Attachment 

Comments on the November 2008 draft of the 

Oregon Regional Haze SIP 

The Forest Service recognizes the complexities in assessing visibility in Oregon’s Class I 

areas, due in part to the State’s diverse topography and source emission categories. Overall, 

ODEQ provided a comprehensive assessment of visibility impairment in Class I areas. This 

was extremely helpful in assessing the adequacy of the Reasonable Progress Goals and Long 

Term Strategy. We offer the following comments and/or request clarification of the following 

issues. 

Source Apportionment 

We suggest ODEQ to include a discussion of the contribution of secondary organic aerosols 

from biogenic emissions as natural sources of haze. A review of the WRAP TSS organic 

aerosol modeling results verifies that indeed secondary emissions from biogenic sources 

contribute a large fraction of the organic carbon observed during the summer months in the 

Wilderness areas (e.g. Mt. Hood Wilderness area). This is consistent with the finding of the 

Columbia River Gorge Visibility Study in which biogenic emissions were found to be a major 

contributor to summer-time haze. Secondary biogenic emissions can contribute significantly to 

the organic carbon portion of haze, especially during the summer months. Given the high 

impact of organic carbon to regional haze during the summer months, the lack of including 

this source category may artificially lead one to attribute the contribution to another source 

category. Please evaluate and revise this section accordingly. 

Best Available Retrofit Technology (BART) Evaluation 

The proposed Best Available Retrofit Technology (BART) limit for NOx is 0.23 lb/mmbtu 

based upon a 12-month rolling average. As in the case with NAAQS and PSD increments, we 

would like to see consistency in the averaging time of the permit limit and regional haze. 

Although regional haze is an instantaneous phenomenon, it is treated as a 24-hour average 

phenomenon throughout the BART process and New Source Review (NSR). The BART 

guidelines recommend a 30-day rolling average for utility boilers subject to the presumptive 

limits. As such, we would like to see at least an equivalent 30-day rolling average for NOx 

limits from this unit. 

Comments on Reasonable Further Progress Goals: 

As none of the Class I areas in Oregon are expected to meet the Uniform Rate of Progress 

(URP) goals by 2018, Oregon is proposing to establish Reasonable Progress Goals (RPGs) 

that provide for a slower rate of improvement in visibility, at least through 2018. While a state 

may establish reasonable progress goals that provide for a slower rate of improvement than the 

rate that would be needed to attain natural conditions by 2064, the State must, (1) demonstrate 

that URP goals are not reasonable, and (2) provide an assessment of the number of years it 

would take to attain natural conditions at the rate of progress selected by the State as 

reasonable. 
While Oregon has provided a four-factor analysis for non-BART source categories, and the 

costs of implementing some of these controls appear to the Forest Service to be reasonable, 

Oregon has concluded that it is not reasonable to require controls for these source categories at 

this time. Please clarify that (1) several of these source categories have costs that are within 

the range of what is considered reasonable under the BART or BACT programs, and (2) 

clarify why Oregon is not pursuing reducing emissions from these sources now. 

Additionally, please provide an assessment of the number of years it would take to attain 

natural conditions at the rate of progress selected by the State as reasonable. 

Comments on the Long Term Strategy: 

Fire: 

Given the potentially large impact of wildfire on haze, such events have the potential to have a 

significantly larger impact on the magnitude of the average of the 20% worst case days, more 

so than any other emission source. The Forest Service would like Oregon to recognize, in its 

regional haze SIP, the potential benefits of an implementing fuels reduction programs, 

including prescribed burning, as a strategy for reducing haze from wildfires. Such language is 

already contained in Section 629-048-0020 of the Oregon Smoke Management plan 

(Necessity of Prescribed Burning), including a description of the likely differences in air 

pollution effects of wildfires as compared with prescribed burning. 

The Forest Service agrees that prescribed burning may contribute to haze in federal Class I 

areas and further evaluation is needed. However, the methodology proposed to evaluate the 

contribution of prescribed forestry burning to haze has some inherent biases and uncertainties 

that may result in artificial attribution to this source. The Forest Service would like to work 

with ODEQ in formulating an appropriate evaluation technique, interpreting the results, and 

identifying of any potential additional control techniques to mitigate such effects. 

Non-BART Source Evaluation: 

The Forest Service would like to participate in the development of the guidance for the 

evaluation of non-BART sources to reduce regional haze. We are further concerned about 

how sources which have demonstrated that impacts from their emission unit are less than the 

0.5 dv threshold, based upon actual, not permitted emission levels. These sources may still 

have the potential to contribute to regional haze (above the 0.5 dv) threshold if their actual 

emissions increase above values used in the BART exemption modeling. 

Furthermore, we would like to see the State evaluate the cumulative source impacts from a 

grouping of sources, such as those that occur in the lower Columbia River in Northwest 

Oregon and Southwest Washington that together may cause haze in Class I areas. Such an 

approach is commonly used in the Eastern US and seems logical to apply here as well. 

Area Sources of Organic Carbon: 

Organic carbon is identified as the largest contributing aerosol species to the 20% worst-case 

days in the Class I areas of the Oregon Cascades. In the Mt. Hood Wilderness, and to a lesser 

extent in the Mt. Jefferson, Mt. Washington, and Three Sisters Wilderness areas, organic 

carbon is identified as the largest contributing source to organic carbon. However, there is no 

mention of how the State intends to address this source category as part of its Long-Term 
Strategy. Please add a discussion of area sources of organic carbon to the Long-Term Strategy 

for these wilderness areas. 

Crustal Material (Coarse Particulate Matter and Fine Soil) 

We would like Oregon to address crustal material as part of its Long-Term Strategy for Class I 

areas in Eastern Oregon, as these are more affected by this pollutant than the Oregon’s other 

Class I areas. Examination of alpine lake sediment cores from the western interior United 

States have revealed a five-fold increase in dust deposition since the early twentieth century, 

coinciding with expansion of livestock grazing1. Eastern Oregon has well known wind blown 

dust episodes which are at times implicated using the Wind Blown Dust Episode Analysis tool 

available through the WRAP TSS. We encourage ODEQ to use this tool and consider 

windblown dust not only as a natural source but also an anthropogenic source which may 

increase with land use disturbance in considering options to reduce dust emissions in the 

future. Please discuss this pollutant and potential control strategies as part of Oregon’s LongTerm Strategy. 

Sulfates: 

Sulfates from area source have been implicated as significant sources of haze causing 

pollutants in the Mt. Hood Wilderness, which are not expected to meet the 2018 URP. While 

ODEQ did addressed stationary SO2 fuel combustion sources the analysis a more thorough 

analysis is warranted considering the impact on this Class I wilderness area. In addition to 

fuel switching and post-combustion controls, which ODEQ has somewhat addressed, other 

options to reduce emissions from this source category may include working with pollution 

prevention and conservation experts to evaluate the full suite of options and make 

recommendations for future sustainability. We encourage Oregon to consider sustainability 

and energy conservation as part of its Long-Term Strategy for all pollutants, including 

sulfates. 

• The Forest Service routinely requests that SIPs include language linking the Regional Haze 

Program with the Prevention of Significant Deterioration program. We note that the PSD 

program can be an effective tool to prevent degradation of “Best Days”, and that new sources 

should be consistent with or accounted for in RH SIP revisions. 

 

1

 Neff, J.C, et al. Increasing Eolian Dust Deposition in the Western United States Linked to Human Activity. 

Nature Geoscience. Vol. 1, March 2008. www.nature.com/naturegeoscenice.