14th St. Year Established : 2008 Elevation : 650 ft

Parameters: Site Type Monitoring Objective Spatial Scale Sampling Method

Operating 

Schedule

Design Value

PM2.5 SLAMS Max Population Exposure 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 : 410391009 UTM Zone : 10

City : Springfield State LASAR ID : 18538 UTM Easting : 498577

County : Lane Statistical Area : MSA 2400 UTM Northing : 4877060

Address : 225 5th St. Year Established : 1984 Elevation : 466 ft

Parameters: Site Type Monitoring Objective Spatial Scale Sampling Method

Operating 

Schedule

Design Value

PM2.5 SLAMS Population Exposure 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 Valley School

Site Code : SAG AQS ID : 410391007 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

0.059 ppm

Site Description: The Delight Valley School site is located in Saginaw, just 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

PM2.5 SPM Population Exposure Neighborhood Filter based FRM 1 in 3

24-hour

28 μg/m3 

Annual

8.3 μg/m3

Nephelometer SPM AQI / Program Support Neighborhood Optical Backscatter Continuous -

PM10 SPM Maximum Concentration Neighborhood Filter based FRM 1 in 6 59 μg/m3

PM2.5 FEM SPM Max Population Exposure Neighborhood Beta Attenuation Continuous -

PM2.5 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 2012. 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
Attachment 3 

LRAPA Dashboard Report, October 2015 
1 

National Ambient Air Quality Health Standards

Clean Air Act Goal Current

Status Trend ExpectedFinish 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 PM10 air quality health

standard

Ongoing

Continuing improvement of PM10

concentrations; Eugene/Springfield

now a maintenance area. See pages 

7 and 10. 

Maintain compliance with

the annual PM2.5 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 PM2.5 air quality

health standard in

Eugene/Springfield

Ongoing

Levels improving long-term in Eugene,

Springfield, and Cottage Grove, but 

2013-2014 worsening in Eugene is of 

concern. See pages 8 and 10. 

Maintain compliance with

the annual PM2.5 air quality

health standard in Oakridge

Ongoing

Levels improving. Oakridge meets the

annual federal standard. See pages 

8 and 10. 

Attain compliance with the

24-hour PM2.5 air quality

health standard in Oakridge

Ongoing

Despite long-term improvements,

Oakridge continues to violate federal

standard. See pages 8 and 10. 

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 2015
2 

Particulate Matter

Priority Current

Status Trend ExpectedFinish Comments

Improve PM2.5 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 10.

Complete work on new

PM2.5 controlstrategy and

attainment plan for

Oakridge, Including

reconsideration of nonattainment 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.

Currently working with Oakridge on

new moderate level SIP plan to attain 

by December 2015.

Maintain compliance with

PM2.5 standard in Eugene

Springfield and Cottage

Grove

Ongoing

Annual and worst day PM2.5 levels

improved long-term and meet

standards. Occasional high, “Red” 

days during cold, stagnant weather

in Eugene in 2013-2014 of concern. 

Extended HWH season 

implemented Oct 1 – May 31. 

StrengthenOakridge

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 PM2.5

standards

November 2007 

November 2013 

The 2006 PM2.5 standard changed the

100 level of the AQI. The 2013 PM2.5

standard changed the AQI 50 level.

CompletePM2.5/GHG

implementation in

industrialpermitting

Ongoing Incorporated upon permit renewals.
3

Air Toxics and Ozone

Priority Current

Status Trend ExpectedFinish Comments

IncorporateMaximum

Achievable Control

Technology (MACT)

requirementsinto 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 structuresfor area

source National Emission

Standardsfor Hazardous air

Pollutants(NESHAPs)

Ongoing as EPA

finalizes new

NESHAP

standards

Boiler NESHAP implementation

currently ongoing

Compare modeled air toxics

concentrationsin the

National Air Toxics

Assessment(NATA) with

local air toxics monitoring

data

NATA resultsto

be updated by

EPA for 2011, 

2014, and 2017 

NATA 2011 resultsfrom EPA

compared to LRAPA 2010-2011 

monitoring results on page 12. LRAPA

conducting air toxics monitoring for

2015 at two locations.

Review revised national

ambient air quality

standardsfor ozone; assess

the status of airsheds in Lane

County, identify nextsteps 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 ExpectedFinish Comments

Maintain self-supporting

operation, at break-even or

better production levels

Maintain 12-

month average

of 20 units sold

per month.

See page 11. 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 2015 

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.
OZONE DATA

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 0.070 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 2015

Ozone 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 2015

Ozone Concentration (ppm)

Ozone: Maximum Daily 8-hour Average Levels

Saginaw Amazon Park

8-HOUR AVERAGE OZONE LEVELS 2006 – 2015

(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 4th 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 4th 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
CARBON MONOXIDE DATA

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 2014

CO 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 2014

CO Concentration (ppm)

CO: Maximum Daily 8-hour Average Levels

LCC Sacred Heart Hospital

CARBON MONOXIDE (CO) LEVELS 2005 - 2014 (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
PARTICULATE MATTER DATA – PM10

EPA has designated the following National Ambient Air Quality Standards (NAAQS) for PM10: 

Level Averaging Time Description

150 μg/m3 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 2014

PM10 Concentration (μg/m3)

PM10 : Annual Highest Daily 24-hour Concentrations

LCC C.G. Hwy 99 Oakridge

24-HOUR AVERAGE PM10 LEVELS 2005 - 2014 (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
PARTICULATE MATTER DATA – PM2.5

EPA has designated the following National Ambient Air Quality Standards (NAAQS) for PM2.5: 

Level Averaging Time Description

12.0 μg/m3

Annual (Arithmetic 

Average)

To attain this standard, the 3-year average of the annual mean PM2.5 concentrations 

from monitors must not exceed 12.0 μg/m3(effective December 14, 2012).

35 μg/m3 24-hour To attain this standard, the 3-year average of the 98th percentile of 24-hour 

concentrations must not exceed 35 μg/m3(effective December 17, 2006).

0

10

20

30

40

50

60

70

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

PM2.5 Concentration (μg/m3)

PM2.5 : 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 AVERAGE PM2.5 LEVELS 2005 - 2014 (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 98th %-ile 35.6 31.8 36.3 28.7 35.9 16.5 21.2 25.4 38.6 30.7

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

3 year 98th %-ile --- --- --- --- --- 23 23 19 21 21

Saginaw

Annual mean 6.8 5.5 --- --- --- --- --- --- --- ---

Highest 24-hour 24.7 16.6 --- --- --- --- --- --- --- ---

Annual 98th %-ile 17.9 16.6 --- --- --- --- --- --- --- ---

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

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

3 year 98th %-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 98th %-ile 58.4 38.6 42.7 38.7 41.3 33.0 42.0 38.4 41.0 41.1

3 year 98th %-ile 53 48 47 40 41 38 39 38 40 40

8
9
10
0

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-16

Units per Month

AirMetrics Sampler Sales Trends

3-month

6-month

12-month

11
2011 NATA Modeled Concentration Comparison to Measured Concentrations

Modeled concentrations for the 2011 NATA have been compared to measured values from LRAPA’s Amazon Park and Peterson Barn monitoring sites. The 

Amazon Park monitor is located in census tract 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. 

Comparison of modeled and measured concentrations, all values in μg/m3

NATA Pollutant

AMZ 2011 NATA

Modeled 

Annual Average

AMZ 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 0.00129 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 1.602 700

NICKEL COMPOUNDS 0.00028 0.00042 0.0023 0.00018 0.05

TOLUENE 2.933 5.840 2.758 7.132 5000

XYLENES (MIXED ISOMERS) 1.274 3.322 1.408 3.926 700

12
Attachment 4 

Lane Electric Cooperative, Enhanced Incentive Program for Oakridge Heat 

Pumps, August 28, 2015 
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
Attachment 5 

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

Oakridge Extension Request 2015






Attachment 6 

Supplemental Strategies Overview – Southern Willamette Forest 

Collaborative, October 2015 
1

Oakridge Air Attainment Plan for Particulate Matter 2.5

Since 2009 Oakridge has been designated by the Environmental 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 (μg/m3) based on an average of the most recent three years of federal 

reference monitoring data. 

Emissions inventory data gathered by the Lane Regional Air Pollution Agency (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 November 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 standard through 2015 a one-year extension can be granted. 

The Air Attainment partners have developed a three-part strategy that focuses on 1) 

Education, 2) Enforcement, and 3) Economic Assistance. Related short-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. 20th, 7PM), water bill,

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

Attachment 6

Oakridge Extension Request 2015
2

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. Smoke 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 extended it’s Member Assistance Program to make 

the cost of using the heat pump effectively free on declared "red days" to 

encourage less burning on those days. 

Potential long-term measures (with additional funding):

1. Education: 

a. Hire a full time coordinator to implement all air attainment programs and 

act as a coordinator between partner agencies and organization. A

coordinator that would be extremely essential in reaching the cities 

established PM 2.5 goals.

i. Estimated costs are $100,000 per year for 3 years to pay for salary, 

benefits, and travel for a full time coordinator. 

b. A designated budget for educational materials and videos for a three-year 

period is $30,000.

i. With these funds a programs could be created that target messaging

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 diversion program will be primarily an educational 

program. A fee will be assessed to the offender. There will be additional 

duties added to the Municipal Court Clerk. Annual additional costs are 

estimated at $5,000 a year for 3 years.

2. Enforcement: 

d. Train neighborhood watch, fire department, and public works personnel on 

how to measure wood smoke opacity.
3

e. Extend the code 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 full time code 

enforcement 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. Expand the DHP program to the entire community, both homeowners and 

renters, while allowing homeowners to keep certified wood stoves. 

i. The estimated costs for DHP replacement is $4,000 per household. A 

program targeting 100 homes would cost approximately $400,000.

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

survey 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 

located 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 Heating Credit offering electric-dependent homes 

compensation for electric bill on no-burnings days.

i. There are approximately 1400 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 approximately 10 days a year, is $45,000.

j. Increase Housing and Community Services Agency (HACSA) weatherization

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. Implement a community firewood program to provide seasoned firewood at 

affordable rates based on household income. There is no funding request for 

this program at this time. 

l. Reimburse 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

$100,000 3 years $300,000

Code Enforcement 

Officer

$70,000 3 years $210,000

TOTAL $1,990,000

Sarah Altemus-Pope

SW Forest Collaborative (SWFC)

swfcollaborative@gmail.com

October 23, 2015
Attachment 7 

Lane Electric Ruralite Magazine – LRAPA Oakridge Winter Wood 

Heating Article, November 2015 
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 2015
Red 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 2015-2016 Oakridge SIP Development Plan, September 2015 
1 

SIP Development Plan 

Oakridge Attainment Plan – 2015/2016 Supplement PM2.5

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

LRAPA

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 them 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 Police

Department (October

2015) 

• Wood exchange program

(TBD)

• Magnets for woodstoves

(TBD)

• Educational video for

schools (TBD)

Attachment 8

Oakridge Extension Request 2015
2 

• Additional outreach in

low-income

neighborhoods with St.

Vincent De Paul staff

(TBD)

• RACM/RACT Determination

(after attainment

demonstration)

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

LRAPA 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

August 2015: Same model as in 

2012

• Identify model inputs LRAPA January 2016

• Calculate attainment year

PM2.5 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 2015
3 

• 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 November 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